I’ve blogged that activist shareholders have no intention of dialing back their “gender pay gap” efforts, and that shareholder support might be increasing. In addition, as I blogged a few months back, it appears that companies will be required to file pay data with the EEOC at the end of this month – and As You Sow says they’ll use that to push for more proxy disclosure. An Orrick blog discusses the evolution of these types of proposals – and reiterates that companies should expect to receive these proposals in years to come. It offers this advice for preparing:
Organizations should consult with counsel in evaluating whether disclosure of pay gap information is right for the company, and on what terms. Employers may also consider performing a pay-equity analysis — if they are not doing so already — to evaluate employee jobs and compare pay among competitors. Typically, this involves retaining legal counsel, and possibly a labor economist to work at counsel’s direction and conduct a privileged assessment. Given the near-certainty that many large companies will be on the receiving end of a pay gap disclosure proposal at some point in the future, preparedness is key in addressing and disclosing internal pay gap information.
-Liz Dunshee, TheCompensationStandards.com September 13, 2019
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