A FTSE SMALL CAP Group Counsel & Company Secretary writes...
The time is approaching (April 2018) by which all relevant companies must have published their Gender Pay Gap Reporting information.
Are companies proposing to include commentary on that reported information and/or any statements about what they are going to do (if anything) as a result of having published the information? If so, what form will that take?
Is there a view that any such commentary/statements only go with the reported information itself (and not elsewhere) or whether the company’s next published report and accounts will include the commentary/statements – in which case whereabouts in the Report & Accounts would you put this?
I’m particularly interested in what listed companies with a 31 March year end are doing, i.e. those having to publish the information by April 2018, but not publish y/e 31 March 2018 report and accounts until June 2018. Would one include in the latter any commentary/statements on the former?
To answer the question raised in the post on 5 Jan at 2.45pm, yes, we face the same issue (in fact, an extreme version of it) – we have one UK employing entity with over 1000 employees, so will report in respect of that, but (for obscure historic reasons) the holding plc only has 2 employees (who are the two executive directors). In one sense it could look odd that the two executive directors (being the highest remunerated employees in the group by some considerable margin) are not included in the reported GPG information. But given that their remuneration details are of course reported in huge detail, we may on the plc website simply include a narrative comment to explain the situation.
We intend to post a commentary, there are some examples out there on websites including United Utilities and Kuehne and Nagel.
Our Plc business is made up of 3 separate Ltd trading entities each employing more than 250 people therefore each will Gender Pay Report individually. Plc only has a handful of employees and therefore not required to report but will look strange that no Gender Pay Reporting on plc website unless we simply narrative report and point to the subsidiaries – anybody facing similar ?
1) Yes, our intention is to provide a brief covering statement from the CEO explaining the reasons behind our gender pay gaps, and the actions we are taking to address them.
2) We intend to include the commentary (perhaps not in full but a reference to it) in the next published report and accounts.
3) We are a 31 March year end and intend to reflect the above when we publish in June.