Providing Pay Equity Proof
Since 1988, the Pay Equity Commission has been ensuring that companies provide equal pay, for work of equal value. This work is done through investigators that call on companies to provide proof of their programs that support this legislative Act, and its requirements of companies in Ontario. If you are an employer in Ontario with more than 10 employees, you are required to implement a Pay Equity plan to ensure your compliance with the Pay Equity Act.
Pay Equity Determination
Providing proof of your company’s program requires that you have implemented a program within a reasonable timeframe after the passing of the Act, or upon start-up of operations for all new companies in Ontario. The first thing that is required is an evaluation and determination of all job classifications within your operations. A questionnaire of employees as to their duties can provide a basis of understanding for job descriptions in order to determine job classifications. Once the determination of active job classifications are complete, a committee can be created and tasked with evaluating current jobs and their pay equity status.
Committees for Pay Equity
This Job Evaluation committee should be comprised of a diverse background within the company, including both genders, different levels of experience within the company and different socio-economic factors as well. Rules that govern the committee should be laid out as well in regards to meeting times, in case of member absences, a consensus of the members and rules regarding classifying ones’ own job. Once the initial review is complete, and classification and pay adjustments, if any, are complete, there needs to be ongoing review of the pay equity plan to compensate for changing roles and job classifications within the company.
Pay Equity Implementation
To prove the implementation of a Pay Equity system, it is not enough to simply have minutes from a Committee. There needs to be signs and paper proof that the system provided a real evaluation, and an implementation of that evaluation. The following procedures need to have been completed:
- The Gender Neutral Comparison System
- Scores awarded for each job
- Records of pay and benefits per job recorded
- Formal Job Descriptions drawn up or provided
- A survey of genders actually occupying the jobs
- For Public Sector employers with insufficient male job classes, the alternate Proxy Comparator’s jobs, pays and job scores need to be provided.
These procedures ensure that you have actually implemented a Pay Equity procedure that requires an actual review of your current pay scales and job duties.
Pay Equity Maintenance
The ability of a company to provide a manual from 10, 15, or 20 years ago when the policies were initially implemented is simply not enough. Pay Equity issues surface in a company over time as jobs are changed or new job classifications are created. Without regular maintenance of your Pay Equity policies, the company could still be liable for pay equity disbursements from the time the company stopped maintaining these equitable procedures. A regular review to show revision of job classifications, pay scales, gender surveys and records of cost of benefits are required.
These procedures, when kept in continual maintenance with the proper paper records such as Committee Rules, Committee minutes and other necessary paperwork, will show continued compliance with the Pay Equity Act.
If you need further information on the Ontario Pay Equity act itself, or require consultation to further analyze your existing pay equity situation, we are here to help.
