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16.6.2022

Gender Pay Gap Reporting Ireland – Regulations Published

Gender Pay Gap Reporting Ireland – Regulations Published | EisnerAmper Ireland | ESG

On 3 June 2022, the Minister for Children, Equality, Disability, Integration and Youth published the long-awaited Employment Equality Act 1998 (section 20A) (Gender Pay Gap Information) Regulations 2022 (“the Regulations”).

The Regulations provide the underlying obligations and calculation details for the Gender Pay Gap Information Act 2021 (“the Act”) which was signed into law in July 2021. The Act requires organisations to report on their hourly gender pay gap across a range of metrics.

The Regulations provide vital definitions, such as those for ‘allowance’, ‘relevant date’, ‘relevant pay period’, and ‘working hours’.

The Regulations set out how to calculate Hourly Remuneration, Total Number of Working Hours, Bonus Remuneration, as well as setting out details on the format of publication of results by employers.

What we know

Initially, organisations with 250+ employees will be required to report their Gender Pay Gap metrics for the first time in 2022.

Organisations should select their relevant date (i.e. snapshot date) in the month of June. Calculations should be prepared based on relevant employees on this date and reported no later than six months after this date, in December 2022.

Organisations are required to report the following figures:

  1. The mean and median gap in hourly pay between men and women;
  2. The mean and median gap in bonus pay between men and women;
  3. The mean and median gap in hourly pay of part-time male and female employees;
  4. The mean and median gap in hourly pay of male and female employees on temporary contracts;
  5. The percentage of men and women who received bonus pay;
  6. The percentage of men and women who received benefits in kind; and
  7. The percentages of male and female employees who fall within each of:
    • the lower remuneration quartile pay band;
    • the lower middle remuneration quartile pay band;
    • the upper middle remuneration quartile pay band; and
    • the upper remuneration quartile pay band.

The report should also include:

(i) the reasons for any differences; and
(ii) the measures (if any) being taken, or proposed to be taken, by the employer to eliminate or reduce these differences.

The gender pay gap information should be published on the organisation’s website or in some other way that is accessible to all of its employees and to the public.

Ensure Gender Pay Gap Reporting Compliance

While reporting will be mandatory for employers with 250 or more employees initially, by 2024 this threshold will decrease to 150+ employees and in 2025 will decrease further to 50+ employees.

It is recommended that all organisations start performing Gender Pay Gap calculations now. Organisations that understand their Gender Pay Gap metrics can make positive steps to be in a better position when reporting and publishing requirements become applicable.

How EisnerAmper Ireland can help

At EisnerAmper Ireland, our dedicated team of outsourced payroll and advisory professionals possess the tools and the expertise to analyse your payroll data and produce detailed reports highlighting the current gender pay gap in your organisation.

If we can help you or your business in any way, please do get in touch – we’d be delighted to help.

Contact Us

Learn more about our ESG Services here.

Authors

The content above is provided for general information purposes only and is not intended to provide, nor does it constitute, professional advice on any particular matter. If you would like more information or would like to discuss any of the topics raised above, please contact the author(s).

ESG Insights
20.5.2022

Sustainable Finance: Update on the Application of the Sustainable Finance Disclosure Regulation (“SFDR”)

Sustainable Finance | SFDR Update | ESG | FinancialServices | EisnerAmper Ireland

The Sustainable Finance Disclosure Regulation (“SFDR”) sets out sustainability-related disclosure requirements for financial market participants and financial advisers. Its aim is to improve the transparency and comparability of sustainability-related disclosures for end investors, and to reduce the occurrence of adverse sustainability impacts of investment decisions and greenwashing.

The SFDR and related Regulatory Technical Standards which specify the required content and presentation of information to be disclosed are part of a broader range of European Commission (“EC”) initiatives on sustainable development.

On 6 April 2022, the EC published the final version of the Regulatory Technical Standards (“RTS”) under the SFDR.

The RTS contain the final prescribed-form templates for:

  • Annex I: The statement for presenting key performance indicators under the principal adverse impacts regime.
  • Annex II: Pre-contractual disclosures for the financial products referred to in Article 8 of the SFDR – i.e. a financial product which promotes, among other characteristics, environmental or social characteristics, or a combination of those characteristics, provided that the companies in which the investments are made follow good governance practices.
  • Annex III: Pre-contractual disclosures for the financial products referred to in Article 9 of the SFDR – i.e. a financial product which has sustainable investment or a reduction in carbon emissions as its objective.
  • Annex IV: Periodic disclosure for the financial products referred to in Article 8.
  • Annex V: Periodic disclosure for the financial products referred to in Article 9.

Financial market participants and financial advisers should now familiarise themselves with the mandatory reporting templates for pre-contractual and periodic disclosures as well as the Principal Adverse Sustainability Impacts Statement in order to be in a position to make these disclosures from the application date – i.e. 1 January 2023.

How EisnerAmper Ireland can help

As Partner in EisnerAmper’s Governance, Risk & Compliance Group, Carina Myles advises financial service providers on risk, regulatory and compliance-related matters. EisnerAmper’s specialist services include:

  • Supporting organisations through regulatory change;
  • Provision of bespoke board support and training;
  • Designing and developing integrated risk and compliance frameworks;
  • Preparing compliance briefings for discussion with the board; and
  • Supporting the board in responding to and implementing any changes required relating to evolving needs.

If we can help you or your business in any way, please do get in touch – we’d be delighted to help.

Contact Us

Learn more about our ESG Services here.

Authors

The content above is provided for general information purposes only and is not intended to provide, nor does it constitute, professional advice on any particular matter. If you would like more information or would like to discuss any of the topics raised above, please contact the author(s).

ESG Insights
12.4.2022

Sustainable Finance: European Supervisory Authorities provide updated guidance on the application of the Sustainable Finance Disclosure Regulation

Sustainable Finance | Case Study | EisnerAmper Ireland

The Sustainable Finance Disclosure Regulation (SFDR) applies to financial institutions including banks, insurers, asset managers and investment firms operating within the EU and requires these institutions to assess and publicly disclose certain information relating to environmental, social and governance matters.

SFDR aims to increase transparency on how financial market participants integrate sustainability into their investment decisions and recommendations. It introduces a classification system with new disclosure requirements for investment products. It focuses on investor protection and is designed to make it easier for investors to distinguish and compare products by classifying funds into three distinct categories according to the degree to which sustainability is a consideration.

The three European Supervisory Authorities (comprising the European Banking Authority (EBA), the European Insurance and Occupational Pension Authority (EIOPA) and the European Securities and Market Authority (ESMA)), recently updated their joint supervisory statement on the application of SFDR. This update includes a new timeline for the publication of the Regulatory Technical Standards (RTS) (delayed to 1 January 2023) and directs regulators and in scope financial institutions to use the current draft technical standards by way of guidance in order to comply with SFDR while recognising that the draft RTS may be subject to change.

The EU Taxonomy Regulation provides a classification system that helps financial institutions to identify sustainable economic activities and is connected to, and will support, disclosure requirements under SFDR. A useful summary of SFDR and the Taxonomy Regulation disclosure obligations is included in the updated Joint Supervisory Statement by the European Supervisory Authorities.

How EisnerAmper Ireland can help

As Partner in EisnerAmper’s Governance, Risk & Compliance Group, Carina Myles advises financial service providers on risk, regulatory and compliance-related matters. EisnerAmper’s specialist services include:  

  • Supporting organisations through regulatory change;    
  • Provision of bespoke board support and training;   
  • Designing and developing integrated risk and compliance frameworks;   
  • Preparing compliance briefings for discussion with the board; and    
  • Supporting the board in responding to and implementing any changes required relating to evolving needs.   

If we can help you or your business in any way, please do get in touch – we’d be delighted to help. 

Contact Us

Learn more about our ESG Services here.

Authors

The content above is provided for general information purposes only and is not intended to provide, nor does it constitute, professional advice on any particular matter. If you would like more information or would like to discuss any of the topics raised above, please contact the author(s).

ESG Insights
23.11.2021

Dear Chair Letter – 3rd November

Dear Chair Letter – 3rd November | ESG Insights | EisnerAmper Ireland | Financial Services

On 3 November 2021, the Central Bank of Ireland (“CBI”) issued a letter to Chairs and CEOs of Regulated Financial Service Providers (“RFSPs”) on climate and ESG issues.

The letter highlights the statutory obligations of RFSPs and related supervisory expectations relating to climate and sustainability issues.

The letter notes that climate change should be seen as a strategic priority, emphasising the need for RFSPs to lead and drive ESG agendas within their organisations.

Firms should be able to establish demonstrable plans within the following five key areas:

  1. Governance: Boards need to take ownership of climate risks affecting the firm and promote a culture that places emphasis on ESG issues.
  2. Risk Management Framework: Firms need to enhance their existing risk management frameworks to ensure robust climate risk identification, measurement, monitoring and mitigation.
  3. Scenario Analysis: Firms need to perform scenario analysis and stress testing to assess the impact of potential future climate outcomes.
  4. Strategy and business model risk: Firms are expected to undertake business model analysis to determine the impacts of climate risks and opportunities on the firm’s overall risk profile, business strategy, and to inform strategic planning.
  5. Disclosures: Firms should adopt practices which ensure transparent disclosure of ESG issues to consumers and investors, without engaging in the practice of ‘greenwashing’.

These expectations can be applied by RFSPs in a proportionate manner, aligned to the nature, scale and complexity of the organisation. While the letter recognises that the expectations are not prescriptive or binding, the CBI will keep a keen focus on the development of sustainable finance and individual organisations’ roles in achieving this.

How EisnerAmper Ireland can help

Our initial feedback from talking to our clients is that this letter has been well received. Notwithstanding that for many sectors, exact ESG requirements are still to be determined, this letter provides a helpful roadmap summarising the key areas where demonstrable plans should be in place. These expectations also help affirm and shape the roadmap for climate change and sustainability plans that we are assisting our clients with.

Our multidisciplinary team is on hand to help you chart your ESG journey. We help organisations navigate the ESG landscape and understand the applicable legislation and frameworks.

Contact Us

Learn more about our ESG Services here.

Link to the Dear CEO Letter here.

Authors

The content above is provided for general information purposes only and is not intended to provide, nor does it constitute, professional advice on any particular matter. If you would like more information or would like to discuss any of the topics raised above, please contact the author(s).

ESG Insights
29.9.2021

Gender Pay Gap

Gender Pay Gap | Case Study | Financial Services | EisnerAmper Ireland

Gender Pay Gap Information Act 2021

In July 2021, the Gender Pay Gap Information Act (the “Act”) was signed into law. The Act amends the Employment Equality Act 1998 and sets out how certain organisations should report on gender pay gap differentials between female and male employees.

The Act requires that the Minister for Children, Equality, Disability, Integration and Youth make regulations on how certain gender pay gap metrics are to be calculated.

What is the Gender Pay Gap?

The gender pay gap is the difference in remuneration of men and women across a workforce. It compares the pay of all working men and women; not just those in similar jobs, with similar working pattern or with similar competencies, qualifications or experience.

In Ireland, the gender pay gap is c. 11.3% – slightly lower than the EU average of 14.1% (https://ec.europa.eu/eurostat/statistics-explained/index.php?title=Gender_pay_gap_statistics).

Requirements set out by the Act

Initially, the Act will apply to employers with 250 or more employees.

On or after the second anniversary of the regulations, employers with between 150 and 250 employees will be covered by the Act. Finally, on or after the third anniversary of the regulations, employers with between 50 and 150 employees will be covered.

All public sector bodies, (e.g.: Government Departments, Scheduled Offices, An Garda Síochána, the Defence Forces and schools) are included.

The information to be published by employers, as set out in the Act, is as follows:

  1. The mean and median gap in hourly pay between men and women;
  2. The mean and median gap in bonus pay between men and women;
  3. The mean and median gap in hourly pay of part-time male and female employees;
  4. The percentage of men and of women who received bonus pay; and
  5. The percentage of men and of women who received benefits in kind.

The Act also requires employers to provide explanations for any gender pay gaps and the measures (if any) that are being taken to eliminate or reduce the gender pay gap.

Ensure Gender Pay Gap Compliance

It is recommended that organisations start performing Gender Pay Gap calculations now. Organisations that understand their Gender Pay Gap metrics can make positive steps to be in a better position when reporting and publishing requirements become mandatory.

External Links:

The Bill: https://data.oireachtas.ie/ie/oireachtas/act/2021/20/eng/enacted/a2021.pdf.

How EisnerAmper Ireland can help

At EisnerAmper Ireland, our dedicated team of outsourced payroll and advisory professionals possess the tools and the expertise to analyse your payroll data and produce detailed reports highlighting the current gender pay gap in your organisation.

Contact Us

Learn more about our ESG Services here.

Authors

The content above is provided for general information purposes only and is not intended to provide, nor does it constitute, professional advice on any particular matter. If you would like more information or would like to discuss any of the topics raised above, please contact the author(s).

ESG Insights
23.8.2021

Case Study – Sustainable Finance Disclosure Regulation (SFDR)

Case Study | Sustainable Finance Disclosure Regulation (SFDR) | EisnerAmper Ireland | Financial Services

EisnerAmper Ireland (EAI) assisted an Investment Management client who provided both Portfolio Management and Investment Advisory services. The Company is a subsidiary of a large financial services group headquartered in Germany.

The Company was required to draft disclosures based on the Sustainable Finance Disclosure Regulation (SFDR) requirements. The SFDR imposes mandatory ESG disclosure obligations for asset managers and other financial markets participants.

Tom Brennan, Head of Risk & Regulatory at EisnerAmper, examined the arrangements in place at the time for the Company’s investment decision making process. EisnerAmper worked with other members of the group and the parent company to ensure that policies and procedures in place were consistent throughout and that they reflected socially responsible practices.

The Company signed up to the UN Principles for Responsible Investment (UNPRI), an international organisation that works to promote the incorporation of environmental, social, and corporate governance factors (ESG) into investment decision-making

The Company also signed the United Nations Principles for Sustainable Insurance (PSI), further embedding ESG in its insurance business.

EisnerAmper helped to draft the Company’s SFDR disclosure policy, ensuring they:

  • published information on their strategies for integrating sustainability risks in their investment decision-making processes and investment advisory activities on their websites; and
  • made statements on due diligence strategies related to the main adverse sustainability impacts of investment decisions on sustainability factors.

Through this process and from working closely with Tom and his team, the Company completed a robust process to gather the required information to make the disclosures required under SFDR. In examining their business practices and holding them against the SFDR requirements, they were able to form a roadmap to where the Company needs to be in the future and how to assess investments for ESG compliance.

How EisnerAmper Ireland can help

Our multidisciplinary team is on hand to help you chart your ESG journey. We help you navigate the ESG landscape and understand the applicable legislation and frameworks. We also help drive change within your organisation so that sustainability becomes embedded within your strategy, operations and reporting.  

Our ESG services typically include: 

  • Developing and documenting a roadmap to achieve demonstrable ESG compliance; 
  • Provision of assurance over ESG information included in annual reports or other published documents;  
  • Undertaking gap analysis of ESG disclosures;  
  • Designing and delivering Board training on ESG topics, standards and requirements; and  
  • Provision of tools to assist you in demonstrating compliance with ESG requirements. 

Learn more about our ESG Services here.

 

Authors

The content above is provided for general information purposes only and is not intended to provide, nor does it constitute, professional advice on any particular matter. If you would like more information or would like to discuss any of the topics raised above, please contact the author(s).

ESG Insights