Employment Practices (September 13, 2023)
Q: What steps might be considered to comply with the NY State pay
A: The primary objective of the law is to
address and diminish pay inequity and discriminatory wage-setting and hiring
practices by requiring transparent sharing of compensation information up
front. With that in mind, employers may:
review, revise job descriptions for all positions. Document pay ranges.
the reporting structure of out-of-state job listings (e.g. are out of state employees reporting to NY based managers?).
a hard look at your policies for determining salaries, and your pay ranges for
all positions and make adjustments if needed. Develop a process to consistently
review and update job descriptions, pay ranges and reporting structures.
and revise existing job postings and your job advertisement templates.
This includes internal postings for positions (the NY State pay transparency law
applies to advertisements for opportunities that are posted solely within your
company, as well as for public viewing). Confirm that your posts and templates
include job descriptions for the roles advertised and compensation ranges.
your people – all personnel responsible for advertising jobs,
promotions, or transfer opportunities should understand the disclosure obligations and
know how to comply with the law.
your attorneys involved in the process.
Pay disparities cause low morale and the loss of good employees. They
can also lead to lawsuits by employees who believe they are being paid
less because of their gender or race or some other protected class. We can help you correct pay disparities
before they are revealed in future job postings and avoid equal pay/discrimination lawsuits.
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