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Diversity pay gap report 2022

Gender pay gap legislation introduced in 2017 requires all employers with 250 or more employees to report annually on their gender pay and bonus gaps. We’ve also published details of our disability, ethnicity and sexual orientation pay gap data.

Diversity pay gap report 2022

Executive summary

The Pensions Regulator (TPR) has prepared this report as part of the legal requirement for public authorities to publish their gender pay gap on an annual basis. We have also voluntarily included diversity pay gap information for ethnicity, disability, and sexual orientation.

Key statistics

  • There were 890 staff in post at the snapshot date of 31 March 2022 (compared with 825 the previous year).
  • Both the mean and median gender pay gaps have reduced since 2021 and are moving in the right direction, but there is still some way to go to reduce the gap further.
    • The mean gender pay gap has decreased by 2.1 percentage points (ppt).
    • The median gender pay gap has decreased by 1 ppt.
  • Although the proportion of women receiving a bonus has increased and the number of men receiving a bonus has decreased since 2021, both the mean and median bonus gaps have increased. This is largely attributable to higher paid men receiving higher bonus amounts, as bonuses are calculated as a percentage of individual salary.
    • The mean bonus gender pay gap has increased by 2.0 ppts.
    • The median bonus gender pay gap has increased by 0.7 ppts.
  • Both the mean and median ethnicity pay and bonus gaps have increased since 2021 and continue the upward trend highlighted in the analysis below. On 31 March 2022, there were 94 staff who declared themselves as being from a minority ethnic background, which represented 10.6% of the workforce. While the proportion of minority ethnic staff has increased in three of the four quartiles since the 2021 report, we need to do more work for improve this. If the number of minority ethnic staff in TPR doesn’t increase overall and across roles in each of the four quartiles, we are likely to see these gaps perpetuate for the foreseeable future.
  • Both the mean and median disability pay, and bonus gaps have decreased significantly since 2021, but the gaps still remain more favourable for those who have declared themselves as disabled in comparison to non-disabled staff.
  • In terms of sexual orientation both mean and median pay gaps have increased slightly in favour of heterosexual staff compared to LGB+ staff. The mean bonus gap has also increased slightly since 2021, but the median pay gap has decreased.
  • We compare favourably with the overall mean gender pay gap for the Civil Service (8.5% in 2022), with our mean gender pay gap sitting below at 7.0% for 2022. We also compare very favourably with the mean bonus gender pay gap for the Civil Service (27.4% in 2022), with our mean gender bonus gap sitting significantly lower at 12.2%, and the median bonus gender pay gap at 37.1% for the Civil Service in 2022, and just 7.5% for TPR.

Overall, we are confident that our pay strategy is non-discriminatory in its design, and this is supported through our analysis, which demonstrates the pay gap to be largely attributed to the distribution of the workforce, specifically lower female representation in higher grades. The gender pay gap continues to be a key consideration as we develop our future reward strategy.

We recognise that closing our diversity pay gaps for gender, disability, ethnicity and sexual orientation will not be quick or simple, but we’re committed to take the necessary long-term action to reduce them. We have outlined the actions we are taking to improve our diversity pay gaps at the end of this report. Progress towards these actions will be monitored by our  Equality, Diversity and Inclusion (EDI) Committee.

Overview

Mandatory gender pay gap reporting

In 2017, the government introduced legislation requiring organisations with 250 or more employees to report annually on their gender pay gap. The gender pay gap is the difference between the average earnings of men and women, expressed relative to men’s earnings.

Gender pay gap reporting involves carry out six calculations that show the difference between the average earnings of men and women[1]. This includes the mean and median gender ordinary gender pay gaps, the mean and median gender bonus gaps, the proportion of men and women who received bonuses, and the proportions of male and female employees in each pay quartile. The results are then used to assess levels of gender equality in our workplace, the balance of males and females at different levels, and how effectively talent is being maximised and rewarded.

If a workplace has a particularly high gender pay gap, this can indicate there may be a number of issues to address, and the individual calculations may help to identify what those issues are.

The gender pay gap should not be confused with equal pay. Equal pay deals with the differences between men and women who carry out the same jobs, similar jobs or work of equal value. It is unlawful to pay people unequally because they are a man or a woman. TPR uses the Korn Ferry job evaluation methodology to ensure equal pay for work of equal value.

This report fulfils our gender pay gap reporting requirements from 1 April 2021 to 31 March 2022. It goes beyond the minimum mandatory legal reporting requirements to provide a detailed narrative explaining the factors contributing to our gender pay gap and the actions we’re taking to reduce it.

This information is published on our public-facing website, as part of our Annual Report and Accounts, and on the Government Equality Office (GEO) portal.

Additional voluntary pay gap reporting on disability, ethnicity and sexual orientation

We also voluntarily publish information on our diversity pay gaps for disability, ethnicity, and sexual orientation, although there is no mandatory reporting requirement for us to do so. We do this to drive greater transparency and because we are committed to taking a holistic approach to the fair treatment and reward of all staff and ensuring the TPR is an inclusive place where people can be at their best.

Gender pay gap report

Gender representation

The analysis set in the report below is based on the gender pay gap data that was collected for TPR employees that were in post on the mandatory reporting snapshot date of 31 March 2022.

Specifically, there were 890 employees within TPR’s workforce who came within the scope of the gender pay gap reporting requirements on the snapshot date, made up of 456 women (51.2%) and 434 men (48.2%) respectively.

This provided for a relatively even split of men and women in scope for the analysis.

The tables below illustrate our overall mean and median gender pay gaps at the snapshot date and provide details of the discretionary mean and median bonus gaps on the same date.

Mean and median gender pay gap

The gender pay gap is the percentage difference between average hourly earnings for men and women, calculated as a percentage of men’s hourly earnings rate. A positive percentage value indicates that men have a higher rate in comparison to women.

The table below provides details of the most recent gender pay gap analysis conducted for 2022, representing the position as of 31 March 2022. It also includes comparative mean and median gender pay gap values from our 2021 and 2020 reports.

 Year Difference in mean (average) hourly rate of pay  Difference in median hourly rate of pay 
 2022  7%  10.1%
 2021  9.1%  11.1%
 2020  6.4%  6.3%

There have been decreases in both the mean and median gender pay gaps from 2021. The mean gender pay gap has decreased by 2.1 percentage points, from 9.1% to 7.0%. The median gender pay gap has decreased by 1 percentage point, from 11.1% to 10.1%.

The percentage of men and women in each pay quartile

The percentage of men and women in each mean hourly rate quartile pay band on 31 March 2022.

   Quartiles
 Men %  Women %
 Q4 – Upper hourly pay quartile (highest paid)  54.1% (54.4%) *  45.9% (45.6%) *
 Q3 – Upper middle hourly pay quartile  53.8% (51.9%) *  46.2% (48.1%) *
 Q2 – Lower middle hourly pay quartile  41.9% (45.4%) *  58.1% (54.6%) *
 Q1 – Lower hourly pay quartile (lowest paid)  45.3% (40.3%) *  54.7% (59.7%) *

* NB: The figures in brackets illustrate the proportion of men and women in each of the four quartiles from the 2021 gender pay analysis and have been included for comparative purposes.

Women made up 45.9% of the upper quartile (Q4), 46.2% of the upper middle quartile (Q3), 58.1% of the lower middle quartile (Q2), and 54.7% of the lower quartile (Q1).

Compared to 2021, there has been a shift in the representation of women across the four quartiles with a 0.3 percentage point increase in the upper quartile (Q4), 1.9 percentage points decrease in the upper middle quartile (Q3), 3.5 percentage points increase in the lower middle quartile (Q2), and 5.0 percentage points decrease of women in the lower quartile (Q1).

Mean and median gender bonus gap

The mean (average) gender bonus pay gap is the difference between the mean (average) bonus pay paid to relevant employees who are men, and bonus pay paid to relevant employees who are women (as a percentage).

The median gender bonus pay gap is the difference between the median bonus pay paid to relevant employees who are men, and the median bonus pay paid to relevant employees who are women.

We operate an annual discretionary bonus scheme that enables managers to nominate individuals for an award to recognise exceptional performance over the course of the reporting period, above and beyond the normal requirements of the job. Our bonus arrangements allow managers to nominate colleagues for a non-consolidated bonus of up to 10% (strong) or up to 20% (exceptional) of their salary. We also offer an additional up to 5% bonus category to recognise excellent work on individual projects or for part of a financial year.

 Year  Difference in mean bonus pay  Difference in median bonus pay
 2022  12.2%  7.5%
 2021  10.2%  6.8%
 2020  5.0%  -0.1%

The analysis indicates that both the mean and median bonus gaps have increased this year. The mean bonus pay gap increased by 2 percentage points, from 10.2% to 12.2% in favour of men. The median bonus pay gap increased by 0.7 percentage points, from 6.8% to 7.5% in favour of men.

Although more women received bonus awards in comparison to men, the mean and median bonus awards for men were higher than equivalent measures for women. Therefore, the increase in our bonus pay gaps can be directly correlated to the higher number of men in higher paying roles, as our bonus award is calculated as a percentage of an individual’s salary.

The percentage of men and women receiving bonus pay

   Percentage of men and women receiving bonus pay in the 12 months ending 31 March
 2019/2020  2020/2021  2021/2022
 Men  36.7%  40.9%  38.0%
 Women  37.9%  40.6%  41.2%

The analysis indicates that the percentage of men receiving a bonus award over the past 12 months has decreased by 2.9% percentage points, from 40.9% to 38.0%. This figure is calculated by dividing the number of men who received a bonus in the 12 months to the reporting date, by the total number of men (which explains why it does not add up to 100%).

The percentage of women receiving a bonus over the past 12 months has increased slightly, moving by 0.6% percentage points from 40.6% to 41.2%. The figures are calculated in the same way as those for men, with the same caveat.

We continue to use an end-year moderation process to try and ensure performance ratings and bonus decisions are awarded on a fair and consistent basis to avoid the potential for discrimination. Moderation meetings are held at directorate, senior leadership team and executive committee level. The approach to moderation was strengthened for the 2021 to 2022 performance year by adding a pre-moderation meeting before end of year performance reviews to add another level of consistency in the application of the ratings and nominations. The new process was underpinned by strengthening our guidance and mandatory training for people managers around giving and receiving feedback, and objective setting.

To supplement our existing policy and guidelines governing the appointment of employees above the minimum of the pay band, and to minimise the potential for disparity among pay levels for all employees, we introduced Equal Pay Awareness training for recruiting managers in June 2022. This raises awareness among managers of the various factors that they need to consider when setting starting salary levels, including the impact on internal pay relativities for existing members of staff.

Diversity pay gap data for ethnicity, disability, and sexual orientation

We also voluntarily publish information on our diversity pay gaps for disability, ethnicity, and sexual orientation, although there is no mandatory reporting requirement for us to do so. We do this to drive greater transparency and because we are committed to taking a holistic approach to the fair treatment and reward of all staff and ensuring the TPR is an inclusive place where people can be at their best.

In the absence of any clear guidelines on how to report on pay and bonus gaps for these areas, we reasonably applied the same methodology that is used to calculate gender pay and bonus gaps. A positive pay gap percentage signifies that the majority population for each classification is paid more.

Reporting on the pay and bonus gap data for disability, ethnicity and sexual orientation presents more of challenge, because typically voluntary declaration rates are lower in comparison to gender pay gap reporting (where we have 100% of the data, as it is not reliant on voluntary declaration). The knock-on effect of this is that the analysis has to be conducted on much smaller data sets, which can fluctuate significantly year-on-year. Therefore, only those staff who have chosen to voluntarily declare their disability, ethnicity or sexual orientation were included in the pay and bonus gap analysis.

Our declaration rates on 31 March 2022, were 87% for disability, 87% for ethnicity and 81% for sexual orientation. This incomplete picture affects the accuracy of the data analysis, and where gaps do exist, it makes it more difficult for us to properly understand and tailor action to close them. To improve our data, this year we launched an annual campaign to encourage staff to voluntarily share their diversity information.

Based on the workforce data that we hold, we know that 5% of colleagues declared a disability, 10% of our workforce declared they were from an ethnic minority background, and 8% of our workforce declared themselves gay, lesbian or bisexual.

Further examination of our data indicates that there is little representation within our senior leadership levels within the organisation and we believe this is a significant driver of our pay gaps for disability, ethnicity and sexual orientation. Improving representation within our executive committee, senior leadership team and across all levels of the organisation is a focus for us in our EDI strategy.

Disability pay gap data

The table below provides details of the disability pay gap on 31 March 2022. It also includes comparative mean and median ethnicity pay gap data from our 2021 and 2020 analysis.

An examination of the data shows that the pay gap is more favourable for staff declaring a disability compared with those who specifically identified themselves as being non-disabled.

Year  Difference in mean (average) hourly rate of pay  Difference in median hourly rate of pay
 2022  -5.8%  -6.7%
 2021  -12.7%  -17.6%
 2020  -20.9%  -24.8%

The mean disability pay gap between staff declaring themselves as disabled and those who have specifically identified themselves as being non-disabled, although still more favourable for the former group, has significantly reduced significantly by 6.9 percentage points to -5.8%, from -12.7% in 2021.

The median disability pay gap between staff declaring themselves as disabled and those who have specifically identified themselves as being non-disabled, although still more favourable for the former group, has significantly reduced by 10.9 percentage points to -6.7%, from -17.6% in 2021.

Mean and median disability bonus gap

The table below sets out the mean and median disability bonus gaps and illustrates that these are more favourable when compared to non-disabled colleagues.

However, both the mean and median pay gaps have reduced since the 2021 analysis was undertaken.

The mean disability bonus gap has reduced by 32.6 percentage points to -23.4%, from -56.0% in 2021. The median disability pay gap has reduced by 16.7 percentage points to -52.6%, from -69.3% in 2021.

Year  Difference in mean bonus pay  Difference in median bonus pay
 2022  -23.4%  -52.6%
 2021  -56.0%  -69.3%
 2020  -0.6%  -12.7%

The percentage of non-disabled and disabled employees receiving bonus pay

   2020  2021  2022
 No disability  37.4%  43.2%  40.2%
 Disabled  40.0%  39.5%  41.5%

The percentage of non-disabled and disabled staff in each pay quartile

The percentage of non-disabled and disabled staff in each mean hourly rate quartile pay band as of 31 March 2022.

   Quartiles
 Non-disabled %  Disabled %
 Q4 – Upper hourly pay quartile (highest paid)  82.4% (91.1%) *  10.4% (8.9%) *
 Q3 – Upper middle hourly pay quartile  84.3% (93.9%) *  6.7% (6.1%) *
 Q2 – Lower middle hourly pay quartile  82.9% (96.7%) *  4.5% (3.3%) *
 Q1 – Lower hourly pay quartile (lowest paid)  79.4% (94.5%) *  8.1% (5.5%) *

* NB: The figures in brackets illustrate the proportion of non-disabled and disabled staff in each of the four quartiles from the 2021 gender pay analysis and have been included for comparative purposes.

The proportion of staff disclosing that they have a disability, has increased in each four of the quartiles since the 2021 report.

The proportion of non-disabled staff in each of the four quartiles has decreased since the 2021 report.

Ethnicity pay gap data

The table below provides details of the ethnicity pay gap on 31 March 2022. It also includes comparative mean and median ethnicity pay gap data from our 2021 and 2020 analysis.

A comparison of the ethnicity pay gap over the past three years shows that both the mean and median pay gaps are continuing to grow – and the gap continues to be less favourable for minority ethnic staff in comparison to white colleagues.

Year  Difference in mean (average) hourly rate of pay  Difference in median hourly rate of pay
 2022  18.5%  14.1%
 2021  16.7%  13.4%
 2020  11.4%  11.7%

The mean ethnicity pay gap has increased by 1.8 percentage points to 18.5%, from 16.7% in 2021 in favour of white colleagues, in comparison to minority ethnic staff.

The median ethnicity pay gap has increased 0.7 percentage points to 14.1%, from 13.4% in 2021 in favour of white colleagues, in comparison to minority ethnic staff.

Mean and median ethnicity bonus gap

The table below sets out the mean and median ethnicity bonus gaps and illustrates that these are less favourable when compared to white colleagues.

The mean ethnicity bonus gap has increased by 11.9 percentage points to 29.2%, from 17.3% in 2021. The median ethnicity bonus gap has increased by 3.4 percentage points to 36.4%, from 33.0% in 2021.

It also highlights that over the course of the last three pay gap reviews, the ethnicity mean and median bonus gaps have continued widening.

Year  Difference in mean bonus pay  Difference in median bonus pay
 2022  29.2%  36.4%
 2021  17.3%  33.0%
 2020  0.8%  23.7%

The percentage of white and minority ethnic employees receiving bonus pay

   2020  2021  2022
 White  38.5%  44.6%  42.7%
 Minority ethnic  26.9%  16.0%  18.1%

The percentage of white and minority ethnic staff in each pay quartile

The percentage of white and minority ethnic staff in each mean hourly rate quartile pay band on 31 March 2022.

   Quartiles
 White %  Minority ethnic %
 Q4 – Upper hourly pay quartile (highest paid)  83.8% (94.5%) *  5.9% (5.5%) *
 Q3 – Upper middle hourly pay quartile  79.8% (90.1%) *  12.1% (9.9%) *
 Q2 – Lower middle hourly pay quartile  77.9% (85.2%) *  8.1% (14.8%) *
 Q1 – Lower hourly pay quartile (lowest paid)  76.2% (89.0%) *  16.1% (11.0%) *

* NB: The figures in brackets illustrate the proportion of white and minority ethnic staff in each of the four quartiles from the 2021 gender pay analysis and have been included for comparative purposes.

The proportion of minority ethnic staff in three of the four quartiles has increased since 2021, in Q1, Q3 and Q4.

The proportion of white staff in each of the four quartiles has decreased significantly from 2021.

Sexual orientation pay gap data

The overall sexual orientation pay and bonus gaps are less favourable for those who identify as lesbian, gay, bisexual or recorded their sexual orientation as ‘other’ (LGB+) compared to heterosexual colleagues.

Year  Difference in mean (average) hourly rate of pay  Difference in median hourly rate of pay
 2022  11.4%  12.0%
 2021  10.4%  10.1%
 2020  12.2%  15.1%

The mean sexual orientation pay gap has increased by 1 percentage point to 11.4%, from 10.4% in 2021.

The median sexual orientation pay gap has increased 1.9 percentage points to 12.0%, from 10.1% in 2021.

Mean and median sexual orientation bonus gap

The table below illustrates that both the mean and median sexual orientation bonus gaps are less favourable compared to heterosexual colleagues.

The mean sexual orientation bonus gap has increased by 9.5 percentage points to 12.8%, from 3.3% in 2021. The median sexual orientation bonus gap has decreased by 22.1 percentage points to 11.5%, from 33.6% in 2021.

Year  Difference in mean bonus pay  Difference in median bonus pay
 2022  12.8%  11.5%
 2021  3.3%  33.6%
 2020  6.3%  18.5%

The percentage of heterosexual and LGB+ employees receiving bonus pay

   2020  2021  2022
 Heterosexual  37.1%  41.0%  40.9%
 LGB+  41.2%  41.8%  33.3%

The percentage of heterosexual and LGB+ employees in each pay quartile

The percentage of heterosexual and LGB+ staff in each mean hourly rate quartile pay band on 31 March 2022 is illustrated in the table below.

   Quartiles
 Heterosexual %  LGB+ %
 Q4 – Upper hourly pay quartile (highest paid)  97.5% (92.9%) *  5.9% (7.1%) *
 Q3 – Upper middle hourly pay quartile  77.6% (88.7%) *  8.5% (11.3%) *
 Q2 – Lower middle hourly pay quartile  73.9% (89.9%) *  7.2% (10.1%) *
 Q1 – Lower hourly pay quartile (lowest paid)  73.1% (88.7%) *  12.1% (11.3%) *

* NB: The figures in brackets illustrate the proportion of heterosexual and LGB+ staff in each of the four quartiles from the 2021 gender pay analysis and have been included for comparative purposes.

The proportion of LGB+ staff in three of the four quartiles has decreased, in Q2, Q3 and Q4 since the 2021 report.

The proportion of heterosexual staff has decreased in quartiles Q1, Q2 and Q3, but increased in Q4 since the 2021 report.

Key actions we have taken to improve our pay gaps over the last year:

  • We have created a new People team function to put the right structures, resources and expertise in place to deliver against these commitments. This includes the creation and appointment of appointing a new Reward Lead, an Employee Relations team, a Head of Talent and Development and a Talent and Acquisition Lead, who will all be instrumental in developing and driving forward diversity pay gap action plans and wider EDI Strategy.
  • To supplement our existing policy and guidelines governing the appointment of employees above the minimum of the pay band and to minimise the potential for disparity among pay levels for all employees, we introduced equal pay awareness training for recruiting managers in June 2022.This will raise awareness among managers of the various factors that they need to consider when setting starting salary levels, including the impact on internal pay relativities for existing members of staff.
  • We appreciate that we have low representation from ethnic minority and LGB+ individuals at the most senior levels or in the upper pay quartiles. We have undertaken a number of key actions to promote inclusive recruitment practices, to appeal to a diverse pool of prospective applicants, including:
    • introducing a refreshed recruitment policy and guidance, with guidance on assessment tools, recruitment training requirements and reasonable adjustments
    • providing our People Managers with a briefing on steps that they can take to make recruitment more inclusive
    • removing all questions relating to salary history from the application process and interview discussions
    • adding a statement to our adverts which says we welcome applications from underrepresented groups at TPR, including LGB+, minority ethnic, and disabled
    • introducing mandatory interview feedback for all internal applicants from underrepresented groups building on effective feedback training delivered earlier in the year
    • establishing a fair recruitment hub with tools and guidance for hiring managers and all staff
    • designing a one-page candidate pack to demystify the recruitment process, with guidance on CV and cover letters, recruitment timelines, outlining reasonable adjustments available and how they can be accessed
    • designing and collecting feedback on our recruitment process from applicants who reach the interview stage
    • introduced language proofing software to highlight biased language and ensure our adverts are neutral
    • taking part in an open day at a local sixth form college to promote careers to young people especially in the fields of digital, data and technology
    Overall, this should have a positive impact on our pay gaps for all groups.
  • We have worked with our Procurement team to maximise our use of Apprenticeships to provide career development opportunities for internal staff and contribute to our talent pipeline.
  • We launched an inclusive leadership training programme for all people managers. The programme encouraged managers to think about a range of actions they can take to shine a light on hidden inequalities, disrupt the status quo, and play their part in creating an inclusive culture at TPR.
  • We launched an annual diversity data campaign to improve the number of staff declaring their diversity data and increased our overall declaration rates from of 84% to 89%.

Future actions we are taking to improve our pay gaps

Improve recruitment and promotion processes

  • We will explore how we can monitor the effectiveness of our recruitment methods, including advertising to ensure that we are reaching as broad an audience as possible in terms of gender, disability, ethnicity, and sexual orientation. Currently we do not have an applicant tracking system and this limits our ability to identify and target interventions appropriately and monitor and evaluate the impact of the actions we have implemented. We will continue to explore options to bridge this gap.
  • We will look at how we can monitor recruitment data at application, shortlisting and appointment stages to assure ourselves of fairness in recruitment and career progression, with a particular focus on gender, ethnicity, disability, and sexual orientation.
  • Through our recruitment campaign meetings, we will remind all hiring managers to consider taking action for more diverse interview panels.
  • We will deliver sessions that help prepare with hints and tips for applying for roles and getting ready for interviews through our diversity network group meetings.

Career development and progression

  • We will support our diversity network groups to find inspirational speakers to share their lived experience and insights for career progression.
  • We will explore partnerships with suppliers who have lived experience and can deliver targeted career development sessions for progressing into people management and leadership for our individuals from underrepresented backgrounds.
  • We will explore the development of a coaching and mentoring programme for individuals from underrepresented backgrounds to support their progression to more senior roles.
  • We will explore the use of partnerships with external network groups such as Women in Technology to support mentoring.
  • We will launch our talent and development three-year plan in 2023 which will closely align talent plans/actions with EDI plans to attract and retain talent from more diverse backgrounds.

Flexible working and job-sharing

  • We will continue to promote our policies both internally and externally through advertising for all roles (including the most senior) that we offer flexible working and job-sharing opportunities.

Apprenticeships

  • We will continue to work with our procurement team to explore how we can maximise our use of apprenticeships to provide career development opportunities for both internal and external applicants to contribute to our talent pipeline.

Measure and evaluate policies to support diversity and inclusion

  • We will produce a breakdown of the gender and diversity pay gaps by function or directorate, to give greater ownership to executive and senior leaders and obtain greater insight into where challenges are. This will enable us to take more targeted actions.
  • We will review our discretionary bonus scheme arrangements as part of the high level three-year review of our pay arrangements, which is scheduled to be undertaken in 2023. This will not change bonus outcomes for the 2023/24 period.
  • We will use exit interviews to understand the reasons people leave our organisation and use this information to inform our People processes and diversity and inclusion strategy and actions.
  • We will use this data to help us understand the causes of our organisation’s diversity pay gaps.
  • We will carry out an annual initiative to embed diversity declaration into our induction and onboarding processes to increase the reliability of our diversity data, ensure we're reporting the gaps accurately and take targeted actions.
  • We will develop measures to effectively monitor and report on progress against the diversity pay gap action plan.

We will provide a report of progress towards our wider EDI strategy in our Annual Report and Accounts 2022 to 2023, to be published in summer 2023.

Endnote for this page

  • [1] Transgender and non-binary staff reporting — the Equality Act 2010 (Gender Pay Gap Information) Regulations 2017 require employers to calculate their gender pay gap by comparing the pay of their male and female employees. The terms ‘men’ and ‘women’ are not defined in the regulations, leaving employers to decide for themselves how to categorise and include transgender and non-binary employees in their reporting. Government guidance says if the employee does not self-identify as either male or female, they can be omitted from calculations.

    In TPR we capture data on sex under three options, ‘male’, ‘female’ and ‘other’. In line with the regulations only those who self-identify as ‘male’ or ‘female’ are included in the calculations. Those who self-identify as ‘other’ are omitted from the gender calculations as the sample size is too small, and we would not be able to protect anonymity. We do not capture data on gender identity. We capture data on gender reassignment, but we are unable to report on gender reassignment calculations as the sample size is too small, and we would not be able to protect anonymity. We acknowledge that this does not reflect our efforts towards inclusion of the trans and non-binary community and we are exploring how our reporting can be more inclusive going forward.