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The deadline for housing associations with over 250 employees to report their gender pay gaps has now passed and the figures which are available on the government's portal make for interesting reading.

Not only larger housing associations have reported, some with fewer than 250 employees who were not required to report as a matter of law, have nevertheless chosen to do so.

What needs to be done?

The Equality Act (Gender Pay Information) Regulations 2017 came into force on 6 April 2017 and private or voluntary sector employers with at least 250 employees must report their gender pay gap data by 4 April 2018.

As a quick reminder employers are required to report the following on an annual basis:

  • The overall gender pay figures calculated using both the mean and the median based on the snapshot date of 5 April;
  • The number of men and women in each of four salary quartiles, based on the employer's overall pay range. This will show how the gender pay gap differs across the organisation, at different levels of seniority; and
  • Separate information on the mean and median gender pay gap relating to bonuses.

The report must be signed by the CEO and will appear on the Government's dedicated website and the employer's own website for at least three years. The employer can also include a narrative explaining their figures and any plans to address the gender pay gap.

Emerging trends in the housing sector

Although there are no two housing associations alike, some trends have started to emerge. Generally the median pay gap is not too high, with a significant number of housing associations reporting a gap of less than 5% and some even reporting a "reverse gap" (i.e. a gap in favour of women). That said, there are some housing associations reporting gaps well above the national average, including gaps going over 30%. Although the gender pay gap in this sector is not a glaring one, it is still an issue which providers will have to tackle.

Although in some instances there are women in Chief Executive and other senior roles, it is not uncommon for them to be under- represented in more senior levels of the organisation. Another common theme is the prevalence of women in part-time roles, which may have a particular impact on the bonus gap, which is reported as a comparison of total value, and not a pro rated hourly rate.

The gender imbalance in repairs and maintenance roles has been highlighted in some of the reports. Historically these have been more male dominated as they typically attract male employees. These types of roles offer additional payments for overtime, standby and callouts and therefore more men tend to be eligible for them than women.

What about housing associations care businesses?

The social care sector is notable for reports of a zero or even negative gender pay gap for employers with standalone care businesses. However, the picture is somewhat different for housing associations with care businesses. Comparisons may not always be consistent because sometimes there isn't a single employer for the two functions. However, there are examples of employers with both housing and care businesses having a higher gender pay gap because of the historically better terms of men in repairs and maintenance and asset management, and poorer terms for women in social care.

Possible solutions

Some fairly detailed plans for improvement have been produced to accompany the gender pay reports. One of the key issues earmarked is that of female career progression and the need to identify those who have the potential to grow into more senior roles. Proposed solutions include putting extra support in place, such as mentoring programmes and coaching to encourage women to develop the skills and knowledge required to obtain more senior positions.

The implementation of a "Women in Leadership" programme aimed at improving skills and opportunities is another solution. Some organisations also plan to put in place cross-organisational working groups of men and women to discuss the challenges, barriers, opportunities and support required to close the gender pay gap.

Some organisations have committed to reviewing their recruitment and selection processes to prevent any unintentional gender bias, and to ensuring that, wherever possible, there is a mix of genders on interview panels. Encouraging women taking maternity leave to return to work by enhancing their maternity provision is another measure which is considered.

A conscious effort is being made on the part of some organisations to attract women to construction and maintenance roles which have traditionally been held by men. Other things which employers state that they have found useful include mandatory diversity training, and having a wide range of flexible working options to enable employees to manage their work/life balance.

The importance of having a narrative

The provision of contextual information about the findings of a gender pay gap is entirely voluntary, however providing a narrative is a useful way of explaining any particular circumstances or anomalies that have led to any gender pay gap that is discovered. A narrative can explain discrepancies in pay across the organisation, the existence of skills shortages for any roles which may lead to a salary premium, the extent to which overtime is routinely worked and the proportion of men and women regularly working overtime. It can also contain details of bonus schemes, as well as details of any action being taken by the employer to narrow the gender pay gap.

Once an employer has committed to an action plan it is important to follow it through. As gender pay information has to remain on the employer's website for three years it will be obvious if the action plan has not been implemented, or has had little impact. One point worth noting is that the snapshot date for next year's report has also just past, so these improvement plans will not necessarily have any impact until the reports in 2020.