WGEA Reporting : 7 Changes

7 upcoming changes for 23/24 WGEA reporting.

The following report is the second of three articles to be published before #genderpaygapday arrives, to help board, executives and staff understand crucial dates, upcoming changes, reasons to act and where to get help now.

Introduction:

On the 27th of February 2024, WGEA will publish the 22/23 gender pay gaps for thousands of larger employers, providing stakeholders insights into gender composition, median pay gaps, and average remuneration per pay quartile.

By now organisations should have prepared for the inaugural publishing of their median gender pay gaps and should have switched their focus to the new 23/24 reporting and the submission period from April 1st to May 31st 2024.?

However, the evidence within the 22/23 WGEA Equality Scorecard, implies there will be a number of organisations that have already missed crucial dates, and are either trying to play catch-up or on their way to joining the non-complying employer list for 23/24.

For those organisations feeling that they are lagging behind, feel free to connect with us to help get back on track. For more information, please see our previous article WGEA Gender Pay Gaps: 7 Important Dates, which includes key dates and actions that should have occurred by now including sharing the 22/23 Executive Summary and Industry Benchmark reports with their Board and uploading the Employer Statements to the WGEA portal.

Next, we delve into seven of the changes applied to the 23/24 reporting WGEA gender equality reporting requirements. As with our first article, the format includes a short summary first, followed by a longer more detailed explanation.

Summary - 7 Changes for 23/24.

A brief summary of some key changes to the WGEA reporting for 23/24.

1.????? Average (mean) pay gaps to be included in 23/24 reporting.

2.????? Additional demographic questions on all employees.

3.????? Additional questions on Key Management Personnel.

4.????? Expanded sexual harassment and discrimination reporting.

5.????? Expanded parental leave reporting across employment type.

6.????? New voluntary questions on paid family and domestic violence leave.

7.????? New gender equality indicator reporting requirements for the larger organisations with 500 employees or more.

Expanded - 7 Changes for 23/24.

A more detailed explanation of those key changes and implications outlined.

1.????? Average (mean) pay gaps to be included in 23/24 reporting.

With the new mandatory collection of CEO remuneration during the 23/24 reporting period (see point 3 below), the publication of organisational pay gender gaps (around this time next year), for the 23/24 data will also show the average (mean) #genderpaygaps.

In the interim, the 22/23 WGEA reporting considers the median gender pay gap.

2.????? Additional demographic questions on all employees.

Next there will be additional mandatory inclusions in the 23/24 reporting data set. These will include both the year of birth and primary workplace location (postcode) data for each employee.

The inclusion of these two new research variables will allow organisations (and the WGEA) to delve deeper into their pay gap and remuneration analysis to view how age and geographical bias may be associated with either gender composition and remuneration, including pay gaps, both median and mean.

3.????? Additional questions regarding Key Management Personnel (KMP's).

The WGEA use a different hierarchical definition for "Key Management Personnel" than most large and regulated organisations that have to report remuneration by law, for example in their annual reports. Generally, KMP is a term used to describe both the board and executive team. for the sake of further confusion, there are changes to data collection on two separate areas within the realm, looking at CEO's, the second being the Board or governing authorities.

• CEO’s

The 23/24 reporting will include mandatory reporting of CEO remuneration, in addition to Heads of Business and Casual Managers. The WGEA see this an important step forward in gaining a more accurate representation of the real gender pay gap.

With 78% of CEO’s being recorded as male within the 22/23 WGEA Gender Equity report, the WGEA hope that by including this additional information it will “make gender pay gaps more reflective of the real position of men and women in the workforce”.

The remuneration of individual CEO's will not be published by the WGEA, rather used in the calculation for the organisation's average (mean) gender pay gap.

Interestingly, the remuneration of partners, despite their seniority and pay in some large organisations, will not be included in 23/24 as they are technically not deemed to be employees and not currently part of the data set, although the WGEA is investigating this anomaly.

• Governing Bodies

The new reporting regime, requires information on organisational policies relevant to enforced tenure periods of Chairs and Directors within Boards.

We suspect, the WGEA may use the data to delve into any correlation between maximum director tenure policies and gender equity. The enforcement of maximum tenures could be a lobbying policy of the future to aid in the increased representation of females on boards and governing bodies, via the enforcing of more succinct director tenure periods and forced board turnover policies.

?4.????? Expanded sexual harassment and discrimination reporting.

There will be expanded reporting requirements on prevention, accountability for, and response to sexual harassment, harassment on the ground of sex or discrimination in the workplace in alignment with Positive Duty and good practice from Respect@Work. The information will require further detail on the policies, strategies and actions to prevent harassment and discrimination.

Employers will need to report on preventative and accountability measures. This includes information about the frequency of leadership review of policies/strategies; training on sexual harassment; expectations communicated to employees about workplace conduct; workplace health and safety risk management process; supports for employees; and reporting and data collection processes on sexual harassment.

5.????? Expanded parental leave reporting across employment type.

Expanded detailed questions on employees with access to employer-funded parental leave delving into employment type.

Instead of reporting the 'proportion of the workforce', employers must now report the 'number of employees' who took a period of parental leave, and/or who ceased employment during, or at the end of, that period.

6.????? New voluntary questions on paid family and domestic violence leave.

Employers will be asked to report on if employees have taken paid family and domestic violence leave in the reporting period, and if so, how many.

Employers will also be asked how many days of paid family and domestic violence leave were taken by employees in aggregate in the reporting period, and how many employees took the maximum leave entitlement.

Employers will indicate whether permanent, contract/fixed term, and/or casual employees have access to employer-funded paid parental leave.

This information is sought to understand the utilisation of family and domestic violence leave in the context of the new entitlement to 10-days paid family and domestic violence leave as a National Employment Standard under the Fair Work Act 2009. Only deidentified data will be shared for this purpose and at aggregate level rather than the organisational level.

7. Policies and strategies for each of the six gender equality indicators for larger organisations with over 500 employees.?

In order to achieve compliance these reporting employers must develop a policy or strategy for each of the six gender equality indicators, being:

• GEI 1 – gender composition of the workforce
• GEI 2 – gender composition of governing bodies of relevant employers
• 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
• GEI 6 – sexual harassment, harassment on the ground of sex or discrimination.

Whilst, there is guidance provided by the WGEA on the difference between a policy and a strategy, other data from the 22/23 WGEA scorecard suggests that there may reporting improvements required by employers when deciding which of the avenues applies to their organisation.

Perhaps this is partially exemplified through the changes this year asking employers if they set certain targets on gender equality within the questionnaire and providing them a list of targets to select from.

Conclusion:

Within the large list of 5,000 plus private sector employers, it is our expectation to see some wild variations of gender composition and pay gaps both across industries, individual organisations and seniority within.

The cold hard truth, is that not every leader (nor organisation) cares about gender equity, diversity and inclusion at the same level. The 22/23 WGEA macro reporting already infers this through the statistics provided.

In our final article of this three-piece series, we delve into see what the data tells us and propose seven reasons why every leader and organisation, even those that don't really seem to care at all, should.

For urgent assistance with Employer Statements, upcoming 23/24 compliance reporting (including gender pay gap remuneration analysis and development of GEI policies or strategies), contact us today.

You can book a chat now, or email us for an alternate discussion day or time.

To learn more about urgent, divergent and incongruent gender-based risks, download our brief discussion on our gender equity remoDEI service.

Next article: Coming (very) soon.

Follow john myers and perple to ensure the next article is in your feed, scheduled for publication on Monday 26th February at 10 am.

Cheers,

John Myers

Founding Director

perple - people performance pty ltd