Good Work Plan: transparency consultation

Below is Mumsnet's response to the transparency portion of the Good Work Plan consultation

What is the Good Work Plan?

The Good Work Plan was introduced by the government and consults on legislation to make working practices better in the UK.

Our responses throughout are based on Mumsnet users' responses to a survey we ran using the consultation questions. Over 700 Mumsnet users took part in this survey over the past few weeks.

Mumsnet's Publish Parental Leave campaign

Mumsnet has been running a Publish Parental Leave campaign since earlier this year, encouraging employers to commit to publishing details of their family leave and pay policies so that job-seekers can take informed decisions.

Mumsnet users unequivocally back this campaign. In a survey of over 1000 Mumsnet users conducted in February 2019, 91% supported the campaign aims. 84% of respondents said employers’ parental leave policies are very or somewhat important for them when applying for or considering applying for a job, but 82% say they are reluctant to ask about these policies for fear it will make a job offer less likely.

Parental leave and pay policies aren’t perks or on par with things like gym memberships. They’re absolutely critical pieces of information that allow people to plan their futures. Yet two-thirds say they’ve avoided asking about parental leave policies at the interview stage for fear it would give a negative impression, and the same number say that at least once they’ve found it difficult or impossible to find information on an employer's policy when applying for a job.

We, and our users, strongly believe that publishing family leave policies is a small, cost-free change that could have a powerful impact. It will help to address the gender pay gap by tackling a working culture that penalises mothers and it could also persuade more fathers to consider extended periods of leave. As we've seen with gender pay gap reporting, it could encourage a race to the top and will put power back where it belongs – in the hands of job-seekers.

Our response

Section 1: Publishing family-related leave, pay and flexible working policies

If a requirement to publish family-related leave, pay and flexible working policies was introduced, large organisations might be required to provide a link to the relevant policies on their website. As the purpose of the requirement is to achieve greater transparency, we believe that this should be the case whether their offer exceeded the statutory minima or not. Where the offer does not exceed the statutory, a simple statement should suffice.

Question 1

Do you agree that large employers (250+ employees) should publish their family-related leave and pay policies on their website? Strongly agree

Please provide reasons for your answer.
We at Mumsnet have been running a campaign to encourage employers to publish their parental leave policies. As part of that we surveyed more than 700 Mumsnet users using the Good Work transparency consultation questions. 91% of them agree that ‘large employers (250+ employees) should publish their family-related leave and pay policies on their website’; just 3% disagree. In a survey we conducted in February 2019, 84% of respondents said employers’ parental leave policies are important for them when applying for or considering applying for a job, but 82% say they are reluctant to ask about these policies for fear it will make a job offer less likely.

Question 2

Do you agree that large employers (250+ employees) should publish their flexible working policies on their website? Strongly agree

Please provide reasons for your answer.
In our survey of 700+ Mumsnet users using the Good Work transparency consultation questions, 93% of respondents agree that ‘large employers (250+ employees) should publish their flexible working policies on their website’; just 3% disagreed. (See comments for Question 3.)

Question 3

Do you agree that transparency of these policies will help employers to recruit and
retain staff?
Strongly agree

Please provide reasons for your answer.
In our Good Work transparency consultation survey of 700+ Mumsnet users, 92% agree that ‘transparency of these policies will help employers to recruit and retain staff’; just 1% disagree. 84% of Mumsnet users tell us that having children has made it harder for them to progress in their career and 76% feel less employable since having a child. 71% rate flexible hours as something mothers look for in a job when returning to work. There is no doubt that flexibility is a huge factor in encouraging women to return to work after having children. As such, addressing the gender pay gap (which is largely a motherhood gap) and helping employers to capitalise on the skills and experience of an under-utilised group will be of huge benefit to both employee and employer.

Question 4

Do you agree that, where the employer has a policy on family-related leave and pay which extends the statutory minima, reworking and publishing your internal policy document on a public-facing website would not be a significant or expensive task? Strongly agree

Please provide reasons for your answer.
81% of our users agreed with this proposition. As part of our Publish Parental Leave campaign, Mumsnet has recently undertaken an exercise in which we looked at the publicly available HR policies of FTSE 350 companies. Almost all of them already publish some of their policies in order to attract applicants, but very few (less than 10%) publish their parental leave policies. Publishing existing family leave and pay policies on a web page should be the work of a moment, given that almost all companies already publish some of their other employee benefit policies. Writing, publishing and hosting a web page has minimal cost implications.

Question 5

Do you agree that, as for family-related leave and pay, reworking and publishing your flexible working policy on a public-facing website would be simple and inexpensive? Strongly agree

Please provide reasons for your answer.
82% agree with this proposition. Please see comments for Question 4.

Question 6

How helpful would the following information be if it was held (and viewable) on a central database – for instance the Gender Pay Gap Reporting Portal?

consultation table

Please provide reasons for your answer.
When asked whether it would be helpful if information was held (and viewable) on a central database, 94% agreed it would be helpful in the case of ‘whether flexible working may be available from the start’; 95% agree it would be helpful in the case of ‘approach to place, hours and times of work’; 94% agree it would be helpful in the case of ‘approach to informal flexible working’; and 95% agree it would be helpful in the case of ‘enhancements to different types of family-related leave and pay’.

Question 7

To what extent do you believe that a job applicant’s decision on whether to apply for a job depend on the publication of the information mentioned above? Somewhat; A lot

Please provide reasons for your answer.
In our survey, 52% of respondents chose ‘somewhat’ while 44% chose ‘a lot’. Just 4% chose ‘not at all’.

Section 2: A requirement to report or a voluntary approach?

There are already a number of mandatory reporting regimes in place, including gender pay gap reporting (mandatory for all large businesses, ie those with 250+ employees). These provide incentives on businesses to take action to improve their performance, so we are mindful of introducing additional regulation without testing a voluntary approach in the first instance – particularly given the impact the reporting requirement alone appears to be having in raising the profile of these issues.

However, the potential for change to be driven by greater transparency around existing policies should also be weighed against the potential stimulus for change which an action plan might provide. Around 50% of large employers already voluntarily supplement their gender pay gap information with a narrative or an action plan, which sets out the steps they are taking to narrow the gap. It may be that a dynamic action plan is a more effective way of driving cultural change also on this issue.

Question 8

How effective do you believe a voluntary approach to encourage greater transparency about an organisation’s approach to flexible working and family-related leave and pay (eg through the Gender Pay Gap Reporting Portal) might be in providing information about employers’ policies? Very effective; Fairly effective

Please provide reasons for your answer.
59% of survey respondents agreed this approach would be ‘very’ or ‘fairly effective’. In the course of our research among FTSE 350 companies for our Publish Parental Leave campaign, we've found that many of the companies we've written to to ask them to publish have agreed very quickly that it’s an easy and low-cost action to take with many upsides and no downsides. Our experience has been that companies are happy to consider this and don’t mention any serious objections. However, the fact that many companies don't do this already suggests that a voluntary approach may be limited in its effectiveness.

Question 9

How effective do you believe creating a facility on the Gender Pay Gap Reporting Portal on GOV.UK to record details about an organisation’s policies on flexible working and family related leave and pay would be?

table

Please provide reasons for your answer.
Survey respondents thought creating a facility on the Gender Pay Gap Portal would be net 85% effective (42% ‘very effective’ and 44% ‘fairly effective) in the case of providing a central point of information for employees or prospective employees, and net 82% effective (39% ‘very effective’ and 43% ‘fairly effective’) in the case of letting employers record the information as a part of the annual Gender Pay Gap Reporting cycle.

From our research among FTSE 350 companies, the fact that there isn’t one standardised place for employers to record this information means that even when employers have published it, finding it requires a certain amount of dedication and determination.

When looking for evidence of FTSE companies publishing their parental leave policies, for each organisation we searched five distinct search phrases in Google (the same five search terms within the employer’s own website) and read through their ‘About Us’ and ‘Work For Us/Careers’ sections. This was the only way we could be fairly sure we had given ourselves a good chance of finding the information if it existed. Hosting the information in a one-stop-shop would make things far easier for job-seekers.

Question 10

How effective do you believe it might be to encourage employers to set out how they are using greater transparency about their employment policies as part of their gender pay gap action plans? Fairly effective

Please provide reasons for your answer.
Survey respondents thought it would be net 76% effective (35% ‘very effective’ and 41% ‘fairly effective’).

Question 11

Do you agree that it would make sense to enforce a reporting requirement of this kind in the same way as gender pay gap reporting (ie a requirement to provide this information as part of the gender pay gap reporting process)? Strongly agree

Please provide reasons for your answer.
83% of respondents agreed with this proposition, with 47% saying they ‘strongly agree’ and 36% saying they ‘agree’. In speaking to FTSE companies as part of our Publish Parental Leave campaign, we have not heard objections to the idea of mandatory reporting. As outlined in the comments to Question 9, even when employers do publish, the information is not always easy to find. A statutory requirement would overturn these hurdles and place this information in the hands of job-seekers.

Section 3: A requirement to say whether jobs may be open to flexible working in an advert

If employers were to be required to say in a job advert whether flexible working was available, there would be a need to strike a balance between what information it was practical to provide, and what a candidate would find helpful.

Question 12

Thinking about the balance between what it is practical to provide in a short job advert and what is useful to a candidate, which of the following is the best option (please select one)?

table consultation

Please provide reasons for your answer.
Among our respondents, the biggest group (39%) chose ‘a simple statement and a link to a published policy’. 28% chose ‘a short statement covering the organisation’s approach to place, hours and times of work and a link to a published policy’ – so in total, 67% are in favour of a short-ish statement and a link to a policy.

Question 13

If a requirement was introduced to state in job adverts whether flexible working may be available or not:
A. Who might the enforcement power sit with? Please describe. No comment
B. What should be the process for reporting a breach? Please describe. No comment
C. What should be the penalty for a breach? Please describe. No comment

Question 14

If a requirement to provide a link to your flexible working policy on the gender pay gap reporting portal was introduced, do you agree that it would be helpful to also ask employers to record whether they had advertised jobs as open to flexible working? Strongly agree

Please provide reasons for your answer.
82% of our survey respondents agreed, 42% strongly agreed.

END

[October 2019]