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Equal Pay Policy Template
The Equality Act 2010 gives employees a legal right to equal pay covering every element of remuneration — not just salary, but bonuses, pension contributions, LTIPs, car allowances, and share options — with claims reaching back six years and attracting back pay, pension recalculation, and statutory interest. For FCA-regulated firms, the exposure doesn't stop at the Employment Tribunal. A Senior Manager whose pay decisions are found discriminatory faces fitness and propriety questions under SYSC 22, and a firm that can't demonstrate systematic pay auditing and documented remediation can't demonstrate adequate governance to the FCA either. A pay gap you don't find, they will. The FCA doesn't wait.
What's included:
Full legislative mapping: Equality Act 2010 ss64–78, Gender Pay Gap Regulations 2017, Part-time Workers Regulations, ERA 1996, EHRC guidance, FCA SYSC 22, and SM&CR Conduct Rules
Five-concept equal pay framework: Equal Pay, Like Work, Work Rated as Equivalent, Work of Equal Value, and Comparator — with Material Factor Defence criteria
Comprehensive remuneration scope: salary, overtime, commission, bonus, LTIP, pension, PMI, car allowances, share options, and flexible working monetary value
Pay audit framework: annual comprehensive, quarterly focused, ad-hoc (post-restructure), and immediate (on complaint receipt) — covering all remuneration elements
Statistical analysis methodology: mean/median gap calculations, regression analysis, and quartile distribution — 5% threshold triggers immediate investigation
Back pay calculation matrix: up to 6-year limitation, overtime recalculation, pension adjustment, and statutory interest — processed through the next available payroll
Dispute resolution: 10-day informal resolution, 20-day formal investigation, appeal process, ACAS Early Conciliation, and Employment Tribunal
+ much more
Who is this for?
Compliance Officers, HR Directors, Remuneration Committee members, SMF16 holders, and Board members at FCA-regulated firms who need a complete, board-approved Equal Pay Policy addressing Employment Tribunal exposure, gender pay gap reporting, and FCA governance obligations simultaneously.
How it works
Step 1 — Read it. Every section exists for a reason, grounded in a specific regulatory obligation.
Step 2 — Understand it. Map the content against your current practices. Identify where you're strong and where gaps exist.
Step 3 — Make it yours. Tailor the language to reflect how your organisation actually operates. A policy that sounds like your firm is a policy your people will follow.
Step 4 — Take ownership. Assign clear accountability — Board approval, named SMF holder, designated policy owner. A policy without an owner is a liability, not an asset.
Step 5 — Operationalise it. Embed the policy into your governance calendar, training programme, and annual review cycle. This is where compliance becomes culture.
Or, get this free with RegTechPRO
Access this alongside the full compliance policy library — SM&CR, COBS, AML, Consumer Duty, GDPR, and more — for a fraction of the cost of consultancy.
The Equality Act 2010 gives employees a legal right to equal pay covering every element of remuneration — not just salary, but bonuses, pension contributions, LTIPs, car allowances, and share options — with claims reaching back six years and attracting back pay, pension recalculation, and statutory interest. For FCA-regulated firms, the exposure doesn't stop at the Employment Tribunal. A Senior Manager whose pay decisions are found discriminatory faces fitness and propriety questions under SYSC 22, and a firm that can't demonstrate systematic pay auditing and documented remediation can't demonstrate adequate governance to the FCA either. A pay gap you don't find, they will. The FCA doesn't wait.
What's included:
Full legislative mapping: Equality Act 2010 ss64–78, Gender Pay Gap Regulations 2017, Part-time Workers Regulations, ERA 1996, EHRC guidance, FCA SYSC 22, and SM&CR Conduct Rules
Five-concept equal pay framework: Equal Pay, Like Work, Work Rated as Equivalent, Work of Equal Value, and Comparator — with Material Factor Defence criteria
Comprehensive remuneration scope: salary, overtime, commission, bonus, LTIP, pension, PMI, car allowances, share options, and flexible working monetary value
Pay audit framework: annual comprehensive, quarterly focused, ad-hoc (post-restructure), and immediate (on complaint receipt) — covering all remuneration elements
Statistical analysis methodology: mean/median gap calculations, regression analysis, and quartile distribution — 5% threshold triggers immediate investigation
Back pay calculation matrix: up to 6-year limitation, overtime recalculation, pension adjustment, and statutory interest — processed through the next available payroll
Dispute resolution: 10-day informal resolution, 20-day formal investigation, appeal process, ACAS Early Conciliation, and Employment Tribunal
+ much more
Who is this for?
Compliance Officers, HR Directors, Remuneration Committee members, SMF16 holders, and Board members at FCA-regulated firms who need a complete, board-approved Equal Pay Policy addressing Employment Tribunal exposure, gender pay gap reporting, and FCA governance obligations simultaneously.
How it works
Step 1 — Read it. Every section exists for a reason, grounded in a specific regulatory obligation.
Step 2 — Understand it. Map the content against your current practices. Identify where you're strong and where gaps exist.
Step 3 — Make it yours. Tailor the language to reflect how your organisation actually operates. A policy that sounds like your firm is a policy your people will follow.
Step 4 — Take ownership. Assign clear accountability — Board approval, named SMF holder, designated policy owner. A policy without an owner is a liability, not an asset.
Step 5 — Operationalise it. Embed the policy into your governance calendar, training programme, and annual review cycle. This is where compliance becomes culture.
Or, get this free with RegTechPRO
Access this alongside the full compliance policy library — SM&CR, COBS, AML, Consumer Duty, GDPR, and more — for a fraction of the cost of consultancy.

