The pay survey is not a mere presentation of current pay data. "In order to take concrete steps towards equal pay, it is important that women's and men's pay are compared with each other and that the reasons for pay differences are examined." This is a quote from a statement by the Employment and Equality Committee of the Finnish Parliament at the time it discussed the pay survey provision.
In other words, pay comparisons and analysis of pay differences are an essential part of the pay survey. The purpose of the pay survey is, first and foremost, to determine whether there are unjustified differences in pay at the workplace. Once differences are identified, the first step is to assess their reasons and establish whether they are gender-based, either directly or indirectly. Subsequently, an assessment of whether the grounds for the pay differences are acceptable or unjustified from the point of view of the Equality Act, must be made.
This assessment serves as a basis for the measures concerning pay to be set out in the gender equality plan.
According to the Act, measures necessary for achieving equality in pay must be included in the gender equality plan. The pay is mentioned in the Act specifically as one of the areas that must be tackled by including specific measures in the equality plan. If no concrete measures concerning pay issues are recorded in the gender equality plan, there is reason to justify this in the plan.
The measures should be as concrete as possible. It is advisable to include in the plan a time frame within which the measures concerning pay are to be implemented, even if such a time frame is not set down in the Equality Act.
Pay survey and the assessment of gender equality
According to the Equality Act, it may be agreed locally that the pay survey and the assessment of the gender equality situation in the workplace are conducted at least once every three years.
Decisions on measures to be taken
Necessary measures included in the gender equality plan must be updated and a review of the implementation of measures must be made annually.
The minimum content requirements for a gender equality plan, among other issues, are provided by the Equality Act. The Equality Act does not contain detailed provisions on how the pay survey should be made in practice. Some instructions on how to prepare the pay survey can be found in the preparatory materials of the Equality Act. In addition, the objective of the pay survey to ensure that the pay is non-discriminatory, provides some guidelines. The above instructions by the Ombudsman for Equality are based on these premises.
Many issues raised when conducting the pay survey are related to the preparation of equality plans in general.
For further information
The gender equality plan