Equal Pay Statement and Information 2015

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1 Equal Pay Statement and Information 2015

2 Contents 1. Introduction Commitment Purpose Approach Equal Pay Information Occupational Segregation Equal Pay Statement Looking Forward Appendix A: Equal Pay Information Appendix B: Staff Grading Structure Appendix C: Occupational Segregation Appendix D: The Equality Act

3 1. Introduction 1

4 1. Introduction To meet the requirements of the Equality Act 2010, this report will detail how the College has revised its existing equal pay statement after conducting an equal pay analysis based on staff data as of 1 st April The College is one of Scotland s major education providers. Approximately 50% of our students are from Glasgow, while the rest mainly originate from other areas across Scotland, as well as the rest of the UK and overseas. The College offers education and training opportunities ranging from foundation courses through to Higher National Diplomas, as well as a number of Degree courses with our higher education partners. Courses are delivered across the following curriculum areas: Building, Engineering & Energy. Education & Society. Business. Leisure & Lifestyle. Creative Industries. Nautical Studies. The College also provides services for local businesses and employers that include professional and bespoke training courses. These external commercial courses are delivered by City Enterprises. More specialised support is also available through our specialist centres, such as the Centre for Paralegal Education and the Centre for Supply Chain Leadership. The College employs over 1,000 staff across 11 locations in the city centre, at riverside, and to the east of the city. Construction of the new campus buildings at the city centre and riverside locations begins in 2013, for completion by

5 2. Commitment 3

6 2. Commitment College Values Equality, Diversity & Inclusiveness is one of 6 core College values: The Individual. Equality, Diversity & Inclusiveness. Integrity, Honesty and Transparency. Excellence & Achievement. Partnership. Innovation & Enterprise. College Behaviours Through student and staff engagement, behaviours were identified which support the College values and promote a positive culture. These agreed behaviours are being communicated through a variety of approaches, including the Our Behaviours booklet, communication materials and workshop awareness raising sessions. Such approaches will help promote and reinforce the behaviours to ensure they become embedded within the College culture. College Strategic Aims Equality, diversity and inclusiveness are addressed within the following strategic aims: 1.2. Work with students as co-creators of their own learning that is accessible, supportive, and representative of all Provide access and progression opportunities for all Respond to the diverse and evolving needs of all students by providing effective systems of support and guidance Embed the College s commitment to equality, diversity, inclusiveness, tolerance, and respect for the individual. 4

7 Access and Inclusion The College will encourage access and inclusion, and thus widen participation, by recognising, prioritising and meeting the needs of individuals and groups which comprise the communities the College serves. Some key enablers of access and inclusion include: Curriculum Design. Marketing and Communications. Community Engagement. Student Recruitment and Selection. Student Funding. Student Services. Student Learning Support. HR Recruitment and Selection. Diversity & Equalities Policy and Mainstreaming Vision The College s Diversity & Equalities (D&E) Policy details the aims, scope and responsibilities for D&E. As stated, the College s Equalities Mainstreaming Vision is: To nurture an environment in which the diversity and equality of students and staff from all backgrounds is routinely anticipated, expertly accommodated and positively celebrated. Diversity & Equalities Statement We will positively promote equality, diversity and human rights for all. In doing so, the College will: Foster good relations based on dignity and respect; Advance equality of opportunity for individuals; and Eliminate harassment, victimisation and discrimination. 5

8 6

9 3. Purpose 7

10 3. Purpose The College welcomes the opportunity to report its progress, over the past year, in meeting the requirements of the specific duties under the Equality Act 2010, through its strategy, operations and culture. For a summary of the general and specific equality duties of the Equality Act 2010, please refer to Appendix D. The purpose of this report is to outline progress in meeting the following specific duties: Publish gender pay gap information in relation to the percentage difference among staff between men s average hourly pay and women s average hourly pay. The College has used this opportunity to review and enhance its statement on equal pay in relation to men and women, specifying occupational segregation. The duties to gather staff data and report progress in mainstreaming the equality duty will be reported in the separate Equality Mainstreaming Report The duty to report progress in achieving the College s equality outcomes will also be reported separately. Equality statutory reports, together with completed equality impact assessments, are available from the Diversity & Equalities section of the College s website, accessed directly from the home page. 8

11 4. Approach 9

12 4. Approach Following the implementation of job evaluation in January 2013, an equal pay analysis was undertaken in order to enable the College to monitor the pay gap that exists between men and women and, in doing so, comply with its obligations in accordance with the Equality Act 2010 specific duties in Scotland. The College held meetings with Close the Gap to ensure that any activity was aligned with the Equality Act 2010 and, through building this relationship, the guidance received has been used to inform the College during this process. Feedback was provided by Close the Gap on the College s Equal Pay Policy and Statement and provision of horizontal and vertical segregation data. In the interests of transparency, the analysis included all roles as at 1 st April The analysis was conducted by gathering information from the College HR database, where all person specific data is held. This information was then collated and manipulated to populate the tables contained within the appendices of this document. The data was then analysed to produce the additional narrative. The data provided is accurate as of 1 st April

13 5. Equal Pay Information 11

14 5. Equal Pay Information Appendix A details the equal pay formula and information summary. Please refer to Appendix B, detailing the staff grade structure. Prior to conducting job-evaluation, the Gender Pay Gap for the City of Glasgow College was 13%. During the previous equal pay analysis, conducted in 2013, the mean average hourly rate was The differential between male employees and female employees was 2.09; versus This resulted in a Gender Pay Gap of 12.8%. The mean average hourly rate is The differential between male and female employees is 2.18; compared to This did however exclude the top two staff within the College, both of whom are men. Following the Equal Pay analysis in 2013, the College has since undergone a restructuring exercise. This resulted in a reduction in the number of managers within the College, with 31 staff accepting voluntary severance packages. In addition, some staff transferred to new pay grades following the end of their salary protection. The current Gender Pay Gap for the City of Glasgow College is 13.98%. The mean average hourly rate is The differential between male and female employees is 2.45; compared to In the interests of transparency, this figure is inclusive of the two most senior members of staff within the College. By including the top two most senior College staff in the analysis allows the College to externally benchmark itself with other Scottish colleges and other public authorities in other sectors. 12

15 6. Occupational Segregation 13

16 6. Occupational Segregation The current split of male to female overall within the College is 535 to 661. The distribution of male to female varies across Teaching Staff and Support Staff within the College. Refer to Appendix C which details horizontal and vertical segregation for support staff, followed by academic staff. Refer to Tables 4-18 in Appendix C, detailing horizontal and vertical segregation for support staff. Within the support cohort overall there is a significant variance in the distribution of male to female staff, 195 to 320, there are also significant variances within certain departments, e.g. in Finance Directorate, with 14 male to 55 female; People & Culture Directorate, with 3 male to 20 female; and Infrastructure, with 78 male to 91 female staff. In January, 2013, to better support the gender equality agenda, the College completed a full review of all support roles and the salary and grading structure through conducting a Job Evaluation exercise. This ensures that going forward staff will receive equal pay for work of equal value. Between January 2013 and December 2015, the College has been aligning salaries for staff whose post has been down-graded and were currently paid above the rate for the job. Any salary protection will be reduced/removed after that date and this will further align salaries and lessen the Gender Pay Gap. Refer to Tables in Appendix C for a detailed presentation of horizontal and vertical segregation for teaching staff. Within the teaching cohort overall there is almost an equal distribution of male to female staff, 340 to 341. However within certain Faculties there are significant variances, e.g. Nautical Studies, 49 male to 3 female staff; Building, Engineering & Energy, 75 male to 7 female staff; and Business, 57 male to 84 female staff. It must be noted however that within relevant industries this differential would also be present as historically Hairdressing and Beauty would be predominantly staffed by females and Building and Construction would historically be staffed by males. In order to reduce occupational segregation and the Gender Pay Gap, the College will ensure that the relevant policies and processes are consistently applied and that all staff involved in recruitment and selection have been appropriately trained and are aware of the implications of conscious and unconscious bias. 14

17 7. Equal Pay Statement 15

18 7. Equal Pay Statement Introduction It is the City of Glasgow College s policy to provide equality to all, irrespective of the following protected characteristics: age, disability, gender reassignment, marriage and civil partnership status, pregnancy and maternity, race (including colour, nationality, ethnic or national origins), religion or belief, sex (formerly gender) and sexual orientation. The College s Diversity & Equalities Policy sets out the College s overall aims, within a Diversity & Equalities Statement: We will positively promote equality, diversity and human rights for all. In doing so, the College will: Foster good relations based on dignity and respect; Advance equality of opportunity for individuals; and Eliminate harassment, victimisation and discrimination. Equal Pay Statement City of Glasgow College is committed to the principles of equality in employment and believes that staff should receive equal pay for the same or broadly similar work, or work rated as equivalent and for work of equal value, regardless of their age, disability, ethnicity or race, gender reassignment, marital or civil partnership status, pregnancy, political beliefs, religion or belief, sex or sexual orientation. City of Glasgow College understands that the right to equal pay between women and men is a legal right under both domestic and European Law. In addition, the Equality Act 2010 (Specific Duties) (Scotland) Regulations 2012 require the College to taking the following steps: Publish any sex (gender) pay gap information, initially as at April 2013, and regularly updating this (no later than on a biannual basis). 16

19 Publish a statement on equal pay between men and women to include the protected characteristics of race and disability in the second and subsequent statements from 2017 onwards. It is good practice and reflects the College value of Equality, Diversity & Inclusiveness that pay is awarded fairly and equitably. The College recognises that horizontal and vertical segregation currently exists and will ensure that the College policies and processes are consistently applied to reduce Organisational Segregation and the Gender Pay Gap. In order to achieve equal pay for employees doing the same or broadly similar work, work rated as equivalent, or work of equal value, it should operate pay systems which are transparent, based on objective criteria and free from unlawful bias. Statement Objectives and Actions Our objectives, in line with the Public Sector Equality Duty of the Equality Act 2010, are to: Eliminate unfair, unjust or unlawful practices and other discrimination that impact on pay equality. Advance equality of opportunity and the principles of equal pay throughout the workforce. Foster good relations between people sharing different protected characteristics in the implementation of equal pay. We will: Inform employees as to how pay practices work and how their own pay is determined. Provide training and guidance for managers and for those involved in making decisions about pay and benefits and grading decisions. Examine our existing and future pay practices for all our employees, including part-time workers, those on fixed term contracts or contracts of unspecified duration, and those on pregnancy, maternity or other authorised leave. 17

20 Undertake regular monitoring of the impact of our Recruitment and Selection practices in line with the requirements of the Equality Act Terms and Conditions of employment will be consistently applied for all new employees of the College. Ensure that all staff who are involved in selection interviews undergo training which explicitly highlights the College s duties under the Equality Act 2010, as well as the effects of conscious and unconscious bias. Conduct a bi-annual analysis of pay data, based upon mean (average) data, within the equal pay review, with results presented as a Gender Pay Gap Percentage. Compare the College pay gap with the other Colleges within the Glasgow Region as well as the remainder of Scotland. In addition, the Further-Education sector will be benchmarked against other public authority sectors. Key Commitments The College has concluded an analysis of pay data (April 2015) following its recently implemented Job Evaluation Programme and previous equal pay analysis (Jan 2013). The Gender Pay Gap is 14% (13.98%). Contributing to the Gender Pay Gap are: Continued higher proportion of staff in senior positions which are occupied by men. Historical differences in Terms and Conditions of Employment following the merger of the three Colleges into City of Glasgow College. Large percentile of staff with long service that have progressed through the grades. In mitigation, the College has concluded their Job Evaluation process and recognises that Horizontal and Vertical segregation currently exists. In order to reduce the Gender Pay Gap the College will consistently apply the relevant policies and procedures to reduce both Organisational Segregation and the Gender Pay Gap. 18

21 The College will also, in addition to making readily available the College s Equal Pay Statement: Maintain a systematic job evaluation scheme which incorporates the principles of equal pay. Conduct an Equal Pay Review to ensure any service related entitlements can be justified on the grounds of rewarding loyalty, maintaining motivation and reward for higher levels of skills and experience e.g. salary, annual leave, occupational sick pay, etc. As part of the Equal Pay Review, ensure that pay and organisational structures identify and target barriers which may result in horizontal and vertical occupational segregation. Conduct a detailed examination into the distribution of vertical and horizontal segregation which exists across College faculties and directorates and use this information to inform workforce planning, staff training and College policy. Improve workforce planning and use analysis to target staff development opportunities considering the barriers to progression. Review staff benefits ensuring men and women have equitable access to these, e.g. pension, occupational sick pay, employee counselling etc., as part of the Equal Pay Review. Regularly monitor and review results of relevant analyses bi-annually, in partnership with Trade Union and Staff Representatives. Respond promptly to grievances or complaints on equal pay. Responsibilities Board of Management As the governing body of the College, the Board and its Sub Committees, specifically the Students, Staffing, and Equalities Committee are responsible for ensuring that the College complies with its statutory obligations in terms of equal pay. The Board will regularly consider equalities matters including equality monitoring and annual achievement of Equality outcomes. 19

22 The Principal Will be responsible for ensuring that the College commitment to diversity and equalities including equal pay is implemented; that training and guidance is provided for those making decisions regarding remuneration and that the equal pay policy statement is communicated to internal and external parties. Executive Director People & Culture Will be responsible for: Ensuring that pay, benefits and reward systems are kept under regular review and that statistical analysis is undertaken on an annual basis. Advising on the authorising of job specifications, post profiles and appropriate salary levels to ensure that equal pay issues are given appropriate consideration. Provide Recruitment and Selection awareness, and focused training for all relevant managers, to ensure all staff are aware of the equal pay policy and statement. Communicating the policy statement, via internal communication platforms, to ensure all staff are aware of the wider equality related issues. Ensuring that key information on equal pay statistics is published in accordance with the College s statutory duties. All Senior Staff, Managers & Supervisors Will be responsible for: Implementing the policy statement. Following any relevant procedures relating to equal pay and, where appropriate, seeking appropriate advice and guidance. Ensuring that employees know and understand their responsibilities regarding equal pay and, where appropriate and necessary, receive support and training in carrying these out to ensure the College achieves the legal requirements under the Equality Act

23 Complaints and Grievances An employee concerned about discriminatory action in relation to equal pay should in the first instance use the College Grievance Procedure in order to achieve internal resolution. Monitoring The Executive Director People & Culture will monitor and review this policy, consulting with employee and trade union representatives as appropriate, on changes being required due to changes in line with legislation or best practice. 21

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25 8. Looking Forward 23

26 8. Looking Forward The report identified a Gender Pay Gap of 14% (13.98%) and examined vertical and horizontal occupational segregation between men and women. This information informed and supported the development of the College s Equal Pay Statement, including objectives and actions. Through the responsibilities of key staff groups, the College is committed to communicating and delivering these objectives and actions. The College will again publish Gender Pay Gap information by April This will allow any additional revisions to be identified and made. Finally, the College will extend the equal pay statement and analysis of occupational segregation to cover disability, race and gender by April This document is available in alternative formats upon request. For more information, please call /1587, or contact 24

27 Appendices 25

28 Appendix A: Equal Pay Information Table 1: Proportion of Staff by Male and Female at 1 st April 2015 Staff Number Percentage Female % Male % Total 1, % Table 2: Hourly Pay and Rate by Gender for all staff role at 1 st April 2015 Staff Averages Total Hourly Average Mean Average 19, Female Average (A) 9, Male Average (B) 9, * Percentage Pay Gap Calculation (A / B) X 100 = Total 100 Total = Pay Gap Percentage Pay Gap Calculation (15.08/17.53) X 100 = = 13.98% 26

29 Appendix B: Staff Grading Structure Table 3: Staff Grading Structure Grade Minimum Salary Maximum Salary Minimum Point Bar Point Maximum Point 10 55,000 65,000 - N/A ,820 47, N/A ,449 41, N/A ,232 36, N/A ,903 31, N/A ,219 28, N/A ,157 24, N/A ,159 21, ,907 18, ,140 16,

30 Appendix C: Occupational Segregation Support Staff Table 4: Overall Support Staff Staff Grades Male Female Total Principal 100% (1) 0% (0) 100% (1) Depute Principal 100% (1) 0% (0) 100% (1) Vice Principals 0% (0) 100% (1) 100% (1) Directors 46.2% (6) 53.8% (7) 100% (13) Heads of Service 50.0% (10) 50.0% (10) 100% (20) Grade % (2) 33.3% (1) 100% (3) Grade % (8) 61.9% (16) 100% (24) Grade % (12) 53.8% (14) 100% (26) Grade % (20) 55.6% (25) 100% (45) Grade % (19) 62.7% (32) 100% (51) Grade % (9) 25.0% (3) 100% (12) Grade 3 Bar 45.5% (20) 54.5% (24) 100% (44) Grade % (10) 81.1% (43) 100% (53) Grade 2 Bar 25.4% (18) 74.6% (53) 100% (71) Grade % (20) 20.0% (5) 100% (25) Grade 1 Bar 31.2% (39) 68.8% (86) 100% (125) College Total 37.86% (195) 62.14% (320) 100% (515) 28

31 Table 5: The Principal and Executive Leadership Team Staff Grades Male Female Total Principal Depute Principal Vice Principals Total

32 Table 6: Business Faculty Support Staff Staff Grades Male Female Total Director Grade Grade Grade Grade Grade Grade Grade 3 Bar Grade Grade 2 Bar Grade Grade 1 Bar Faculty Total

33 Table 7: Building, Engineering & Energy Faculty Support Staff Staff Grades Male Female Total Director Grade Grade Grade Grade Grade Grade Grade 3 Bar Grade Grade 2 Bar Grade Grade 1 Bar Faculty Total

34 Table 8: Creative Industries Faculty Support Staff Staff Grades Male Female Total Director Grade Grade Grade Grade Grade Grade Grade 3 Bar Grade Grade 2 Bar Grade Grade 1 Bar Faculty Total

35 Table 9: Education & Society Faculty Support Staff Staff Grades Male Female Total Director Grade Grade Grade Grade Grade Grade Grade 3 Bar Grade Grade 2 Bar Grade Grade 1 Bar Faculty Total

36 Table 10: Leisure & Lifestlye Faculty Support Staff Staff Grades Male Female Total Director Grade Grade Grade Grade Grade Grade Grade 3 Bar Grade Grade 2 Bar Grade Grade 1 Bar Faculty Total

37 Table 11: Nautical Studies Faculty Support Staff Staff Grades Male Female Total Director Grade Grade Grade Grade Grade Grade Grade 3 Bar Grade Grade 2 Bar Grade Grade 1 Bar Faculty Total

38 Table 12: Finance Directorate Support Staff Staff Grades Male Female Total Director Heads of Service Grade Grade Grade Grade Grade Grade Grade 3 Bar Grade Grade 2 Bar Grade Grade 1 Bar Directorate Total

39 Table 13: People & Culture Directorate Support Staff Staff Grades Male Female Total Director Heads of Service Grade Grade Grade Grade Grade Grade Grade 3 Bar Grade Grade 2 Bar Grade Grade 1 Bar Directorate Total

40 Table 14: Corporate Development Directorate Support Staff* Staff Grades Male Female Total Director Heads of Service Grade Grade Grade Grade Grade Grade Grade 3 Bar Grade Grade 2 Bar Grade Grade 1 Bar Directorate Total *This table includes SWAP West Staff 38

41 Table 15: New Campus & Student Development Support Staff Staff Grades Male Female Total Director Heads of Service Grade Grade Grade Grade Grade Grade Grade 3 Bar Grade Grade 2 Bar Grade Grade 1 Bar Directorate Total

42 Table 16: Infrastructure Directorate Support Staff Staff Grades Male Female Total Director Heads of Service Grade Grade Grade Grade Grade Grade Grade 3 Bar Grade Grade 2 Bar Grade Grade 1 Bar Directorate Total

43 Table 17: Performance Staff Grades Male Female Total Directors Heads of Service Grade Grade Grade Grade Grade Grade Grade 3 Bar Grade Grade 2 Bar Grade Grade 1 Bar Directorate Total

44 Table 18: Exectutive Office & College Secretary Staff Grades Male Female Total Directors Heads of Service Grade Grade Grade Grade Grade Grade Grade 3 Bar Grade Grade 2 Bar Grade Grade 1 Bar Directorate Total

45 Teaching Staff Table 19: Overall Teaching Staff Staff Grades Male Female Total Curriculum Head 53.2% (25) 46.8% (22 ) 100% (47) Senior Lecturer 63.8% (37) 36.2% (21) 100% (58) Lecturer 48.1% (272) 51.9% (293) 100% (565) Faculty Total 49.9% (334) 50.1% (336) 100% (670) 43

46 Table 20: Business Faculty Teaching Staff Staff Grades Male Female Total Curriculum Head 33.3% (3) 66.7% (6) 100% (9) Senior Lecturer 81.8% (9) 18.2% (2 ) 100% (11) Lecturer 37.2% (45) 62.8% (76 ) 100% (121) Faculty Total 40.4% (57) 59.6% (84) 100% (141) 44

47 Table 21: Building, Engineering & Energy Faculty Teaching Staff Staff Grades Male Female Total Curriculum Head 100% (5) 0% (0) 100% (5) Senior Lecturer 88.9% (8) 11.1% (1) 100% (9) Lecturer 91.2% (62) 8.8% (6) 100% (68) Faculty Total 91.5% (75) 8.5% (7 ) 100% (82) 45

48 Table 22: Creative Industries Faculty Teaching Staff Staff Grades Male Female Total Curriculum Head 71.4% (5) 28.6% (2) 100% (7) Senior Lecturer 77.8% (7) 22.2% (2) 100% (9) Lecturer 57.3% (59) 42.7% (44) 100% (103) Faculty Total 59.7% (71) 40.3% (48) 100% (119) 46

49 Table 23: Education & Society Faculty Teaching Staff Staff Grades Male Female Total Curriculum Head 28.6% (2) 71.4.% (5) 100% (7) Senior Lecturer 14.3% (1) 85.7% (6) 100% (7) Lecturer 27.0% (27) 73.0% (73) 100% (100) Faculty Total 26.3% (30) 73.7% (84) 100% (114) 47

50 Table 24: Leisure & Lifestyle Faculty Teaching Staff Staff Grades Male Female Total Curriculum Head 33.3% (4) 66.7% (8 ) 100% (12) Senior Lecturer 41.7% (5) 58.3% (7) 100% (12) Lecturer 33.0% (38) 67.0% (77) 100% (115) Faculty Total 33.8% (47) 66.2% (92) 100% (139) 48

51 Table 25: Nautical Studies Faculty Teaching Staff Staff Grades Male Female Total Curriculum Head 100% (5) 0% (0) 100% (5) Senior Lecturer 100% (6) 0% (0) 100% (6) Lecturer 92.7% (38) 7.3% (3) 100% (41) Faculty Total 94.2% (49) 5.8% (3) 100% (52) 49

52 Table 26: Student Development Teaching Staff Staff Grades Male Female Total Curriculum Head 0% (0) 0% (0) 100% (0) Senior Lecturer 25.0% (1) 75.0% (3) 100% (4) Lecturer 7.7% (1) 92.3% (12) 100% (13) Faculty Total 11.8% (2) 88.2% (15) 100% (17) 50

53 Table 27: Corporate Development Teaching Staff Staff Grades Male Female Total Curriculum Head 50% (1) 50% (1) 100% (2) Senior Lecturer 0% (0) 0% (0) 100% (0) Lecturer 50% (2) 50% (2) 100% (4) Directorate Total 50% (3) 50% (3) 100% (6) 51

54 Appendix D: The Equality Act 2010 The full Equality Act 2010 can be accessed through this link: Equality Act Introduction and Protected Characteristics The purpose of the Equality Act is to streamline, strengthen and harmonise 40 years of equalities legislation. The Act establishes 9 protected characteristics. These are: Age. Marriage & Civil Religion or Belief. Disability. Partnership. * Sex. Gender Pregnancy & Maternity. Sexual orientation. Reassignment. Race. Public Sector Equality Duty (General Duty) A public authority must, in the exercise of its functions, have due regard to the need to: a) Eliminate discrimination, harassment, victimisation and any other conduct that is prohibited by the Act; * b) Advance equality of opportunity between persons who share a relevant protected characteristic and persons who do not share it; c) Foster good relations between persons who share a relevant protected characteristic and persons who do not share it. * All protected characteristics (with the exception of marriage & civil partnership) are subject to the full duty. The duty also covers marriage & civil partnerships, with regard to section a) in employment. The public sector equality duty; can be accessed through this link: Equality Duty. Refer to Figure 1 below for further information: Figure 1. 52

55 Public Sector Specific Equality Duties (Scotland) The final regulations, which came into effect on 27th May 2012, can be accessed through this link: Specific Duties (Scotland). Duty to Report Progress on Mainstreaming the Equality Duty Publish a mainstreaming report on the progress made to make the general equality duty integral to the exercise of its functions so as to better perform the duty: o No later than 30th April 2013; and o Subsequently at intervals of no more than 2 years, beginning with the date on which it last published a report. Duty to Publish Equality Outcomes and Report Progress Prepare and publish a set of equality outcomes, which is considered to enable better performance of the general equality duty: o No later than 30th April 2013; and o Subsequently, at intervals of no more than 4 years, beginning with the date on which it last published a set of equality outcomes. In preparing a series of outcomes: o Take reasonable steps to involve persons who share a relevant protected characteristics/those who represent the interests of those persons; and o Consider relevant evidence relating to persons who share a relevant protected characteristic. Publish reasons if equality outcomes do not cover every relevant protected characteristic in relation to further the general equality duty. Publish a report on the progress made to achieve the published equality outcomes: o No later than 30th April 2015; and o Subsequently, at intervals of no more than 2 years, beginning with the date on which it last published a report. 53

56 Duty to Assess and Review Policies and Practices Assess the impact of applying a proposed new or revised policy or practice against the needs of the general equality duty. In making the assessment, consider relevant evidence relating to persons who share a relevant protected characteristic (including any received from those persons). In developing a policy or practice, take account of these results. Publish, within a reasonable period, the results of any assessment made. Make arrangements to review and revise any policy or practice to ensure that it complies with the general equality duty. Any consideration as to whether or not it is necessary to assess the impact of applying a proposed new or revised policy or practice is not to be treated as an assessment of its impact. Duty to Gather and use Employment Information Take steps to gather information on the number and relevant protected characteristics, in each year, of the: o Composition of the authority s employees; and o Recruitment, development and retention of employees. Use this information to better perform the general equality duty. Report progress within the mainstreaming report, including: o Annual breakdown of information gathered, which has not been previously published elsewhere; and o Details of the progress made in gathering and using that information to enable it to better perform the general equality duty. 54

57 Duty to Publish Gender Pay Gap Information Publish information on the percentage difference among staff between men s average hourly pay (excluding overtime) and women s average hourly pay (excluding overtime). Publish this information no later than 30th April 2013 and every second year thereafter. Duty to Publish Statements on Equal Pay, etc Publish a statement containing the required information no later than 30th April 2013 and every fourth year thereafter. The statement must specify the policy on equal pay among its employees between: o Women and men; o Persons who are disabled and persons who are not; and o Persons who fall into a minority racial group and persons who do not. The statement must specify occupational segregation among its employees in relation to the concentration of: o Women and men; o Persons who are disabled and persons who are not; and o Persons who fall into a minority racial group and persons who do not. The first statement (therefore no later than 30st April 2013) must contain information on women and men. The second statement (therefore no later than 30st April 2017) and subsequent statements must contain information on gender, disability and race. 55

58 Duty to Consider Award Criteria and Conditions in Public Procurement When relevant and proportionate to the subject matter of an agreement for goods, works, or services, institutions should have due regard to whether the award criteria of the agreement and the contract conditions relating to the performance of the agreement should include considerations relevant to its performance of the general equality duty. Duty to Publish in a Manner that is Accessible, etc. When producing the mainstreaming report, outcomes and subsequent progress, Gender Pay Gap information and equal pay statements, the authority must: o Publish in a manner that makes the information published accessible to the public; and o So far as practical, employ an existing means of public performance reporting. 56

59 Figure 1: The General Duty of the Equality Act 2010 Components A public authority must, in the exercise of its functions, have due regard to the need to: Due Regard Having due regard specifically involves taking steps to: a) Eliminate discrimination, harassment, victimisation and any other conduct that is prohibited by the Act, i.e. to ensure fairness. b) Advance equality of opportunity between persons who share a relevant protected characteristic and persons who do not share it, i.e. to advance opportunity. a) Remove or minimise disadvantages suffered by persons who share a relevant protected characteristic that are connected to that characteristic. b) Take steps to meet the needs of persons who share a relevant protected characteristic that are different from the needs of persons who do not share it. c) Encourage persons who share a relevant protected characteristic to participate in public life or in any other activity in which participation by such persons is disproportionately low. c) Foster good relations between persons who share a relevant protected characteristic and persons who do not share it, i.e. to foster respect. a) Tackle prejudice. b) Promote understanding. Due regard comprises two linked elements: proportionality and relevance. The weight that public authorities give to equality should be proportionate to how relevant a particular function is to equality. In short, the greater the relevance of a function to equality, the greater the regard that should be paid.

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