Transcript

Rolanda: Hello, everyone. Good morning, and you're very welcome to our webinar on the new Codes of Practice on Equal Pay and Sexual Harassment.

My name is Rolanda Markey. I'm part of the Learning & Development team at Legal-Island, and I'm joined by Caroline Reidy from The HR Suite. She's the managing director of The HR Suite.

Legal-Island webinars and podcasts, and all our webinars are now turned into podcasts, are sponsored by MCS. MCS help people find careers that match their skillsets perfectly as well as supporting employers to build high-performing businesses by connecting them with the most talented candidates in the market. And if you're interested in finding out how MCS can help you, then head to www.mcsgroup.jobs.

If you're new to our webinars, we're here for the next 45 minutes. Caroline is going to take you through the new codes and what the implications are. We'll have time for questions, so please drop any questions into the question box and we'll deal with those at the end.

But if you're new, I want to tell you a wee bit just about Caroline. Caroline is obviously an extremely experienced and very well qualified HR consultant. She's a past member of the Low Pay Commission and also an adjudicator in the Workplace Relations Commission. She has completed a Master's in Human Resources through the University of Limerick. She is CIPD accredited as well as being a trained mediator. And that's obviously very relevant for this particular topic, Caroline.

She has worked across various groups of HR for over 20 years in both the Kerry Group and then the retail and hospitality sectors, where she was the operations and HR director of the Garvey Group prior to setting up The HR Suite in 2009.

Caroline speaks widely and writes articles and papers on thought leadership in relation to the future landscape of HR and the challenges and opportunities that that presents for employers and employees.

She's also a regular speaker and contributor to the Legal-Island Annual Review of Employment Law each year. This year, the dates for that have been confirmed as 30 November and 1 December. Everybody pop those in your calendar.

In this webinar, Caroline is to consider these very new, quite relatively recently hot-off-the-press codes and consider what they mean for employers, obviously, in terms of your policies and procedures for managing these two areas.

And as I said, if you have any questions for Caroline, then pop them into the question box. If you are having any issues with sound, and that occasionally does happen, then we'll put a wee note in just to make sure you've got the right sound settings set for that. Obviously, there's no point in me saying that because if you can't hear, then you wouldn't have heard me saying that. But we'll pop a wee note in the chat just about that.

Caroline, delighted to be joined by you again today, and I hope you're keeping well.

Caroline: Great. Thanks, Rolanda. Always must say I enjoy these sessions and it's great to see so people joined today, which is always really positive and it shows how important these two new codes are and the relevance within the work organisation. It's another new policy update required as well, so more work for the HR practitioners.

Rolanda: Absolutely.

Caroline: We'll try and see if we can make it as straightforward as possible for people today.

Rolanda: Thank you. Over to you, Caroline.

Caroline: Okay. If I maybe take you through the updates. As Rolanda said, these new Codes of Practice are relatively hot off the press. They're not even a month old. Basically, on International Women's Day, which is 9 March, IREC, the Irish Human Rights and Equality Commission, published these two new Codes of Practice.

There are two codes. One is in relation to equal pay, and it's the Equal Pay Code, and the other is in relation to sexual harassment and harassment at work. And these two codes are guidance for employers, but as we know, in relation to the codes, it's really important that we use them as best practice to guide our policies within the work environment.

It's also really important to note that at the start of 2021, we had a new Code of Practice in relation to bullying. And we saw the very, very significant changes that were introduced by having new stages of the Code of Practice. So instead of the bullying as it was before, people could go straight to formal, should they so wish.

We saw lots of new introductions, particularly things like the contact persons, the preliminary stage, and the informal stage being enhanced as well, which required us to do a policy update but also required us to do training, to meet our vicarious liability under that Health and Safety legislation.

And it's not really any different in terms of the expectation here. We need to do two key actions coming away from today. One is to revisit our policy in relation to harassment and sexual harassment, to make sure it reflects what's in the code. And then also, we need to revisit our equal pay to see if there's anything within our job categories, etc., that might cause us a concern to need to revisit those.

I'm going to go take you through both of the codes and what they mean. And you'll also find in the chat section there that we've uploaded a copy of both codes for your information. But as I talk them through, if you have any questions, as Rolanda said, feel free to pop them in the chat.

The Equal Pay Code ⚓︎

If I start with the equal pay code, I suppose the equal pay, at the moment, is something that comes up from a board perspective, as we look at ESG, and also as we look at trying to ensure that we're as diverse and as equitable as we can. Particularly now with the rollout of gender pay gap reporting upon us, it really does echo the same spotlight around equal pay.

So what these key principles require is that we look at what does equal pay mean. And even though typically we talk about equal pay when it's to do with gender, it's important to note that the full obligation in line with the Employment Equality Acts apply.

And it refers to remuneration, which is broader than just pay, and it includes allowances, bonuses, and any other non-cash benefits. It's really important that when we're doing our review, we look and make sure that there isn't any inequity to do with any of the equality grounds linked to the broader remuneration that we pay people in relation to basic pay, allowances, bonus, and other non-cash benefits.

So the equal pay code recommends that we do a job evaluation, which is considered to be the most effective way of ensuring that we have equity of pay. That's doing a detailed review of all remuneration linked to any person or any job, and it's trying to identify any anomalies that might exist to cause a concern that might be linked to equality as a result.

And as we're looking at our gender pay gap reporting, ultimately, this is something that's going to be very much on the focus of boards and of HR practitioners as we go through the year.

So it really encourages the employer now to do an independent audit and basically look at trying to make sure that this isn't the case and looking at things like job data, analysis of the jobs, analysis of the pay data, and then if anomalies exist, putting corrective measures in place. So again, some important areas.

And again, it's an area that there's, I suppose, rarely an issue without there being a big spotlight on it.

We had a recent case in the WRC where an employee was working as a statistician, which some of you may be familiar with, and she took a claim under the Equal Pay legislation to say that even though their titles were slightly different, ultimately, they were doing the same job and she was female and her comparator was male. So again, that's the typical scenario in relation to a possible claim in this regard.

The adjudicator, in this case, was quite critical of the internal HR department based on, when she raised this concern, how unresponsive and how untimely they were in terms of addressing it.

So I think it's twofold. One is the proactive approach. Now we have the equal pay code, we're proactively trying to identify any anomalies and keeping in mind that just because the job title might be slightly different, the jobs need to be obviously different. And that's an important consideration.

I think that case is a good example of how we are trying to get underneath the job code or the job title to make sure that they are actually different and the rates of pay, or the remuneration as it's referred to, is justifiably different.

So you have the equal pay code. You can go through it in more detail, but I think you'll see that they are the main elements to it. I'm next going to go through the harassment code. And then, as I say, I'll happily take any questions that you may have in relation to either of them.

The Harassments Code ⚓︎

The harassment code, I suppose, has really been spotlighted with the whole #MeToo movement and with a really big spotlight last year on the whole area of dignity and respect at work.

And one of the key areas we always flag when we're talking about harassment or sexual harassment is many people would use the words, "I'm being bullied and harassed", and would not understand the difference between bullying being repeated inappropriate behaviour and harassment can be one incident, but it needs to be linked to the equality grounds. Obviously, sexual harassment is specifically linked to that gender and sexuality issue.

So again, when we're now drafting our policy or at least revisiting our policy to make sure it's compliant with this new code, making sure that you've already done your bullying Code of Practice and have that up to date.

Obviously, we specialise in investigations in The HR Suite and we do a lot of investigations or outcomes or appeals. And what we're finding even as recent as the last number of weeks is a lot of the policies that we . . . Obviously, if we're doing an investigation for you, we have to rely on your internal policy, so we'd always ask the client to send us that policy. We're finding that a lot of the policies haven't yet been updated to reflect the new Bullying Code of Practice or to reflect what is now the new harassment code.

Well, that's a really serious issue and concern because then you're going to have to do your investigation not taking into account best practice.

And now that the new Bullying Code of Practice is in over a year, it would definitely be high on my priority list if you haven't done it already.

Obviously, we help people to update their policies. Also, if it's something that you know you're not going to get to on your to-do list fairly soon, definitely give us a call and we can give you a quote for what it would cost for us to do it for you instead.

So as you update your harassment policy, there are a few key considerations that you want to take into account.

One key thing is the intent of the perpetrator is irrelevant. It's the effect of the behaviour that is the determinant. And that's why doing the training is so important. There's been a huge, huge take-up in doing training around dignity and respect, and I think that's going to continue to be a priority for employers due to that vicarious liability that we have.

For many employees, if there's an allegation put to them, they often say, "Well, I didn't realise that by saying that joke or that banter, that could have been perceived as harassment or bullying for that matter". So it's really important in our training that we help employees understand it's the effect of the behaviour on the employee is what's the determinant and not the intent of the perpetrator or the employee who did the alleged act.

So the key focus on this harassment code is to develop and implement policies and procedures to obviously ensure there's an environment free of harassment. In this respect, the policy is what the initial starting point is and also the training then to complement that and that rollout.

It's also really important that we consider, as always, people whose first language may not be English. And also, it encourages employers to implement training for managers, supervisors, and all staff in relation to preventative measures and ensuring that as part of staff induction, we do proactive training.

One of the key things around vicarious liability that you'll have seen coming up in any case law is the adjudicator, or the Labour Court if it goes that far, will ask the employer, "What measures did you take to try and ensure a work environment free of any of bullying, harassment, or sexual harassment?" And the starting point is the up-to-date policy. The next is the training and induction and the rollout of making sure that there are constant reminders in place for it.

I suppose it's particularly important to note that the code highlights that persons with disabilities, those with precarious employment contracts, so those that might be on short-term contracts, etc., those who might be new workers or immigrant workers, they're particularly vulnerable to sexual harassment and harassment. Therefore, additional measures may be required for these categories of workers.

And again, really taking that into account is really important. Again, I would actually add in younger workers to that also, because we've had a number of issues that have arisen with younger workers.

I think it's really important that additional measures are put in place in relation to training, supportive measures, and regular check-ins to ensure that they have that safe place of work in relation to dignity and respect, which is really important. So again, important that we are conscious of the actions in relation to that.

I think we've been clear about the importance of having a champion or champions within the organisation who would be outside of HR to champion dignity and respect.

And we've seen in the bullying code where they have contact persons where somebody can go to somebody and flag, "Look, I have a concern. What should I do?" etc.

So for many of our clients, we're suggesting that they might use that same contact person for the harassment code and broaden it out wider than just the area of bullying, which requires those contact persons to be put in place.

Obviously, it's no good putting a contact person in place unless you give them complementary training. And remember, the idea of the contact persons is that those parties are named and they're available for somebody to go to without ever contacting HR.

At this stage, you've all probably trained your contact persons in line with the Bullying Code of Practice, so it wouldn't take a lot more. Just an additional short training session to bring them up to speed in relation to the harassment code. But I think that would be another positive step in relation to that.

Obviously, it would also be important to check and see how effective our training is now by doing things like staff surveys, anonymous questionnaires, and maybe discussion and focus groups.

And again, I think that's how we can do and get that temperature check and doing those anonymously. And again, we can assist from that perspective in helping with those as well.

Important to note that the codes, even though they're not legally binding, it's not something I would suggest in terms of ignoring them. The codes are admissible in evidence in proceedings before the Workplace Relations Commission or the Labour Court or outside of that, any other legal framework. Therefore, it's very likely that they will be referred to if an employee was to take a claim. So it's really important that we do consider using them as the best practice guide.

I suppose what's really the big concern here is people want to join organisations where there is a culture that is very positive towards dignity and respect, that bullying, harassment, and sexual harassment are absolutely not allowed within the work environment and that we are doing everything we can to support and encourage a diverse workforce.

So again, I think this is one that the more we can hero it, the more we can make it part of best practice and part of our normal work, the better it is.

In a lot of the training we've been doing, we've got the CEO to open the training, and that has been hugely impactful and effective to show the weight and support the organisation are giving the training.

So again, food for thought to think about, because this isn't just an issue in terms of attraction and retention. It's also a big reputational risk for any business to be in breach of such important Codes of Practice. So again, very important areas to be fully clear and aware of.

To say to you, the codes themselves are user friendly. I think they're designed so that they give really good examples and demonstration purposes, etc. But sometimes, doing the training to complement it is really what is required because oftentimes employees just don't read the policy, as we know. So at least this way it's going to address it in a very proactive way.

What's also important is to consider reasonable accommodation and non-employees. Again, non-employees, even though they may not want to engage in the process, it's really important to show that we're still doing everything we can to address the issue if it is a non-employee, and we do give them that opportunity to respond and we do engage with them.

So just to mention that because oftentimes we find that it is a non-employee that might be the subject of the complaint, and the employee may think, "Well, because it's a non-employee, I can't raise the issue". But that's not the case. We have the same obligations to address any issue that they raise as much as an internal employee.

Rolanda, I might take some questions, if that's okay. And then at the end, I might just do a little summary of the key takeaways in relation to both of the Codes of Practice because it seems like we have a lot of questions in there and it might be a good use of time. Thank you for sharing the contact details there as well.

Rolanda: No problem. So somebody had asked a question. I think you've answered this, but it's probably worth just emphasising.

In the bullying code, there was a contact person and a nominated that person. Is that the correct terms? So when you talk about somebody dealing with things informally, can the person who has already been trained to be the contact person for the bullying policy be the same person for the harassment policy? ⚓︎

Caroline: So I think it would be a good idea for them to be the same person. Now, you obviously can get more people trained. However, most employees, we find, group them together. They consider it "I'm bullied and harassed". They don't generally understand the difference maybe at the outset in relation to what is bullying and what is harassment and what are the differences between them.

So I think if you're the one person as that go-to person and you up-skill the contact person to understand the harassment code and sexual harassment code as well, I think it makes it easiest for the employee.

Sometimes as well, when they go, they say, "Look, I'm being bullied", but the contact person could actually say, "Well, actually that definition meets the definition of harassment more likely than it meets the definition of bullying because it's not repeated behaviour", for example.

So I think that's a good approach, Rolanda. And even though the current harassment code doesn't require a contact person, I think it would be good practice.

Again, our whole aim here is to nip everything in the bud as early as possible. So rather than waiting for an incident to happen two or three or four times when the person might only wait and come and talk to HR, we want them to come and flag any issue as early as possible.

I think if you have the contact person that they can go to and just say, "Listen, by the way, I just feel this isn't exactly right, this behaviour. What do you think, and maybe how should I handle it?" they can then help the person resolve it at the earliest possible stage rather than waiting for the issue to escalate.

Rolanda: Okay. And I suppose this is a $9 million question. I think we dealt with this probably as well when we were looking at the bullying code.

Should organisations have two separate policies, or could you have one policy that meets the needs of both codes? ⚓︎

Caroline: I would say having seen the new Harassment Code of Practice, and obviously we know the bullying code, they're quite different now in terms of the root to resolution. So if you are going to join them together, then you're making a decision that you're, I suppose, having a new formal and new format. For example, you're going to be making harassment meet the bullying requirements is what I would say, because there's more to the bullying stages.

So if you're doing that, you need to make it really clear to everybody as you update your policy that this is the approach you've taken and why you've taken that approach. Otherwise, you're going to keep them separate.

But I do think there's a lot of merit in the preliminary stage in the Bullying Code of Practice, for example, where we're now required to assess in advance by an independent person whether or not the allegation meets the definition of bullying before it goes to the formal stage.

So I think that there's merit in that process because, again, sometimes people don't understand the definition. But also, you'll remember what I said when I was giving my short presentation. I find that not a lot of people have actually updated their policy based on the investigations I'm doing, which I'm quite surprised about, to be honest.

I know now every HR department in the country is up the walls because of so many business changes. That horrible word we're not going to mention has been a huge factor managing the return to work. There are so many things.

But I would say that this is one that I would definitely be adding to the priority list very high because we're a year and a bit in now. If an issue occurs, you have to use the policy that's in place within your organisation. If you haven't updated it, that presents an issue.

So I think there's a bit of decisions to be made as to whether you're going to combine them or keep it separate, but you need to do it as soon as possible, communicate it to staff, and do your rollout training, then, to complement both.

Rolanda: If you do combine them…

Should you be making clear that if it's a serious harassment or sexual harassment, then you don't have to go through the contact and the nominated and you can take it formally? Would you have to make that clear if you combined it? ⚓︎

Caroline: At the moment, nobody has to go through the stage of the contact person anyway. It's optional. And it's optional as well to choose the informal route in the Bullying Code of Practice. So they can go straight to preliminary screening if they want, which is the first stage before it goes to formal in the Bullying Code of Practice.

If somebody comes with a very serious allegation in relation to harassment or sexual harassment, normally by the time they come to HR, it is very serious at that stage. Nine times out of 10, I would say it does require formal investigation rather than mediation or rather than informal. Whereas normally allegations of bullying can possibly be resolved, particularly if they're flagged earlier through informal and through the mediation process.

But that's why I think having that contact person will add a lot of positive value to the organisation, because I think it will help get the issue resolved sooner rather than waiting for the person to come when they want it investigated formally, which is definitely much too late in terms of resolution.

Rolanda: And there is quite a lot of emphasis on mediation in the code, isn't there, in terms of trying to resolve it? Hopefully, that clarifies things for people.

Somebody is asking a question that if you already have a very robust sexual harassment policy in place, do you think are there any key things they need to amend as a result of this code if they feel their policy is already quite comprehensive?

Caroline: I think you'd have to sit down and do kind of a check against the Code of Practice. And everybody has the link for that there now. It's only by doing that that you're going to spot the difference.

A few things for me were that they're specifically spotlighting vulnerable employees and they've defined those, and I've called those out for you today. And I think assessing what we're doing to support those additionally is really important.

There's also a specific callout in relation to mediation and, again, making sure that you have mediation available and that you're "heroing" that as an option to people. In other words, trying to encourage early resolution rather than to wait for something to escalate. However, with harassment, as we know, one incident of harassment can be an allegation that's upheld. So that's where the issue occurs.

For me, then, what I would flag is it's all about prevention. Both the equal pay and the harassment and sexual harassment codes are very much focussed on "What are we doing in terms of prevention?"

And again, remember that vicarious liability under Health and Safety legislation, which covers this area. What are we doing?

The policy to me isn't enough, and I don't think that we've seen that in any of the cases that have come before the WRC or the Labour Court. It's very much more than if it's important enough, training needs to be complementary.

Again, the amount of people, as I said, that we do investigations and the person is there straight away going, "Listen, Caroline, if I had thought by saying or doing what I did that that would result in an allegation like this, there's no way I would've done it". Again, it's that raising awareness so people don't do that.

That's often what causes the issue, and people forget that it's not the intent that we take into consideration. It's the effect on the individual. And it's very emotive as well. People are very, very upset to be alleged to have done bullying or alleged to have done harassment or sexual harassment.

Rolanda: Yeah. And I think I did read something in the code that said why your policy is important and obviously having one, but it's not enough when it comes to the WRC. Obviously, you need to make sure that if you do have a really good policy, it is followed in practice. So those are important.

I thought I read something in the code about . . .

So you mentioned if it's a non-employee. What if it's a non-employee doing the harassing? What happens there? What penalties? What can an employer do in that situation? ⚓︎

Caroline: What the code says in relation to that is if it's a non-employee, you've got to still make every effort to resolve the issue. And also, even though they may not want to partake, you still need to make sure they can manage the process.

What is also really important is you keep the employee up to date in relation to your progress. And that has come up also in the WRC where you've had employees who leave midway through an investigation, for example. They might take constructive dismissal, for example. And the courts would always say the importance of keeping the person up to date . . .

Even though they might be saying, "Well, look, it's going on too long. I'm not willing to wait", or whatever the case may be, don't not communicate with the person. Make sure you let them know what's happening.

And the same applies if it's a non-employee. You never go back to the person to say, "We've looked after that", and leave it blank and vague. I think it's really important that you go back and you give the employee the comfort and confirmation that the issue has been addressed in line with the policy and the Code of Practice, etc.

And obviously, if it's a non-employee, there might be limits in what you can do. Obviously, if it's an internal employee, you've got disciplinary action that will follow suit if the allegation is upheld. But again, it's always an allegation.

I've also been involved in investigations that have been really, really serious, where they haven't been founded and they've been malicious. So we always have to make sure that we provide employee assistance programmes and support mechanisms to both the parties that are making the allegation and the person who is the subject of the complaint because, as we know, everybody is innocent until proven different.

Another point to note maybe, Rolanda, before I take another question is just in relation to the robustness of that investigation. Remember, the outcome of that is that investigation report. So it needs to be done timely, it needs to be done professionally by a competent person, and they need to make sure that the output of that report is very comprehensive. That's what's going to be relied on at a later date if an employee was to take a claim in relation to the employer not being proactive in terms of addressing the complaint.

Rolanda: Okay. If we move on maybe to the equal pay code, you mentioned, Caroline, doing a job evaluation.

Could you tell us just maybe a wee bit about more of what's involved in that? Imagine the thought of that strikes horror into hearts of HR people in the country. So what exactly is involved in that? Is that something you do, for example? ⚓︎

Caroline: Yeah, we do indeed. I suppose it's basically something that's a lot more topical now because of the gender pay spotlight and because of the recent case, for example, that I mentioned that's only hot off the press from the WRC in relation to that statistician, and also in relation to the new code being launched.

I would say there are two things you need to consider. One is if an employee raises an issue internally, that should spark you to do that job evaluation rather than to do a light touch kind of confirmation to say, "No, the job titles are different. Therefore, it's fine". And the job evaluation is very much getting underneath the iceberg.

I'll use that example of that WRC recent case where one person was a senior statistician and the other one was a more junior statistician, for example. And in that scenario, it's only by doing the job evaluation that you'll really understand what's actually the detail and responsibilities of these roles, getting past the title so that you really understand, "Is there justifiable differences in that remuneration package, or actually, is there a gender-based reason, for example, as to why one is paid more or one is paid less?" So if you have a grievance raised, I would definitely be doing the job evaluation.

And the second time I would consider doing it is if you have categories of workers that do specific categories and they're gender-based. For example, the majority of men do one job and the majority of women do another job. If that's the case, I would do a deep dive as part of that job evaluation to assess, "Are there genuine differences to justify why one cohort is paid more and one cohort is paid less?"

It's absolutely objectively justified that you can pay people differently once it's objectively justified and nothing to do with any of the equality grounds.

So you will find that there are jobs that are less desirable or require more flexibility, etc. They'll warrant to be paid more for that reason, or else no one would want to do them. But again, it's just doing that evaluation if that is something within your organisation that comes up.

Rolanda: Okay. And somebody has just sent in a question there. I'm not sure if this is one you can answer, but

Is it reasonable to have two employees, one male, one female, doing the same or similar job, but on different salaries, if it is reflected through performance reviews that one is a stronger performer than the other? ⚓︎

Caroline: Again, once you have very valid criteria in relation to that performance that can be objectively justified, that's fair and reasonable. And again, it's remuneration, remember. It's the broader sense. So the bonuses and allowances, etc., are taken into account when we do this evaluation.

But it needs to be very objectively justified. So it can't be something intangible to say, "Well, Caroline's performance is better", and it's as neutral as that because that's not objectively justified.

For example, if there were two salespeople and Johnny is performing less because he's not meeting his sales targets, Caroline is performing better and she's paid more, that's objectively justified.

So again, it's based on KPIs or targets or criteria that can be . . . That magic word "objectively justified" is key here.

And the best way of being able to stand over that is if you say it to somebody else, do they believe that objective justification when you explain the rationale and the criteria? And oftentimes when we do that evaluation, people will kind of go, "No, that doesn't make sense actually, because we can't justify the performance as objectively as we'd like".

Rolanda:

And do you think it's safer if an employer has a clear performance-related pay policy to justify that kind of difference as opposed to being a bit more ad hoc in terms of how pay is awarded or whatever? ⚓︎

Caroline: Absolutely. I think transparency is happening much more now with pay, and people are becoming a lot more open about pay, terms and conditions, etc. So I think we're going to see more of it, Rolanda. I think now even as jobs are advertised, we're seeing the terms and conditions and the pay being advertised as well in an effort to try and attract talent to see what's on offer.

Rolanda: Okay. Do you know the name of that case you were talking about, Caroline, the WRC case? We can send the link afterwards to people.

Caroline: While you're doing maybe the follow-up, I'll tell you the code if you want.

Rolanda: Sure. I suppose we can send the answer to that in the follow-up email.

Caroline: Yeah. But what I'll do is I'll give you the ADJ that goes with it, Rolanda, and maybe we can pop it out as an email to people after today.

Rolanda: That's fine. Perfect. A question here still around equal pay.

So within the management team, if there's divide and pay between function heads, which sometimes can happen, different members of management are paid different salaries, what are your thoughts on this taking gender into account? I suppose that's like the other question. Could there be an equal pay issue there? ⚓︎

Caroline: Absolutely. I mean, that's the idea of the job evaluation, so that we can objectively justify. And by doing that review, you can stand over it.

I mentioned at the start, as well, that this is something . . . I just had to do my Chartered Director diploma in the IoD. One of the big, big things now is that ESG and that whole piece around making sure that boards are very conscious and clear of what is the remuneration policy to ensure equity and fairness and equal pay, etc.

So a lot more boards now are requesting, "What is the remuneration policy? Can we show the objectively justified criteria, etc.?" So we're seeing a lot of companies go down that road.

Rolanda: Yeah, I think that certainly the gender pay is going to raise, as you say, more issues around this. And that is definitely happening this year. Obviously, we'll bring you more on that as it comes through, but it's definitely going to be an issue.

Well, we're basically through all our questions, Caroline. That was really very efficient today.

Oh, there's something else. In terms of job evaluation, is there guidance or a template you recommend? Is there something out there generally, or is it really . . .

Caroline: To be honest, it's got to be very much job-specific. The idea is that you're evaluating the components of the job that make up how somebody is paid. But obviously, that's very different whether you're a senior person who's in the organisation, whether you've got targets, or whether it's a job that is undesirable. So you would very much have to tailor it to suit the individual jobs. And again, it's something we can absolutely help companies with if they would like some help.

Rolanda: Obviously, equal pay has been quite a big issue in the UK. There have been lots of cases of supermarket workers successfully comparing themselves to warehouse workers for equal pay purposes. So it is certainly a growing area.

Caroline: Tesco in the UK. Those cases are definitely landmark cases that we're all keeping a very close eye on because one would argue that they were actually quite different in terms of roles, somebody working in a warehouse and somebody working as a sales assistant.

But again, "like work" definition was kept that broad that they could be used as comparators, which is the first big hurdle that was passed there. So yeah, I think we're going to hear a lot more about this area for all the reasons we've discussed today.

Rolanda: Yeah, it's certainly interesting.

Folks, just on your screen there you see a slide just to say this will be turned into a podcast. If you're a podcast person, then you can enjoy listening to this again. You'll find it on Apple and Amazon and on all the ones listed there.

Just to say, then, our next webinars are on . . . We have a couple coming up actually. On 14 April, we have one on Digital Resilience in an Always-On World with Chris Flack from Unplug. So how do we switch off?

Our next webinar with The HR Suite is on 4 May. We haven't decided on the topic for that yet. We'll see what's hot coming up.

And then on 23 June, we have our second Comparative Employment Law update with Lewis Silkin. I don't know if anyone joined us for the last one of that, but it was quite good. You can get it on the website as well if you missed that, just in terms of differences between employment law in Northern Ireland, Ireland, and GB.

So thank you very much, once again, for your time, Caroline. It was great to see you again. We'll send all the information in the follow-up email, folks, along with the links for the codes. And just check your junk mail. Sometimes it can go in there with organisation security settings and that sort of thing.

See you again soon.

Caroline: Thanks so much, everybody. Bye.

Rolanda: Bye.