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EEOC Releases Proposed Rule to Collect Pay Data from Employers

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EEOC-bannerRecent news shows that the gender pay gap is not only persistent, it is worsening as time goes on, and this gap is even more pronounced for women of color. President Obama’s proposed effort to address the gap has important implications for companies with 100+ employees and their diversity and inclusion efforts. Fair or not, compensation is an easily identifiable marker of a company’s commitment, or lack thereof, to D&I. And whether intentional or not, if your compensation data is not compliant with concepts of equity on its face, defending your comp policy to the EEOC is going to be difficult, if not impossible.

A company’s compensation system is an important element in its overall business strategy, and it should work in concert with your D&I efforts to achieve bottom line business goals, but also to ensure you are maximizing all your talent to do so, and that includes diverse employees. Do you have a compensation system that is fair both in application and in its results? Are you prepared to begin reporting your data to the government without having done a thorough review of your approach to ensure you are comfortable with your submission? We recommend getting out in front of this proposed rule making by doing a comprehensive review of your compensation strategy, its application and its de facto impact. It behooves all companies who must report EEO-1 data to align their compensation strategies with diversity and inclusion initiatives, and to do so before the government mandates it. This approach is just one more value add in incorporating all the various elements of your business operations into one seamless macro business strategy, and this includes diversity and inclusion.