What is a pay equity plan?
A key component of Part II of the Act is the pay equity plan. Pay equity plans provide employees with information about how pay equity was done in their establishment and the results and therefore should be accessible to all employees. The Act requires that pay equity plans be posted in prominent places in each establishment and that copies of a plan be provided upon request to bargaining agents or non-union employees.
i. Which employers are required to post a pay equity plan?
All Part II employers are required to post a pay equity plan. Private sector employers who employed 10 to 99 employees as of January 1, 1988 may have chosen to post a plan in order to phase in pay equity adjustments. However, after January 1, 1994 when Part III of the Act was repealed, the option to post a plan for these smaller employers no longer existed. Currently, the only employers required to post plans are large private sector employers who had employees on January 1, 1988, and public sector employers that existed on the effective date or July 1, 1993. New private sector employers, regardless of size, are not required to post plans.
ii. What were the deadlines for posting pay equity plans?
See What are the Compliance Deadlines? for dates for posting pay equity plans. An employer who was required to post a plan but missed the posting deadline must develop the plan, make adjustments and achieve pay equity as if the process proceeded on time.
iii. How many pay equity plans are required?
Employers who were required to prepare pay equity plans must have at least one pay equity plan for each establishment. If the workplace was unionized at the effective date, there must be separate plans for each bargaining unit, the contents of which must be negotiated [14. (4)], and one for all non-union employees [14. (1)].
iv. What are the contents of pay equity plans?
The Act specifies what must be contained in a pay equity plan for job-to-job plans , for proportional value plans [21.6], and for proxy plans [21.18]. Job-to-job plans must:
- Identify the establishment and the group of employees covered by the plan (i.e. non-union or bargaining unit employees).
- List all female job classes covered by the plan and all male job classes that were evaluated as potential comparators.
- Describe the gender neutral comparison system used to do the job comparisons.
- List the results of pay equity comparisons, including:
- all the female job classes and the male job classes found to be equal or comparable in value;
- the difference in job rates between each female job class and its male comparator, or a statement that pay equity already exists for the female job class;
- a list of female job classes that did not find male comparators.
- Explain any permissible differences in compensation relied on to explain differences between female job classes and their male comparators.
- Describe how compensation will be adjusted to achieve pay equity.
- Note the date on which the first adjustments will be effective (and effective dates of any adjustments made retroactively if the plan was posted late).
- Describe the method used to achieve pay equity, either job-to-job or proportional value comparison, for each female job class.
- Describe the method used to carry out the proportional value calculations.
- List of the male job classes that made up the representative group and how they were selected.
- Identify how the relationship of job rate to job value was determined for the representative group of male job classes.
- Describe any revisions made to the original job-to-job pay equity plan.
v. How long should the pay equity plan be posted for?
The Act does not state how long employers must post pay equity plans or keep other pay equity documents. The law does state that employers who are required to post a pay equity plan shall provide a copy to bargaining agent or employees upon request [1. (3)]. The Commission recommends that the plan be posted until pay equity is achieved or the plan is amended. It is advisable to keep records of the pay equity plan and its posting date.