Questions & Answers
Can you please specify if for the below indicators: the gender pay gap, defined as the difference of average pay levels between female and male employees, expressed as percentage of the average pay level of male employees; should we include variable components of salary or only gross wage?
- Gender pay gap
- gross wage
- salary - variable components
Background
Annex II Acronyms and Glossary of Terms states the following:
‘PAY: the ordinary basic or minimum wage or salary and any other remuneration, whether in cash or in kind, which the worker receives directly or indirectly (“complementary or variable components”) in respect of his/her employment from his/her employer. “Pay level” means gross annual pay and the corresponding gross hourly pay. “Median pay level” means the pay of the employee that would have half of the employees earn more and half less than they do’.
Disclosure Requirement S1-16 includes the following paragraphs on remuneration metrics (pay gap and total remuneration):
‘95. The undertaking shall disclose the percentage gap in pay between its female and male employees and the ratio between the remuneration of its highest paid individual and the median remuneration for its employees.’
‘97. The disclosure required by paragraph 95 shall include: (a) the gender pay gap, defined as the difference of average pay levels between female and male employees, expressed as a percentage of the average pay level of male employees . . .’
‘98. The undertaking may disclose a breakdown of the gender pay gap as defined in paragraph
97 (a) by employee category and/or by country/segment. The undertaking may also disclose the gender pay gap between employees by categories of employees broken down by ordinary basic salary and complementary or variable components’.
ESRS S1 paragraph 97 includes additional information in a footnote as follows: ‘The gender pay gap information supports the information needs of: financial market participants subject to Regulation (EU) 2019/2088 because it is derived from a mandatory indicator related to principal adverse impacts as set out by indicator #12 in Table I of Annex I of Commission Delegated Regulation (EU) 2022/1288 with regard to disclosure rules on sustainable investments (“Unadjusted gender pay gap”); and benchmark administrators to disclose ESG factors subject to Regulation (EU) 2020/1816 as set out by indicator “Weighted average gender pay gap” in Section 1 and 2 of Annex II.’
Answer
Complementary and variable components of the employee’s remuneration package form part of the calculation. Annex II Acronyms and Glossary of Terms defines ‘pay’ as the salary and other remuneration in cash or in kind that the employee directly or indirectly receives in respect of his/her employment.
ESRS S1-16 AR 98 describes the methodology to follow when calculating the gender pay gap required by ESRS S1-16 paragraph 97 (a). The value to be used in the ratio is the gross hourly pay level.
Relations
Paragraph | Content |
|---|---|
The undertaking may disclose a breakdown of the gender pay gap as defined in paragraph 97(a) by employee category and/or by country/segment. The undertaking may also disclose the gender pay gap between employees by categories of employees broken down by ordinary basic salary and complementary or variable components. | |
The disclosure required by paragraph 95 shall include: | |
The undertaking shall disclose the percentage gap in pay between its female and male employees and the ratio between the remuneration of its highest paid individual and the median remuneration for its employees. | |
The undertaking may disclose a breakdown of the gender pay gap as defined in paragraph 97(a) by employee category and/or by country/segment. The undertaking may also disclose the gender pay gap between employees by categories of employees broken down by ordinary basic salary and complementary or variable components. | |
The disclosure required by paragraph 95 shall include: | |
The undertaking shall disclose the percentage gap in pay between its female and male employees and the ratio between the remuneration of its highest paid individual and the median remuneration for its employees. | |
The disclosure required by paragraph 95 shall include: | |
The undertaking shall disclose the percentage gap in pay between its female and male employees and the ratio between the remuneration of its highest paid individual and the median remuneration for its employees. | |
The disclosure required by paragraph 95 shall include: | |
The undertaking shall disclose the percentage gap in pay between its female and male employees and the ratio between the remuneration of its highest paid individual and the median remuneration for its employees. |