Workplace Gender
Equality Reporting
Summary of Consultations
December 2014
Page 1 of 21
Contents
Introduction
3
Overview of reporting requirements
4
SUMMARY OF ONLINE SURVEY RESULTS
5
Cost to employers
5
Easiest and most difficult sections of the report
6
Additional reporting requirements (Schedule 2 requirements)
6
General comments
7
SUMMARY OF SUBMISSIONS
7
Feedback from employers reporting during the 2013–14 reporting period
(reporting organisations)
8
Feedback from employer representatives
11
Feedback from gender equality advocates
14
SUMMARY OF EMPLOYER MEETINGS
16
Time required to report
16
Manager categories
16
Non-manager categories
17
Employment status
17
Reporting level from the Chief Executive Officer
17
Remuneration
17
Reporting questionnaire
18
Additional reporting requirements (Schedule 2 requirements)
18
General comments
18
STAKEHOLDER CONSULTATION SESSIONS
19
ATTACHMENT A: List of organisations that have made public submissions (excludes anonymous
submissions)
20
ATTACHMENT B: Guiding questions for submissions
21
Page 2 of 21
Introduction
On 25 March 2014, Senator the Hon. Eric Abetz, Minister for Employment and Senator
the Hon. Michaelia Cash, Minister Assisting the Prime Minister for Women, announced a public
consultation process on reporting requirements established under the Workplace Gender Equality
Act 2012 (the Act).
Since May 2014, the Department of Employment has led the consultation process, in consultation
with the Office for Women within the Department of the Prime Minister and Cabinet.
Evidence gathering has occurred through the feedback received from an online survey, submissions,
employer meetings, emails to the Department, letters to the Minister, as well as feedback from
employer representatives and gender equality advocates. The Department also consulted with the
Australian Bureau of Statistics, the Australian Taxation Office, the Fair Work Commission and the
Workplace Gender Equality Agency (the Agency).
The Department wrote to stakeholders (including reporting organisations, employer representatives
and gender equality advocates) with information on the consultation process, how they could be
involved (including information on the web page) and what information was being sought.
Links to the webpage were provided on the Business.gov.au, the Office for Women page on the
Department of Prime Minister and Cabinet website, and the Agency website. A shortcut link was also
used in media releases and other advice on the consultation process.
Forty-two submissions were received, of which 28 are public (including three anonymous
submissions). Five hundred and twenty-three valid survey responses were received, and the
Department met with 18 employers to seek their views on the current reporting regime and options
for improvement. The Agency also attended many of these meetings. Separate stakeholder
consultation sessions were held in September 2014 with employer representatives and gender
equality advocates to discuss the evidence collected to date and potential options for change. In
addition, interested parties had the option to provide feedback to the Department via a public inbox.
Eleven emails were received by the Department and feedback was consistent with that provided
through the online survey and submissions.
Page 3 of 21
Overview of reporting requirements
The Act requires non-public sector organisations with 100 or more employees to report to the
Agency on their workplace gender equality performance. Reporting requirements are further
detailed in the Workplace Gender Equality (Matters in relation to Gender Equality Indicators)
Instrument 2013 (No. 1).
Under current reporting arrangements, employers are required to report on an annual basis. As part
of this, employers are required to report on the workplace profile of their organisation, including
information on the number of employees by:





gender
occupational categories for managers and non-managers
employment status (full-time, part-time, permanent, contract, casual)
reporting level from the Chief Executive Officer (for managers only)
base salary and total remuneration data by employment status, manager and non-manager
occupational categories.
In addition, employers are required to provide information, mostly in the form of answers to
questions, on each of the Gender Equality Indicators (GEIs):






GEI 1: gender composition of the workforce
GEI 2: gender composition of governing bodies of relevant employers
GEI 3: equal remuneration between women and men
GEI 4: availability and utility of employment terms, conditions and practices relating to
flexible working arrangements for employees and to working arrangements supporting
employees with family or caring responsibilities
GEI 5: consultation with employees on issues concerning gender equality in the workplace
GEI 6: any other matters specified in a legislative instrument. The legislative instrument sets
out sex-based harassment and discrimination as a further indicator.
From 1 April 2015, additional reporting requirements will be introduced which include providing
further information on:



annualised components of total remuneration by employment status, manager and
non-manager categories and gender
applications received, interviews conducted, appointments made, promotions awarded and
resignations that occurred by gender and manager/non-manager, and full-time/part-time
for promotions and resignations
return to work from, and extensions requested and approvals granted for, parental leave by
gender and manager and non-manager categories.
Page 4 of 21
SUMMARY OF ONLINE SURVEY RESULTS
A short survey was available for organisations that did not have the capacity to make a full
submission. The survey was open between 15 May and 31 July 2014. Five hundred and twenty-three
valid responses were received. Employers with 101–300 employees made up 39 per cent
(the highest proportion) of survey respondents.
Figure 1: Survey respondents by number of employees
Cost to employers
Reporting organisations provided a wide range of cost estimates, from less than $100 to as high as
$140,000. The median cost of reporting was estimated to be $1500.
Figure 2: Cost of reporting to employers ($)
Page 5 of 21
Easiest and most difficult sections of the report
In the survey, employers were asked to identify the reporting requirements that were the hardest
and the easiest to complete. Employers identified total remuneration (75 per cent of respondents to
the question), manager occupational categories (69 per cent of respondents to the question) and
non-manager occupational categories (68 per cent of respondents to the question) as the hardest
questions to answer. Each of these reporting elements are found in the Workplace Profile.
Common themes that made these questions difficult to complete included:



the manual process of classifying the entire workforce into categories
definitions that were not clear or subjective
complex reporting lines, and that the report was not tailored to suit organisations with
multiple business units.
Employers responded that it was easy to answer questions relating to flexible working arrangements
(70 per cent of respondents to the question), gender composition of the workforce (69 per cent of
respondents to the question) and paid parental leave for primary and secondary carers (64 per cent
of respondents to the question).
Employers found these questions easy because the answers were in a simple, multiple-choice
format, the data were easily accessible, the questions were straightforward and easy to understand,
and they aligned with the National Employment Standards (flexible working arrangements).
Additional reporting requirements (Schedule 2 requirements)
Seventy-eight per cent of employers that responded to the question reported that they were
unhappy with some part of the additional reporting requirements and more than half (54 per cent)
indicated it would be difficult or very difficult to report on the additional Schedule 2 reporting
requirements.
Figure 3: Additional reporting requirements (Schedule 2)
Page 6 of 21
General comments
Respondents were able to provide general feedback about the reporting requirements.
Two hundred and seven respondents provided comments, with 79 per cent of those that responded
unsatisfied with some part of the gender reporting requirements, 19 per cent providing general
feedback and 5 per cent providing positive feedback. Common themes included:




reiterating that the experience was time consuming (24 per cent)
difficulties in consolidating one report across multiple business sites with different
occupational categories, remuneration arrangements and organisational sizes (21 per cent)
problems with acquiring and using an AUSkey (13 per cent)
difficulties with the Agency website and reporting system (13 per cent).
SUMMARY OF SUBMISSIONS
Submissions were accepted from 15 May 2014 to 30 September 2014. Forty-two submissions were
received, of which 28 are public (including three anonymous) and 14 are private.1 Submissions were
received from employers, employer representatives and gender equality advocates. A list of
organisations that agreed for their submissions to be public is at Attachment A.




The feedback from employers and employer representatives is consistent with the survey
results. Most submissions from employers and employer representatives supported
workplace gender equality principles, but felt that the current reporting burden is too high.
The most frequently reported concerns raised relate to difficulties in extracting annualised,
Full-Time Equivalent (FTE) remuneration data; reporting against the manager and
non-manager categories; technical problems relating to the AUSkey or online reporting and
the additional impost of Schedule 2 requirements.
Submissions from the gender equality advocates support the retention of most of the
reporting requirements. Some conceded that a small reduction could be made, while others
requested additional reporting requirements.
A small number of submissions commented on the workplace gender equality minimum
standard and procurement compliance measures; these issues however are out of scope of
the current review.
1
Public and anonymous submissions can be accessed on the Department of Employment’s website at:
https://submissions.employment.gov.au/empforms/WGRPC/pages/index?c=1
Page 7 of 21
Feedback from employers reporting during the 2013–14 reporting period
(reporting organisations)
Three reporting organisations have agreed to make their submissions public, three provided
anonymous submission and 13 provided private submissions.
General comments
Most submissions from employers stated broad support for the principle of workplace gender
equality. Most employers also expressed a concern about the time and resources required to
complete the report, and several questioned the value of the reporting process for the organisation.
Collecting and providing data for reporting purposes
Just over half of the employer submissions indicated that the new online system was an
improvement on the previous reporting system.
Most organisations experienced some difficulty in collecting the data for reporting purposes. Many
organisations indicated that their HR and payroll systems were not set up to facilitate this type of
reporting, and they had difficulty aligning their data into the format required. Large organisations
indicated that data needed to be sourced from multiple HR or payroll systems, which often had to be
manually compiled. Three organisations provided positive feedback about collecting data either
because they found the questions easy to understand or because they thought the online system
had made the process simpler.
Many organisations reported that they had difficulty obtaining and using an AUSkey. AUSkey is a
secure login for businesses accessing online government services that is managed by the Australian
Taxation Office and is used widely across government.
Time and cost to report
Reporting organisations indicated how long it took the organisation to complete the report.
Responses ranged from under one week to eight weeks. Some employers also provided a cost
estimate for reporting based on the hours of staff time used to complete the report, with the cost
ranging from $2000 to just above $30,000.
Industry classifications
Under current reporting requirements, reporting organisations are asked to indicate which industry
they operate within according to the Australian and New Zealand Standard Industrial Classification
(ANZSIC). Some reporting organisations operate across multiple industries (e.g. mining,
manufacturing)
In this case, organisations are required to submit at least one report per ANZSIC division (i.e. one
report that captures data on all the entities within the corporate structure that operate within the
mining division, and one report that captures data on all the entities within the corporate structure
that operate within the manufacturing division).
Page 8 of 21
Some employers that operate across multiple ANZSIC divisions found this process difficult. One
suggestion was to create a classification, such as ‘multi-sector holdings’, that would capture these
organisations and allow them to complete a single report.
Manager categories
Under current reporting requirements, employers must classify and report on managers against five
standardised occupational categories (Chief Executive Officer, key management personnel, other
executives/general managers, senior managers and other managers).
Reporting organisations’ submissions provided mixed views on the manager categories, with some
organisations finding the categories relatively straightforward and others indicating that they did not
neatly align with existing management structures. Those employers that found manager categories
to be difficult also reported that the process was time consuming and involved manual manipulation
of the data. Some submissions acknowledged that reporting would be simpler after the first year.
Non-manager categories
Under current reporting requirements, employers must classify non-managers against eight
occupational categories. These categories are based on the top-level categories in the Australian and
New Zealand Standard Classification of Occupations (ANZSCO), a classification tool that is used by
the Australian Bureau of Statistics and across government. In addition, employers must report on
graduates and apprentices.
In their submissions, most reporting organisations experienced some difficulty matching their
employees into non-manager categories. The most common reasons for finding these categories
difficult were the effort required to manually classify employees into the categories and the time
taken to agree internally on how employees should be classified. Employers also raised the concern
that inconsistency in classifications across organisations could make benchmark comparisons
unreliable.
Employment status
In completing the workplace profile, reporting organisations are required to report on employment
status (full-time permanent, full-time contract, part-time permanent, part-time contract or casual)
by gender. Most submissions from employers indicated that reporting on employment status was
relatively straightforward as this information is generally maintained within an organisation’s HR
systems.
Some submissions raised concern about the inclusion of independent contractors (contracted for
services) in workplace profile reporting. Some employers felt that the contractors’ employing entity
(and not the organisation contracting them for services) should be responsible for reporting on
independent contractors and, in particular, providing their remuneration data.
Page 9 of 21
Reporting level from the Chief Executive Officer
Under current reporting arrangements, reporting organisations are required to report on the
reporting level from the CEO (up to 15 levels removed). Reporting organisations’ submissions
provided mixed views on the reporting level from the CEO. Some organisations found it a
straightforward exercise, while others—most notably those with less hierarchical organisational
structures—found the process difficult and felt that the results could be misleading.
Remuneration
Several employers indicated that they had difficulty reporting on remuneration. Employers seemed
to find reporting on total remuneration more difficult than reporting on base salary. Employers
provided the following reasons for why reporting on remuneration was difficult:





remuneration definitions were unclear or difficult to understand
data had to be sourced from multiple payroll systems
calculating the different components that went into total remuneration (e.g. allowances and
overtime) was difficult
part-time and casual wages were difficult to annualise and translate into full-time equivalent
pay and may produce misleading data
the data had to be manually entered into the Agency’s online reporting system.
Reporting questionnaire
Relatively few reporting organisations provided feedback on the reporting questionnaire in their
submissions.
The questionnaire requires organisations to indicate whether they have policies or strategies in
place that address particular workplace gender equality issues. Two organisations that compiled a
single report on behalf of multiple entities within their corporate structure found this aspect of the
questionnaire inflexible. For example, if six entities had a policy or strategy in place and two did not,
the questionnaire format required the organisation to answer ‘no’ to that particular question. These
organisations felt that a ‘no’ answer did not reflect the reality of their organisation as a whole.
Two organisations indicated that the Reference Guide was critical in supporting them to answer the
questionnaire, they also indicated however that some sections of the guide were more detailed than
others and further information in the guide would be useful.
Additional reporting requirements (Schedule 2 requirements)
Just over half of the employer submissions indicated that there would be difficulty in meeting the
additional reporting requirements, due to be implemented from 1 April 2015. Several employers
indicated that they already collect some of the data for the additional requirements, but indicated
that it would still require some effort to extract the data and manipulate it to fit the reporting
format. Several employers expressed concern about reporting on components of total remuneration
and the number of job applications by gender.
Page 10 of 21
Benchmark reports
Reporting organisations’ submissions provided mixed views on the value of benchmark reports.
Some organisations were looking forward to receiving the reports and felt that any benchmarking
information that could be provided would be useful. Other organisations did not see how the
benchmark reports would be of value. Organisations indicated it would be useful if benchmark
reports:





included the percentage difference in remuneration between women and men at each
occupational level
included the percentage of women at each occupational level
included the gender pay differential at each occupational level
allowed for comparison between organisations of the same or similar size and comparison
between organisations in the same industry.
provided an insight into industry standards, practices, policies and strategies that other
organisations are using to improve workplace gender equality.
Feedback from employer representatives
Fifteen employer representatives agreed to make their submissions public and one private
submission was received.
General comments
Most submissions from employer representatives stated broad support for the objectives of the
Workplace Gender Equality Act 2012. Despite this, all employer representatives indicated that the
current requirement placed a high compliance and regulatory burden on employers. A high
proportion of these submissions questioned whether the current reporting framework would
improve workplace gender equality outcomes and whether outcomes achieved through this process
would balance the cost of reporting. Several employer representatives recommended that the focus
shift from reporting and compliance to policies and initiatives that encourage cultural change within
organisations.
Collecting and providing data for reporting purposes.
Several employer representatives indicated that their members struggled to collect data for
reporting purposes as they lacked sophisticated human resources information systems. Several
employer representatives also stated that their members had to manually collate and manipulate
the data in order to present it in the format required. Two employer representatives indicated that
members found inputting data into the online system was relatively easy. Some technical difficulties
were experienced including issues with the AUSkey system, error messages for minor formatting
issues and repeated attempts to submit online forms.
Time and cost to report
Most employer representatives did not provide an estimate of the cost of reporting. All submissions
from employer representatives did, however, comment that meeting reporting requirements was a
time-consuming and costly exercise for their members.
Page 11 of 21
Manager and non-manager categories
Three submissions from employer representatives commented on manager categories. One
submission recommended that management categories be simplified to better reflect the diversity
of management structures in place. Two further submissions indicated that classifying employees
into management categories was difficult for their members.
Three submissions from employer representatives directly commented on non-manager categories,
with each reporting that this process was difficult for their members as they do not neatly align with
the job titles used internally by reporting organisations.
Reporting level from the Chief Executive Officer
Four employer representative submissions indicated that members had found the reporting level
from the CEO to be difficult. One employer representative indicated that its member organisations
had trouble allocating levels from CEO as its industry featured highly decentralised workplaces and
levels from CEO did not necessarily reflect an employee’s influence within an organisation.
Remuneration
Several employer representatives indicated that their members had difficulty reporting on
remuneration. Employer representatives provided the following comments on remuneration
reporting requirements:




The definition of annualised full-time equivalent total remuneration should be simplified and
clarified. Inclusion of benefits other than cash is particularly problematic. One submission
suggested that the definition be aligned with Australian Bureau of Statistics definitions for
total remuneration.
The reporting burden would be reduced if remuneration data were required only for
manager categories, and if either base salary or total remuneration data were reported on,
rather than both.
Employers should have the option to report separately on employees that are covered by an
Award or Enterprise Agreement and should not be required to report on their salaries.
Remuneration requirements should be replaced with a requirement to identify whether an
organisation has embedded gender equality principles into its remuneration policies and
strategies.
Several employer representatives indicated that their members had concerns about providing
remuneration data for CEOs and senior executives as they felt this was confidential and
commercially sensitive information. One employer representative expressed a concern that the
Agency would use remuneration data to set new industry standards or benchmarks.
Page 12 of 21
Reporting questionnaire
Relatively few employer representatives made comments on the reporting questionnaire. Where
comments were received, these related to the overall tone of the questions being asked and the
‘tick box’ options provided. Some employer representatives felt that the tone of the questionnaire
and tick box questions were too negative and should be reframed in a more positive light. Two
employer representatives commented that the tick box options were too structured and did not
provide employers with an appropriate range of responses. One employer representative suggested
that free-text options be made available so that employers could voluntarily provide explanatory
information in addition to a yes/no response.
Additional reporting requirements (Schedule 2 requirements)
Almost all employer representatives recommended that Schedule 2 requirements be removed and
expressed concern that these requirements would impose an additional compliance burden on
reporting organisations. The requirement to report on recruitment information—and, in particular,
applications—was of particular concern. Reasons given included the large number of unsolicited
applications received by employers, the inability to determine gender from applications, and
limitations in employers’ IT systems that made them unlikely to cope with the type and amount of
data being required.
Benchmark reports
Employer representatives provided mixed views on the value of benchmark reports, with some
indicating that they would provide important feedback to employers and others expressing
significant concern as to the value and purpose of the reports. Some employer representatives
commented that the new reporting format takes a ‘one size fits all’ approach and, as such, the
resulting benchmark reports would not provide a useful comparison of organisations within
industries. One employer representative was particularly concerned that the reports would be used
to set new benchmarks or standards across industries and lead to an additional layer of regulation.
Other comments
A number of additional issues or recommendations were raised in employer submissions, including
the suggestion to:






remove the requirement for the CEO to sign the final report
remove or relax access and notification requirements, so that employers are no longer
formally required to notify employees and employee representatives when a report has
been lodged
add a free-text option to the Workplace Profile so that employers can provide explanatory
information about how they have completed the report
introduce system enhancements enabling users to format in free-text boxes (i.e. bold, italics,
hyperlinks, paragraphs), introduce clear and user-friendly messages on various screens, clear
warning messages, clear error messages and tool tips
better tailor reporting to meet the needs of specific industries and sectors
clarify the definition of ‘relevant employer’ and provide a definition of ‘employee’
Page 13 of 21



relax new criteria for Employer of Choice awards, so that the application process is less
prescriptive and does not dictate what best practice in workplace gender equality should be
identify which questions in the questionnaire are compulsory for qualifying to apply for an
Employer of Choice award
reduce frequency of reporting.
Feedback from gender equality advocates
The Department received seven public submissions from gender equality advocates.
General comments
Submissions from the gender equality advocates highlighted the benefits of reporting on workplace
gender equality. Most of these submissions emphasised the economic gains associated with
increased female workforce participation and the need to address the ongoing gender pay gap in
Australia.
Four submissions strongly supported the existing reporting regime, yet acknowledged that there was
an opportunity to fine-tune, or adjust, some reporting requirements. The remaining submissions
indicated that all existing reporting requirements should be retained and most recommended
additional requirements be introduced.
Benefits of reporting
Most of these submissions indicated that the consultation process, in particular the guiding
questions for submissions (Attachment B refers), had focused too heavily on the costs of reporting
without due regard for the benefits. The following benefits of reporting were highlighted:




enables the collection of meaningful gendered data sets on workforce composition
provides a unique data set that is not available through any other sources
provides reporting organisations with customised benchmark reports that will allow them to
compare their gender equality performance with organisations in the same industry and of a
similar size
provides the Agency with data that will enable it to develop targeted educational and
advisory initiatives and materials to better support employers.
Time and cost to report
Two submissions estimated that the cost for reporting organisations is low, about $2000 per report
(which might cover several subsidiaries) or $692 for each of the 13,000 entities covered by the
Workplace Gender Equality Act 2012.
One submission, with reporting organisations among its members, indicated that close to half of
these members estimated that it took more than 20 hours to complete the report, and more than
one-third said it took more than 35 hours to collate the information required, prior to preparing
their report.
Page 14 of 21
Manager categories
Most of the submissions from gender equality advocates supported the current manager categories.
One submission highlighted the importance of this data for identifying the position of women in the
leadership pipeline, another commented that standardised categories would enable the Agency to
create industry-level and national benchmarks and monitor trends over time. One submission did
suggest that, over time, it would be useful to develop industry-specific manager categories.
Non-manager categories
There was broad support for continued use of ANZSCO classifications to define non-manager
categories as these categories have been standardised, are comparable and are endorsed by the
Australian Bureau of Statistics. Five submissions acknowledged that some reporting organisations
had found non-manager categories difficult and suggested that, over time, the Agency should work
with industries to develop industry-specific non-manager categories based on ANZSCO classifications
or provide greater granularity to the existing categories. One submission recommended that the
requirement to report on graduates be removed.
Employment status
Several submissions emphasised the importance of collecting data on employees that work on a
casual basis as a relatively high proportion of women work on a casual basis. There was some
acknowledgement, however, that reporting on casual employees (and, for example, providing
annualised full-time equivalent remuneration for casuals) was difficult for some employers.
Remuneration
Submissions from gender equality advocates linked the collection of remuneration data and efforts
to address the gender pay gap. One submission suggested that the requirement to report on CEO
salaries be removed.
Reporting questionnaire
A number of submissions made specific suggestions relating to the reporting questionnaire,
including:



amending the requirement to report on the proportion of the workforce that has access to
employer-funded parental leave for primary and secondary carers
simplifying and clarifying the requirement to report on the availability of employment terms,
conditions and practices so that it is clear that employers are required to indicate only
whether flexible conditions are on offer, not whether they have been used
refining the question related to equity partners to capture a richer range of data.
Some submissions also suggested that new reporting requirements be introduced, including:


data on the number of resignations after parental leave and after a request for flexible work
arrangements has been refused
data on the number of requests and approvals for flexible work arrangements on return
from parental leave by people with caring responsibilities
Page 15 of 21

additional questions on remuneration, such as pre-tax superannuation payments and access
to salary sacrifice arrangements
Additional reporting requirements (Schedule 2 requirements)
The majority of submissions supported the introduction of additional (Schedule 2) reporting
requirements and did not propose any reduction to these requirements. One submission suggested
a number of options to simplify reporting requirements including by: removing the requirement to
report on the composition of applications, interviews and appointments by gender; simplifying the
requirement to report on total components of remuneration; and simplifying the requirement to
report on the number of requests and approvals for extensions to parental leave.
Benchmark reports
Most submissions from gender equality advocates indicated that benchmark reports will provide
reporting organisations with useful information that will support them to understand how their
organisations’ gender equity performance compares with performance in similar entities. It was
stated that benchmark reports will be of real value if they provide insights into an organisation’s
gender equality performance and help to drive change.
SUMMARY OF EMPLOYER MEETINGS
The Department and the Agency held meetings with a number of reporting organisations to hear
about their reporting experiences in detail. A range of employers of various industries, size and
locations either met with, or held teleconferences with, Departmental and Agency officers from June
to September. Overall, 18 employers provided direct feedback on their experience with reporting for
the 2013–14 reporting period.
The majority of employers supported workplace gender equality objectives and wanted to improve
their workplace gender equality performance. While they expressed broad support for gender
equality objectives, many were not convinced that the current reporting requirements were the best
way to meet those objectives.
Time required to report
During the interviews, employers commented on the time required to complete the report.
Responses ranged from four hours to over six weeks. In many cases, responses were dependent on
how many staff members were involved in the process.
Manager categories
Ten employers reported that it was difficult to classify their managers into the five manager
categories. Those that found it difficult indicated that the manager categories did not reflect their
business structure or pay scales. One employer expressed concern that that there was large
variation between managers within a single management category (for example between key
management personnel in corporate and commercial areas of the organisation), and that combining
these diverse roles into one management category could produce misleading data. Another
employer stated that while the experience was difficult, it would prefer it if the categories were not
changed now that it had taken the time to classify its employees.
Page 16 of 21
Non-manager categories
Twelve employers indicated that they had difficulty classifying non-managers into ANZSCO
categories and found the process time consuming. For example, some employers reported that a
single category (such as the ‘professional’ category) is too broad and does not reflect the differences
between employees within that single category. Two employers suggested that industry-specific
categories be developed, one suggested that lower level ANZSCO categories (i.e. a greater level of
granularity) should be available, and another suggested fewer categories be used (i.e. less
granularity). A number of employers were concerned that, because the categories were not a good
reflection of their organisational structure, the resulting report was misleading, particularly when
remuneration data was provided against each occupational category. Two employers indicated that
now they had taken the time to classify their employees into ANZSCO categories, this element would
be easier in future years. Other employers advised that it would not get any easier as the data would
need to be extracted and manually manipulated each year.
Employment status
Most employers reported no difficulty or concerns with reporting on employment status, largely
because these employers had few or no casual or contracted employees. One employer found
reporting on employment status difficult as it had a large number of casual workers and the
information had to be manually collated.
Reporting level from the Chief Executive Officer
Most employers did not indicate any concerns reporting on managers’ level from the Chief Executive
Officer. Of those that did experience difficulty, this was mostly due to concerns that the resulting
data might not reflect their business or governance structure and a concern that, when combined
with remuneration data, this would produce misleading results.
Remuneration
Employers reported that annualising base salary and total remuneration was a particular struggle if
there were high numbers of casual or part-time staff, and if staff worked irregular working hours
(such as shift work with some weeks on and some weeks off). These factors made it difficult for
employers to identify a standard working week which they could use as the basis from which to
annualise salary data.
Most employers reported some difficulty in collecting annualised full-time equivalent total
remuneration data. Providing this data also appears more difficult for employers if their employees
work across multiple enterprise agreements and awards.
Employers indicated that reporting on base salary was easier than reporting on total remuneration.
Page 17 of 21
Reporting questionnaire
Employers reported fewer concerns with the multiple choice questions than they did with the
workplace profile.
Several employers indicated that they would like a free-text option added so that they could provide
further information and explain their responses. This issue was raised by employers that did not
have formal strategies or policies in place, but felt that they had informal arrangements that should
be recognised.
Most feedback provided related to Gender Equality Indicator 4: availability and utility of
employment terms, conditions and practices relating to flexible working arrangements for
employees and to working arrangements supporting employees with family or caring
responsibilities. Three employers indicated that while they offered flexible arrangements to staff as
needed, this practice was not captured in any formal policy or strategy and, therefore, could not be
included in the employer’s report to the Agency. One employer indicated that the reporting
questionnaire had been useful as it had prompted discussions within the organisation about flexible
working arrangements and other gender equality matters.
Additional reporting requirements (Schedule 2 requirements)
Many employers thought they would have some difficulty in collecting data on components of total
remuneration and did not necessarily have the systems in place to support this data collection.
Three employers indicated that they would be able to collect this data easily.
Most employers thought that it would be difficult to collect data on recruitment activities.
Employers that received a high volume of unsolicited applications expressed the most concern. Four
employers indicated that they would be able to capture this information, the most common reason
being a low turnover of staff and a small number of applicants.
General comments
Once reporting data has been collected and analysed, the Agency will provide feedback to each
employer in the form of a confidential, customised benchmark report on their gender performance.
During interviews, 13 employers commented on benchmark reports. Most employers thought these
reports would be useful. Those that did not see the reports as useful held this view because of
concerns that the pay and occupational data they had provided did not reflect their organisational
structure and this could compromise the validity and comparability of benchmark reports.
All employers commented on the advice and support provided by the Agency. Nearly all employers
were positive about the assistance provided by the Agency, including support provided online and
via telephone or information session.
Page 18 of 21
STAKEHOLDER CONSULTATION SESSIONS
In late September 2014, roundtable meetings were held with gender equality advocates and
employer representatives. The meetings considered the feedback collected from the consultations
to date and potential options to improve the effectiveness of reporting requirements.



On 17 September, the Business Council of Australia, Australian Human Rights Commission,
the Agency, Australian Industry Group, and Australian Chamber of Commerce and Industry
participated in a teleconference with the Secretary of the Department.
On 19 September, a roundtable with gender equality advocates was held in Canberra,
chaired by Ms Helen Conway, Director of the Agency.
On 24 September, representatives from the Recruitment and Consulting Services
Association, Master Builders Association, and the Australian Mines and Metals Association,
participated in a teleconference with officials from the Department. The Minerals Council of
Australia met separately with the Department on 26 September.
Page 19 of 21
ATTACHMENT A: List of organisations that have made public submissions
(excludes anonymous submissions)
No.
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
23.
24.
25.
Organisation
Calvary Christian College
Jacobs Group (Australia) Pty Ltd
PricewaterhouseCoopers
Australian Chamber of Commerce and
Industry
Australian Federation of Employers and
Industries
Australian Financial Markets Association
Australian Higher Education Industrial
Association
Australian Industry Group
Australian Private Hospitals Association
Australian Public Transport Industrial
Association
Chamber of Commerce and Industry
Queensland
Chamber of Commerce and Industry of
Western Australia
Equity Practitioners in Higher Education
Australasia
Master Builders Australia
Master Electricians Australia
Minerals Council of Australia
Recruitment and Consulting Services
Association
Restaurant and Catering Industry Association
Coalition for Working Women
a. Interim submission (July)
b. Addendum (October)
Diversity Council Australia
Economic Security for Women
Women in Super
Women Lawyers Association of New South
Wales
Shop, Distributive and Allied Employees’
Association
The Women and Work Research Group,
The University of Sydney
Organisation type
Reporting organisation/employer
Reporting organisation/employer
Reporting organisation/employer
Employer representative
Employer representative
Employer representative
Employer representative
Employer representative
Employer representative
Employer representative
Employer representative
Employer representative
Employer representative
Employer representative
Employer representative
Employer representative
Employer representative
Employer representative
Gender equality advocate
Gender equality advocate
Gender equality advocate
Gender equality advocate
Gender equality advocate
Gender equality advocate
Gender equality advocate
Page 20 of 21
ATTACHMENT B: Guiding questions for submissions
1.
Please provide feedback on your experience of collecting data for reporting purposes. For
example, if you already collected the data for reporting, what components were difficult/easy
to provide and are the data requirements and questions easy to understand.
2.
Please provide some feedback on your experience of providing the data to the
Workplace Gender Equality Agency. For example, how was this year’s experience compared to
previous reporting periods when the online portal was not available and the structure of the
report was different?
3.
How long did it take your organisation to complete the report? You may like to include a cost
estimate based on the number of hours of staff time.
4.
What improvements could be made to the reporting requirements?
5.
How easy was it for you to report on employment status (permanent/contract/casual), the
manager and non-manager categories, and reporting level to CEO?
6.
With regards to the full reporting requirements (workplace profile and questionnaire), what
information should be included in the customised benchmarking reports to ensure the reports
are most useful to your organisation? Why?
7.
With regards to the full reporting requirements (workplace profile and questionnaire), what
information would be least useful and should not be included in the customised benchmarking
reports for your organisation (detail all relevant information)? Why?
8.
Do you already collect, or have you undertaken any preparations to collect the additional
requirements due to commence on 1 April 2015?
9.
Do you anticipate any difficulties in reporting on the additional requirements due to commence
on 1 April 2015?
10. Please provide any general comments you would like to add that have not already been
covered.
Page 21 of 21