# PAY EQUITY AND EQUAL PAY POLICY
Date: 1 February 2030
Parties: Northmoor Analytics Limited and its employees and workers
## 1. Purpose and parties
Northmoor applies this policy to employees and workers across its Leeds, Bristol and home-working teams. It commits to equal contractual pay for equal work regardless of sex, and to fair pay decisions without discrimination because of any Equality Act 2010 protected characteristic.
## 2. Facts, scope and terms
Equal pay is assessed by comparing like work, work rated as equivalent, or work of equal value; it is not a promise that every job has the same salary. Genuine material factors such as responsibility, scarce skills, location and performance may explain a difference if applied consistently and without sex discrimination.
## 3. Process and responsibilities
HR maintains grades A–G and publishes each grade's range, progression criteria and bonus rules. An analytical points-based evaluation reviews responsibility, knowledge, effort and working conditions. Managers must record starting-pay reasons and may not ask about salary history to justify an unexplained offer.
## 4. Evidence, records and safeguards
Each April HR audits base pay, bonus, promotion and starting pay by gender and, where lawful and sufficiently aggregated, ethnicity and disability. Northmoor has 184 employees, so gender-pay-gap reporting is presently voluntary; if it reaches the statutory 250-employee threshold it will make the required report and supporting narrative.
## 5. Review, escalation and outcome
A difference above 5% at a comparable grade triggers an investigation, not an automatic finding of illegality. HR tests comparators, material factors and intersectional impact, reports an anonymised summary to the board and gives a correction plan within 12 months where a gap is unjustified. Records are retained with access limited to need-to-know staff.
## 6. Reservations and practical protections
An employee may discuss a concern informally, request relevant comparator information, or submit a formal written grievance to the HR Director. An independent manager investigates and responds within 30 working days. The policy preserves an Employment Tribunal equal-pay claim, applicable limitation rules and protection from detriment for raising a concern or making a protected disclosure.
## 7. England and Wales law and completion
This is a policy, not a waiver of contract or statute; it does not require disclosure of another person's personal data and reasonable adjustments are available. Questions go to HR, then the grievance and appeal procedures. England and Wales law applies and the board approves this version on 1 February 2030.