Many companies struggle with EU legislation on pay transparency. What exactly is required of us? Are we compliant, or do we need to adjust our job architecture or compensation policy? What information do we share when an employee exercises their right to request salary information? And what pay gap figures will we need to disclose?
To prevent legal risks and reputational damage, but also to remain an attractive employer, it’s important to take action in time. Highberg supports organizations in their preparation. Together, we ensure your organization is ready for the future.
1. Readiness Scan
Legislative Compliance Assessment
The Readiness Scan maps where your organization stands in relation to the requirements of the EU Pay Transparency Directive. The scan identifies bottlenecks, risks, and concrete action points regarding compensation policy, processes, data quality, and governance. Result: insight into which areas you are already compliant, and where attention or action is still required.
2. Job Architecture
Solid Foundation for Compensation
The job architecture forms the foundation for compensation policy and pay gap analyses. Therefore, it’s a crucial starting point in preparing for pay transparency. Highberg’s team has years of experience in designing and implementing job architectures in various forms. This includes job architectures based on job evaluation, or a more generic approach with job families or a classification model. Even if a job architecture already exists, we gladly assist with legislative compliance testing and job evaluation reviews.
3. Compensation Policy
Objective and Gender-Neutral Compensation Structures
The legislation requires a clear description of the criteria that determine compensation levels and development. Highberg’s experts support in designing or refining compensation policy, for example in establishing salary scales and salary increase systems. In this process, we focus on aspects including alignment with organizational philosophy, market position relative to benchmarks, and financial feasibility. We also help with implementation.
Keep in mind that policy changes often require works council approval. If adjustments are needed, delay is not advisable.
4. Salary Transparency in the Recruitment Process
Clarity for Candidates Before the First Interview
We advise on and implement processes ensuring candidates are informed about the starting salary or corresponding salary scale before the first interview. We also support in adapting recruitment policies, for example by excluding questions about salary history.
5. Employee Insight
Right to Pay Transparency Within the Organization
We help organizations set up processes, policies, and systems that give employees easy access to information about their own compensation and the average compensation of colleagues in comparable positions, broken down by gender. We ensure proper application of filters so that data is presented relevantly without compromising privacy rules.
6. Pay Gap Analysis, Equal Pay Assessment and Mandatory Reporting
Pay Gap Investigation and Advice on Corrective Measures
The Directive requires organizations to periodically conduct pay gap analyses and publish their findings. Where a pay gap of more than 5% is found, additional investigation is needed, for example through an explanatory equal pay analysis.
Highberg has developed a process and tooling to meet these analysis and reporting obligations in accordance with the standards of the EU Pay Transparency Directive, as well as the CSRD, the European Banking Authority, and other standards.
