A FTSE SMALL CAP Group Counsel & Company Secretary writes...
In terms of corporate governance at board/board committee level, how are listed companies dealing with the new reporting requirements contained in the Gender Pay Gap Reporting regulations?
Where does oversight of compliance with the regulations fit into the existing corporate governance structure of a listed company?
Is responsibility for oversight of the reporting requirements coming within the scope of the Audit Committee’s terms of reference – or the Rem Com? Or is it a matter for the full board (or a special committee of the board)?
We are also doing this through RemCom although we have recognised that many of the actions that we may decide to take to address the gap fall under NomCom. We plan for our external auditors to carry out some kind of review procedures before we report.
I suppose as this is a diversity-related issue, responsibility could also lie with the Nom Com. I don’t think there is a right or wrong answer to this (someone can correct me if I’m wrong). We are using the Remcom as the data will be collected by HR and the Remcom is where the Directors’ relationship with HR mainly sits.