How to get ahead of the curve

Mandatory Gender Pay Gap reporting

New business payment disclosure regime goes live
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The New Zealand Government recently committed to introducing mandatory gender pay gap reporting for many New Zealand companies. It is now more important than ever to be well prepared to ensure you meet your obligations and enhance your reputation with stakeholders, customers and your workforce. 

 

We discuss what mandatory reporting will mean for New Zealand companies, the actions you can take to prepare for what’s coming, and take a look at how overseas pay gap disclosure requirements have developed.

In August, the New Zealand Government announced its commitment to introduce mandatory gender pay gap reporting for companies with over 250 employees next year and for those with over 100 employees in four years. Ethnicity pay gap reporting is also being considered. According to Statistics New Zealand, the median hourly wage gender pay gap in New Zealand has reduced over the last year to 8.6%1, from 9.2%. The average gender pay gap across all Organisation for Economic Co-operation and Development (OECD) member countries is currently 11.9%2, and in Australia it is 13.3% (see below for more information on those regions).

You could therefore be forgiven for asking the question: if New Zealand is theoretically doing better than the average OECD country and Australia without mandatory reporting, why introduce it now? 

Find out what you can do now to prepare for mandatory reporting

The quick answer is that 8.6% is only an estimate! So, whilst the New Zealand pay gap figures look relatively good on paper, we don’t actually know for sure what the ‘true’ figures are.

Stats NZ uses the Household Labour Force Survey to conduct its analysis - a sample survey that does not interview every person in New Zealand. The Mind the Gap campaign goes some way to addressing this, with more than 100 companies, including PwC New Zealand, reporting their pay gaps. However, the data and methodology chosen is at the discretion of the company which makes it difficult to calculate the actual New Zealand gender pay gap or compare companies on a ‘like for like’ basis. Different methodologies also add to the complexity of seeing what, if any, meaningful activities companies are undertaking to address existing pay gaps with a view to their elimination over time. 

It is likely that those companies that volunteer to disclose their gender pay gap are proactively taking steps to address inequity and so are ahead of the curve. Spark stated in their 2023 Annual Report their ambition to achieve 40:40:20 representation (aligned to the Champions of Change initiative) “Spark wide” by the end of FY24 (i.e. 40% men, 40% women and 20% of any gender) and to reduce their median gender pay gap by 10% from FY20 to 18% by the end of FY25. Interestingly, Spark’s CEO is female, and research conducted on Bloomberg’s Gender Equality Index 2023 revealed that companies with female CEOs tend to be more likely to conduct a review to understand the extent of their gender pay gap.  

It is generally accepted that gender pay gap reporting, equal pay audits and other pay transparency policies help advance gender equality in the workplace, as these measures present up-to-date information on a company’s gender pay gap, encourage employers to offer equal pay for work of equal value and identify systemic focus areas to address. 

It is also clear that whether in a ‘buyer’ or ‘purchaser’ market, attraction and retention tactics are key. The ability to show that you are a diverse company, that you value all employees equally and are proactively addressing the root causes of any pay gap and/or pay inequity is extremely powerful and fundamental in remaining competitive and successful in the marketplace. It is also an intrinsic part of a company’s overall Employee Value Proposition (EVP) which future generations, especially, will expect from their employers. 

The New Zealand Government’s commitment should compel companies to take a proactive approach to assessing their current pay gap, and to move beyond reportable numbers to understand the underlying inequalities that contribute to these gaps - especially given the government’s comment in its announcement that a review will take place in three years’ time which will likely make the now voluntary remediation action plans mandatory. This will allow the government, customers, stakeholders, and workforce to see how a company measures up against its peers and whether they are actively addressing the gap and adopting policies and practices that create a sustainable future.

While the specifics of the reporting requirements (i.e. data, methodology, breakdown etc.) have yet to be announced, companies need to consider what actions they can take now to assist with their own state of readiness.  Because if you don’t, you risk being left behind!


Practical actions you can take now

Whether you’re at the start of your pay gap reporting journey, or are already proactively disclosing your pay gap for gender and/or ethnicity:

  1. Determine what employee characteristics you will examine for pay differences – gender, ethnicity, etc. in the short, medium and long term

  2. Consider where your pay and employee data will be sourced from and how accessible your data is – internal/external system(s) 

  3. Review the integrity of your data – remember inaccurate data produces inaccurate results!

  4. Consider who/how you will calculate the pay gap – do you have the internal capabilities and resources available?

  5. Establish how you will identify the main drivers of your pay gap and understand the potential broader inequalities within your company that may be influenced by external social factors e.g. lower availability of female talent in certain areas, a male dominated industry

  6. Identify key actions that will help to mitigate these underlying drivers and inequalities, both within your company and outside it

  7. Continuously monitor and analyse whether any of the actions identified have improved your pay gap in the short, medium and longer term or whether a further shift in your approach is required


1 Stats NZ. (2023). Labour market statistics (disability): June 2023 quarter (https://www.stats.govt.New Zealand/information-releases/labour-market-statistics-disability-june-2023-quarter/)

2 Organisation for Economic Co-operation and Development. (2023). Reporting Gender Pay Gaps in OECD Countries (https://www.oecd.org/publications/reporting-gender-pay-gaps-in-oecd-countries-ea13aa68-en.htm)


How are other regions performing?

On average, across all OECD member countries, the median full-time employed female currently earns 11.9%¹ less than their male counterparts and this has only improved by approximately 7% in the last 20 years. Surprisingly, this is the case even though over half of OECD countries require private companies to report their gender pay gap statistics regularly to stakeholders, such as employees, employee representatives, the government, and/or the public.

In March 2023, the European Parliament adopted a new European Union (EU) Pay Transparency Directive, with the expectation that it is translated into national law by EU member countries within three years. The goal of the directive is to support the application of the principle of equal pay for equal work between males and females and to enhance equality in the workplace in general. The EU ruling shows that whilst steps have been made in the right direction, work is still to be done.

As of February 2023, Australia’s average base salary gender pay gap was 13.3%. In March, the Workplace Gender Equality Amendment Bill 2023 was passed in the Australian parliament in response to the 2021 review of the Workplace Gender Equality Act 2012, which found that companies were not putting sufficient focus on addressing their gender pay gaps. 

Under this Bill, the Workplace Gender Equality Agency (WGEA) will publish the average, median and quartile gender pay gaps for all private companies with more than 100 employees. 

In addition, employers with 500 or more employees will need to put in place a policy or strategy for each of the six Gender Equality Indicators (GEI): GEI 1 – gender composition of the workforce; GEI 2 – gender composition of governing bodies; GEI 3 – equal remuneration between women and men; GEI 4 – availability and utility of employment terms, conditions and practices relating to flexible working arrangements for employees and to working arrangements supporting employees with family or caring responsibilities; GEI 5 – consultation with employees on issues concerning gender equality in the workplace; and GEI 6 – sex-based harassment and discrimination. Again, the introduction of this bill shows that there is still more that companies can do to reduce and tackle their pay inequities.

Looking at the global landscape, it is obvious that pay gap reporting is only the tip of the iceberg. New Zealand companies need to ensure that they appropriately prepare not only for the announced mandatory requirements and the transparency that will provide to the market/stakeholders, but for those that we expect to see in the not-so-distant future. 


How can PwC help?

Our team of workforce experts are happy to assist and support your company with the following services:

  • Gather and cleanse the data required to analyse your pay gap

  • Conduct a pay gap analysis

  • Identify potential root causes of the pay gap

  • Identify specific key actions for your company to take to remedy any pay gaps and calculate, where possible, potential costs of the proposed action(s)

  • Develop processes and procedures to assist with mitigating any future pay gap exacerbation

  • Advise on the development of a Diversity, Equity & Inclusion framework or improvements to your existing structure linking to your overall People & Culture and organisational strategy and objectives

  • Establish KPIs to measure the effectiveness of your Diversity, Equity & Inclusion framework.

Contact us

Mairéad Wychfield

Director, Workforce Reward Services, Auckland, PwC New Zealand

+64 27 560 7210

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Tanya Giles

Director, Workforce Reward Services, Auckland, PwC New Zealand

+64 21 608 122

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Chris Place

Partner, Workforce Reward Services, Auckland, PwC New Zealand

+64 21 221 6187

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