Equal Pay Audit.
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- Dortha Howard
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1 Equal Pay Audit In 2011 Hampshire Constabulary concluded an Equal Pay Audit for Police Staff. This audit covers the areas of gender pay gap and in part occupational segregation. The constabulary has not conducted such an audit in respect of police officers however this has been completed on a national basis. Part 1 of the Winsor Independent Review of Police Officer and Staff Remuneration and Conditions can be viewed here: The executive summary for the Hampshire Constabulary Equal Pay Audit for Police Staff is included below. Hampshire Constabulary Equal Pay Audit 2010/2011 Executive Summary This report sets out the findings of the Equal Pay Audit of Police Staff pay for the period April to September 2009, and sets out the recommendations for further action. 1. Equal Pay Audit It is recommended best practice (European Human Rights Commission), and a legal requirement under the Equality Act of 2010, for the Force to carry out an Equal Pay Audit (EPA) on an annual basis in respect of gender only. Prior to this the right to equal pay was legislated within the Equal Pay Act 1970, the Sex Discrimination Act 1975 and other legislation, much of which is now encompassed by the Equality Act This is the first comprehensive equal pay audit to be carried out by the Force and encompasses gender, ethnicity, disability and age. The sample data used is for all police staff in the Force and, additionally, for Call Management, Transport, Criminal Justice, Finance and Human Resources. The audit has been carried out using internal resources with some external quality assurance of the process. The pay areas covered are basic salary and salary plus overtime where overtime has been earnt. Limited work has been carried out on other payments and allowances including local discretionary payments due to resource constraints and the scope of the work required.
2 Ethnicity encompasses all staff who are recorded following self designation as other than white british and does not differentiate between the different groups within the characteristic. It should be noted that the information with regard to Ethnicity and Disability, in particular, is limited due to low levels of declaration. It is therefore difficult to reach accurate conclusions in respect of disability. Variances are calculated against the Force average for the grade and also against the department average for the grade in the five departments analysed. The variances parameters recommended and used in this audit are +/-5% or any pattern of +/-3%. 2. Findings Staff basic pay 2.1.1i 2.1.1ii 2.1.1iii 2.1.1iv The disparities in basic salaries between the genders for staff within Hampshire Constabulary are all under +/-5% across the nineteen pay scales, with one exception. A variance in a scale PO3 post exists in Criminal Justice which is due to the new appointment of a female member of staff at the bottom of the scale. The gender imbalance in senior management scales identified in the 2007 audit shows no change in Of the fifteen posts in HM grades E to AA, thirteen are held by male staff, with all six posts at scale E held by men. There is no pattern of variation of +/- 3% which would suggest the need for further analysis. Departments The internal variance across the departments is within the +/-5% variance with the exception of the Finance department where there is a variance in the HM grade G posts Ethnicity 2.1.2i 2.1.2ii 2.1.2iii 154 police staff are classified as other than white british, representing 5.5% of the total workforce of The variance in basic salaries for these staff against others on the same scale ranges from to +2.31, so within the +/-5% range. Ethnic minority staff are represented in twelve of the nineteen pay scales and less visible in the scales from PO3 to HM grade AA where they are represented in only three of the nine middle to senior management scales. Departments
3 Of the five departments considered in detail, staff designated as other than white british are represented in all departments. The disparities in basic salaries between those who have designated themselves other than white british and all other police staff is under 5% when compared against the Force and internally Disability 2.1.3i 2.1.3ii 2.1.3iii In respect of disability, only 31 staff (18 female and 13 male) of the total 2777 police staff have declared a disability. These staff are represented in eight of the nineteen pay scales, with none in the nine pay scales from PO3 to HM grade AA. The variance in basic salaries for these staff against others on the same scale ranges from to +3.54, so within the +/-5% range. Departments Age Of the five departments considered in detail, no staff with disabilities are recorded in the Transport or Human Resources departments. Variances in the other three departments are within +/-5% i 2.1.4ii 2.1.4iii 2.1.4iv 2.1.4v Within the Force as a whole, staff are represented in all of the seven age bands covering the age range 16 to 75+, but are mainly concentrated in the age bands from The variance in pay across the seven age bands against each of the nineteen pay scales indicates that two scales showed a variance greater than +/-5%. In scale 1, the lower range is in the age band with the upper range at the same scale being in the and age bands. Further analysis clarified that the relates to one male member of staff who had only two months service as at September 2009 and was on the bottom of the scale 1 pay scale range. In HM grade D, the variance is (male in age band 45 54) to (female age band 45 54). This variation again relates to length of service. The range across all other grades was to so within the +/-5% tolerances Departments
4 Across the departments analysed, only the Transport department had no variance in basic pay across the age bands which was outside the +/-5% parameters i Where the variances outside the acceptable parameters occur, the highest variance, in Criminal Justice, is due to staff turnover in one post and a new appointment at the bottom of the pay scale. The other variances are also length of service related. Additionally, in Call Management bulk recruitment, and the extended incremental pay scale for Call handling staff, also contribute to a higher level of variance (-7.74) 3. Staff Basic Pay and Overtime 3.1 The need for, and the availability of, overtime is dependent on role and this is a contributing factor to variance in pay across the Force and the specific departments considered. The average total pay for each grade in each department will therefore be different. Overtime was paid to staff in grades 2 to HM grade G during the period April to September Gender In respect of gender, female staff are completing more additional hours at plain time than their male colleagues. This is to be expected when 87% of the part-time workforce comprises women. At the higher rates, female staff complete less overtime with the variance across the Force ranging from 4.40 at grade PO1 to 0.33 in scale 4, still within the +/-5% parameters Departments Human Resources has a variance outside the +/-5% range of at scale 3 which relates to the overtime working of one individual at this scale. All other variances both internally and against Force averages are within the acceptable variance range 3.3 Ethnicity Overall, staff recorded against another than white british classification are well-represented across grades 2 to SO1 in respect of overtime. All variances against Force average total pay are within +/- 5% and range from 0.80 to Departments Comparison against Force and internal averages indicates only one exception to variance in the +/-5 range. In Call Management, the overtime earnings of one male individual on scale 5 are % against Force averages and % internally.
5 3.4 Disability Of the thirty-one staff who are recorded as having a disability, six staff at grade 4, three staff at grade 5 and one at grade SO1 worked overtime during the April to September 2009 period. The variance in total earnings ranged from (scale 5) to (scale 4) and at scale SO Departments 3.5 Age Only Call Management had staff in this category working overtime and earnings were within the range of +/-5% both against Force and internal averages. Other departments either had no staff recorded with disabilities or those staff had not worked overtime There are two variances across the six age bands and eleven pay scales where overtime was earnt that fall outside the variance parameter of +/-5% for total pay when compared against the Force average. The range in these variances is from in scale PO1, age band 25 34, to in scale 3, age band Departments There are some variances across the age bands in departments, from scale 4, age band in Call Management to scale 3, age band in the Transport department. 4. Shift and Other Allowances 4.1 There are currently four shift allowances ranging from 12.50% to 20% of basic pay, and a further twelve allowances payable. Thirty one roles receive shift and other allowances. 4.2 Departments Staff in all five departments receive shift and/or other allowances. These range from essential car user allowance to shift and boot or tights allowances. 4.3 Analysis of any disparity in allowance payments across the protected characteristics has not been undertaken as it is recommended that an audit is undertaken to establish continued eligibility for payments before this is done. 5. Other Factors Affecting Pay 5.1 A number of other factors affect pay including the scale the post is evaluated at, pay on appointment, bar progression, the availability of merit /performance related accelerated incremental progression and
6 the number of incremental points on the pay scale. All of which need to be consistently approached to ensure fairness. 6. Conclusions and Risk Factors 6.1 Whilst the basic pay structure is essentially fair and pay variance is within the +/- 5% tolerances, presenting minimal risk of an equal pay claim, there are a number of factors which can undermine this: Overlapping pay scales, variation in the length of incremental scales, and extended pay over two or more pay scales can lead to significant disparities in pay for staff who are essentially fulfilling the same role Not all roles have been evaluated under the same job evaluation system and naming conventions are not in place Policy is lacking in respect of pay on appointment, bar progression, pay on internal transfer and performance related incremental acceleration Managers and staff receive limited communication on pay issues so may be unaware, for example, of the facility for performance related incremental progression Processes are lacking to monitor and check continued eligibility for shift and other allowances, and consistency of process and quality of decisions in respect of pay issues There is currently no training for managers on equal pay The lack of more accurate information on ethnicity and disability within the workforce limits ability to identify and address inequality in pay and other areas of employment. 6.2 All of the above increase the risk that the Constabulary may be unable to defend an equal pay claim. 6.3 Equal pay claims can be costly since a claim may include all contractual terms and conditions, not just pay, and include allowances, maternity payments etc. There is also the risk to the reputation of the force. 6.4 The Code of Practice on Equal Pay also requires organisations to have a transparent pay structure. 7. Recommendations 7.1 The Equal Pay Steering Group is requested to consider and support the actions recommended below and to identify from this report any further actions deemed appropriate.
7 Recommended Actions 1 Development of a Force pay policy to ensure consistency of application in pay issues e.g. pay on appointment, incremental progression, pay protection. 2 Job evaluation of all roles not previously assessed under the Towers Watson system. 3 Review of shift and other allowances and relevance to roles. 4 Review of roles with bar pay scales to assess role requirements; removal of incremental overlap and a reduction in variance between bottom and top of extended pay scales. 5 Undertake initiatives to increase the recording of declared disabilities and ethnicity. 6 Communication strategy on pay and reward issues. 7 Incorporate equal pay awareness into management training. 8 A further Equal Pay Review should be carried out using full end of year data (2012/2013) in April 2013.
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