# PAY TRANSPARENCY POLICY
Date: 1 October 2032
Parties: Harbourlight Community Housing Association and its 42 employees
## 1. Purpose and parties
Harbourlight Community Housing Association adopts this Pay Transparency Policy on 1 October 2032, effective from 1 November 2032. It applies to all 42 employees, whether full-time, part-time or fixed-term, and is owned by HR Director Naomi Bennett. Its purpose is consistent, evidence-based pay decisions and a clear route for questions; it does not promise identical pay where responsibility, experience, performance or a genuine market factor differs.
## 2. Facts, scope and terms
Harbourlight publishes internally the minimum and maximum of each grade: Grade 1 £26,400–£30,800, Grade 2 £30,801–£37,500, Grade 3 £37,501–£46,900, and Grade 4 £46,901–£58,000 per year. A role is placed by evaluated responsibilities, required skills and accountability. Employees may ask HR for their own grade, pay point and position in the band, but individual colleagues' pay is not routinely disclosed. Annual total-reward statements will show salary, employer pension contribution and taxable benefits.
## 3. Process and responsibilities
Progression within a band requires evidence against the published criteria: sustained delivery, relevant capability, role-related development and effective behaviours. Managers must give written reasons for a progression decision, identify any missing evidence and offer a review meeting. Pay reviews take place each 1 April; the first review under this policy is 1 April 2033. A band maximum is not an automatic entitlement, and budget limits cannot justify unequal pay connected to a protected characteristic.
## 4. Evidence, records and safeguards
HR will complete an annual equal-pay audit by grade, role evaluation, sex and ethnicity, and will investigate an unexplained difference of 5% or more within 60 days. The audit will compare like work, work rated as equivalent and work of equal value, then record objective reasons such as responsibility or experience. An unjustified difference will receive a written remediation plan with an owner and target date. Harbourlight has 42 employees, so the statutory gender pay-gap reporting regime for employers with 250 or more employees does not currently apply; it will nevertheless publish an anonymised aggregate summary each September.
## 5. Review, escalation and outcome
A contractual term cannot lawfully prevent an employee from disclosing pay to establish whether there is a connection with sex or another protected characteristic for the purposes protected by Equality Act 2010 section 77. Harbourlight will not discipline or subject an employee to a detriment for such a lawful discussion. Employees should limit disclosure to what is reasonably necessary and must not disclose another person's personal information without a lawful basis. HR will treat a pay concern as confidential as far as practicable, while explaining that confidentiality cannot guarantee anonymity.
## 6. Reservations and practical protections
An employee may raise a pay question with their manager or HR Adviser James Wilcox, request the written band criteria, and ask for a review within 20 working days of receiving a decision. Naomi Bennett will provide a written outcome within 15 working days after the review meeting, or explain the delay. A grievance remains available, and this policy does not shorten any statutory time limit, prevent an Equality Act 2010 claim, or replace independent legal advice. Retaliation for raising a good-faith concern is prohibited.
## 7. England and Wales law and completion
This completed fictional policy is governed by England and Wales law and will be reviewed on 31 October 2033, or earlier after a legal or organisational change. HR will retain the audit methodology, anonymised results, band schedule and review decisions securely, with access limited to authorised personnel. The policy is guidance for fair administration alongside each contract: where a contract or statute gives a more favourable right, that right prevails, and no employee is required to sign away a pay-discussion or equal-pay protection.