Public sector pay policy 2024-2025: equality impact and fairer duty assessment
The equality impact assessment (EQIA) will test the Public Sector Pay Policy 2024-2025 against the needs of the general equality duty in the Equality Act 2010. The Fairer Duty Assessment (FDA) looks at the socio-economic impact of the pay policy.
3. Executive Summary
The pay policy provides employers with the flexibility subject to affordability to address evidenced workforce or structural pressures that create or maintain pay inequalities. The Public Sector Pay team collects information to enable them to have oversight and identify those employers at risk of potential inequalities, such as lower paying organisations or those with longer journey times than the average.
The Equality Impact Assessment of the 2024-25 Public Sector Pay Policy concludes the continued commitment to support the real Living Wage and encouraging progressive pay increases will help mitigate the impact of in-work poverty and could help support those living on low incomes. The analysis indicates there are higher proportions of women, those with a disability, from a minority ethnic background and younger employees among lower earners. Therefore any individual pay proposals which target higher increases for lower earners will in many cases provide a positive benefit.
This may also help in working towards reducing the gender pay gap within the public sector as it should increase the overall base levels of pay for lower earners where traditionally women are overly concentrated. If this is further supported by the continued restraint applied to higher earners including senior appointments, where there are higher proportions of men.
We conclude there is no direct discrimination as a consequence of the policy approach to progression since the individual employers have the flexibility to take decisions on the payment of progression, equality proofing their own pay arrangements taking into account affordability and performance.
Nor is there evidence to suggest that the continuation of suspending non-consolidated performance payments will adversely impact on individuals with a protected characteristic.
There is no evidence to suggest that the pay policy would adversely impact the take-up of Board Appointments among those with a protected characteristic as the level of daily fee rate is unlikely be the key driver for taking up an appointment
The positive movement with the majority of employers standardising to a 35 hour working week during 2024-25 can be seen to provide a benefit to all impacted employees. It is possible there could potentially be a greater benefit for part-time employees, particularly for the many who are lower paid and as such more likely to be a carer, a woman, a disabled person, an individual from a minority ethnic group, a younger employee or a combination of one or more of these characteristics.
The continuation of the commitment to a No Compulsory Redundancy policy provides job protection for all employees covered by the pay policy and there is no evidence to suggest that this creates any negative direct or indirect discrimination.
It is recognised that, while we do have gaps in the information provided by employers directly subject to the pay policy on some of the protected characteristics, we are satisfied from the analyses undertaken there is no unlawful discrimination in the proposed pay policy.
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