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					EQUAL PAY STATEMENT AND OBJECTIVE

Date of next review: Sept 2010 incorporating a published report

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1. Introduction and Statement Moray College supports the principles of Equal Pay and is committed to ensuring that procedures are in place to determine pay and conditions of employment do not discriminate unlawfully and are free from bias. It is in the College’s interest to operate a fair pay system which is transparent and is based on objective criteria. The College is committed to taking action to ensure that equal pay is in place for like work, work rated as equivalent and work of equal value. The College believes that in eliminating bias from pay systems it is promoting positive relations amongst staff, students and the wider community 1.1 Scope

The principle of Equal Pay applies to all employees of the Board of Management of Moray College regardless of full or part-time status, supply, fixed term or permanent contractual status or length of service. 1.2 Objective

The objective of this Statement is to support good practice to eliminate bias from pay systems and to eliminate any unfair, unjust or unlawful practices that impact on pay. This statement also outlines the action that Moray College intends to take to identify and address any existing pay gaps. 1.3 Definitions

For the purposes of this Statement and in line with relevant legislation, pay is defined as; “The ordinary basic or minimum wage or salary and any other consideration, whether in cash or kind, which the worker receives directly or indirectly, in respect of his/her employment from his/her employer” Pay, therefore includes pensions, discretionary bonuses and sick pay as well as other benefits of monetary value. “Like work” is defined as work which is the same or broadly similar. This can be determined by a general consideration of the types of work involved and the skill and knowledge required to do them. Different job titles, job descriptions or contractual obligations do not necessarily rule out a like work claim. “Work of equal value” is defined as work which is of broadly equal value when compared under headings such as effort, skill and decision making.

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“Work rated as equivalent” is defined as work which has achieved the same or a similar number of points under a job evaluation scheme. “Line Manager” is defined as the Director or Section Manager for employees working in that Directorate or Section; in the case of a Director/Section Manager the Line Manager will be the Manager to whom s/he directly reports. An “Impact Assessment” of a policy, procedure or practice is a thorough and systematic analysis to determine whether it has a differential impact on a particular group. 1.4 Responsibilities

Ultimately, it is the responsibility of the Board of Management to ensure that employees are treated equitably. It is the responsibility of the Principal to ensure that the actions to implement the Equal Pay Objective are carried out and resourced. Specific responsibilities for ensuring correct implementation of procedures that determine pay lie with the Human Resource Section. Line Managers are responsible for ensuring that they apply procedures appropriately to ensure that initial starting salaries are consistent with this Statement. Line Managers are also responsible for ensuring that job descriptions accurately reflect the duties undertaken by postholder to enable an accurate evaluation of roles. The Head of HR is responsible for ensuring that this Statement is revised and maintained. 1.5 References

Equal Opportunities Commission – Code of Practice on Equal Pay Close The Gap – Guidance for meeting the specific duty on Equal Pay Moray College Equality Schemes Moray College Equality and Diversity Impact Assessment (see Appendix) 1.6 Factors which may contribute to a Gender Pay Gap

Moray College recognises that a gender pay gap may not solely be caused by men and women receiving different rates of pay for doing the same or similar work. Within an organisation there may be other factors or employment practices which contribute to a Gender Pay Gap such as caring responsibilities. Moray College has taken significant measures to addressing some of these factors and is committed to continuing these efforts.

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1.6.1 Occupational Segregation Women and men can tend to work within gender segregated occupations and the jobs that are most likely to be carried out by women, tend to be those associated with low pay. Although further work is required in terms of monitoring gender by grade, Moray College recognises that there is a higher level of female staff in the occupations of cleaning, catering and clerical work. This compared with the overall staff population gender balance of 49.97% male and 50.02% female (academic session 05/06 data), highlights that further investigation is necessary. An analysis of senior management levels within college shows that prior to a senior management restructuring in summer 2007, one of the seven members of the Principal’s Management Group was female and three out of the six heads of academic Divisions were female. Following the restructuring effective from 01 September 2007, this changed to three out of nine on the Principal’s Management Group and four out of the seven Assistant Directors being female. This adjustment in the profile of the senior management team of the College reflects the efforts that have been made in terms of succession planning and ensuring equitable access to staff development and also a systematic, transparent and recorded Recruitment and Selection process. 1.6.2 Pay Structures It is recognised that pay structures can have a direct impact on the gender pay gap and much work has been undertaken recently to address this in terms of the structures in place in Moray College. Women tend to have shorter service than men and therefore pay structures determined by long service can have a detrimental impact on the salaries paid to women for similar work to male comparators. In the academic session 06/07, the management of Moray College gained the agreement of teaching staff representatives to reduce the number of scale points in the lecturers scale from 12 to 5. Also, a review has been undertaken of the Administrative and Clerical grades to ensure that long scales are no longer applied by omitting intermediate points and removing the lowest scale point. Moray College operates salary placement procedures based on relevant qualifications and experience. This salary placement scheme is under review to ensure that any gender bias is eliminated and to ensure that the pay structures meet the needs of the College’s objectives. 1.6.3 Caring Responsibilities Women are more likely to have caring responsibilities which can result in them seeking part time work in order to balance their responsibilities.

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Certain employees have a legal right to request flexible working, for example parents of a child aged under 6 years (or aged under 18 if the child is disabled); the partner of a parent of such a child and the carer of an adult in need of care. Moray College recognises, however, that the opportunity to work flexibly, and thus strike a better balance between home and work responsibilities, can benefit all employees, their families and the College. In view of this, Moray College has extended the right to request flexible working to all employees of the Board of Management, and undertakes to consider all such requests, granting the requests where possible. A range of forms of flexible working is available where practicable including job share, a shorter working year, term time working and annualised hours, and staff at many different levels in the organisation, including senior management have benefited from that. Moray College has recently reviewed procedures regarding Parental Support (incorporating maternity, paternity, parental and adoption leave) and Absence from Work to assist employees in balancing work and home commitments. 1.6.4 Contract of Employment Structures Moray College has introduced fractional permanent contracts, replacing traditional temporary contracts which applied to a higher proportion of female employees. These fractional contracts accrue the same salaries and benefits to full time contracts on a pro rata basis. Contracts of employment are reviewed on an annual basis. Other measures have also been taken to ensure equality in the terms and conditions such as the removal of the 5 year qualifying period for an additional 5 days annual leave for support staff. 1.6.5 HR Policy and Procedure Structure In recent years the College has identified and responded to gender-related issues in employment arrangements to address recruitment and other arrangements. The College’s Equality and Diversity Committee and the Staffing Committee of the Board of Management monitor information, including gender balance, for such matters as number of applications for posts, appointments, grievances, disciplinaries, leavers and development and training. All Human Resource Policies and Procedures are subject to scheduled review including impact assessment, and the HR Policy Review Group which undertakes the detailed work includes staff representatives. Externally, the College was a partner in a 2-year project– Public and Private Sector Service on Equal Terms (PAVSSET) - in 2005 and 2006. We gained benefit from mapping our HR policies against those of other local organisations and those of the Scottish Executive. The specific outcomes and

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recommendations of the project invite partners to consider practice beyond the legislative requirements.

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Future Actions to implement the Equal Pay Objective

Over the next three years Moray College will: Action 1.7.1 Undertake a review of the Salary Placement Scheme for staff in partnership with staff representatives 1.7.2 Monitor the gender balance of staff by length of service 1.7.3 Monitor the gender balance of staff by position and grade 1.7.4 Monitor the gender balance of types of contracts 1.7.5 Monitor the gender balance of selection methods 1.7.6 Formulate an appropriate objective or objectives to address any gender gaps identified 1.7.7 Determine the scope for an Equal Pay Audit in partnership with staff representatives 1.7.8 Undertake appropriate Audit as determined above in partnership with staff representatives 1.7.9 Assess and review the findings of the equal pay audit and take action where necessary in partnership with staff representatives 1.7.10 Provide training and guidance for those involved in determining pay in addition to Equalities Training provided. 1.7.11 Review pay determining procedures on a rolling basis ensuring that appropriate impact assessment is carried out 1.8 Complaints Responsibility Assistant Principal Secretariat Head of HR Head of HR Head of HR Head of HR Head of HR Timescale December 2007 November 2007 November 2007 November 2008 November 2008 January 2008 and 2009 December 2007 December 2009 tbc

Principal

Principal

Principal

Head of HR

June 2008

Head of HR

tbc

Complaints or enquiries about the lack of equal pay should, in the first instance, be made to the Head of HR. If this informal approach does not satisfy the employee then the Head of HR will refer the matter to the Staffing Committee of the Board of Management in accordance with the Moray College Grievance Procedure.

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Appendix

Equality and Diversity Impact Assessment

The Race Relations (Amendment) Act 2000 places duties in all public sector organisations in relation to race equality. A specific duty is that all policies, procedures and functions are tested for relevance against the Act and, where they are identified as high, an Impact Assessment of the policy, procedure or function must be carried out. Whilst the RRAA places a duty to impact assess in relation to Race Equality, other Equality and Diversity agendas are soon to be included and therefore, Moray College has determined that impact assessment should be carried out for all Equality agendas. In addition, Moray College has determined that all policies, procedures and functions identified as having a high or medium relevance should be impact assessed. 1.0 Definition of Impact Assessment

An Impact Assessment is a review of a policy or procedure which establishes whether the policy or procedure has a negative effect or impact on particular groups. 1.1 The Aim of Impact Assessment

The assessment conducted should result on the promotion of equality of opportunity. It is the outcome of the Impact Assessment that makes it a valuable tool, not the process in itself. Impact Assessment can result in the identification and publication of best practice. 1.2 The Purpose of Impact Assessment

The primary purpose of Impact Assessment of policies and procedures is to determine:  The extent of differential impact upon different groups  Whether any differential impact is adverse  Identification and implementation of appropriate alternative processes/measures to remove the adverse impact.

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1.3

Responsibility to Impact Assess

The Equality and Diversity Committee is responsible for ensuring that impact assessment of policies and procedures is undertaken. Implementation of the Impact Assessment Tool is the responsibility of the College Officer for the parent area for the particular policy and procedure. 2.0 2.1 Impact Assessment Tool Stage 1 – Initial Assessment Of Relevance

This stage must take place for all policies and procedures and enables the identification of required monitoring data. Appendix 1 provides a proforma for arriving at an identification of a high, medium or low relevance rating in relation to the policy or procedures likely negative impact. Policies or procedures which are likely to have a higher relevance are those which involve face to face contact or involve making decisions based on someone’s individual characteristics or circumstances. 2.2 Stage 2 - Examination of Evidence

If stage 1 establishes that a policy or procedure has medium or high relevance valid and accurate data should be collated to ascertain if differential impacts exist. This data will assist in the generation of questions about the potential differential impacts. Methods of gathering evidence can be through a variety of means such as:  Focus Groups and Feedback  Statistical Analysis, Census Data and Review of Complaints  Qualitative Data collected through surveys or research  Piloting new ways or working  Involvement of Trade Unions/Students/Special Interest Groups/Stakeholders The results of the examination of evidence can also be recorded on the proforma at Appendix 1. 2.3 Stage 3 – Evaluation and Action

The outcome of stages 1 & 2 will be one of the following: 2.3.1 The policy or procedure has a low relevance 2.3.2 The policy or procedure has a medium or high relevance and evidence does not support the potential adverse impact 2.3.3 The policy or procedure has a medium or high relevance and evidence does support the potential adverse impact.

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Policies and procedures established to be in group 2.3.3 constitute the areas where the policy owners are required to take further action. This will include a review of the procedure to result in identification of appropriate proposals for alternative procedures or processes to mitigate the adverse impact. 2.4 Stage 4 - Publication

The outcomes of the Impact Assessment process will be considered by the Equality and Diversity Committee and thereafter publicised on the staff intranet. 2.5 Stage 5 – Evaluation of Actions

The Impact Assessment process is imbedded in the College policy review programme. This ensures that policies and procedures are reviewed on a regular basis and therefore the effect of any measures implemented as a result of the Impact Assessment process are evaluated.

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Appendix 1

Assessment of potential impact of College policies in terms of equality and diversity
Stage 1 Section/Division Policy or Procedure Aim and Desired Outcomes of the Policy and Procedure Which of the three strands of the duty does it relate to 1. Eliminating discrimination 2. Promoting Equality of Opportunity 3. Promoting good race relations Overall Relevance Stage 2 Is there evidence or reason to believe that some racial (or other) groups maybe affected differently than others? If so, to what extent? What evidence has been considered?

Comments:

Stage 3:

Does the Policy or Procedure fall into Group 2.3.3? Proposed Actions:

Assessors:

Date: Next Review Date:

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This version: Sept 07 This printing: 31/01/2010

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