How should employers include bonuses paid to part-time employees when calculating their gender bonus gap?

The information that employers are required to report under the Equality Act 2010 (Gender Pay Gap Information) Regulations 2017 (SI 2017/172) includes the difference in mean and median bonus pay between their male and female employees. When calculating this, the employer must include all bonuses paid in the year ending with the snapshot date (5 April each year in the private and voluntary sectors and 31 March in the public sector). Pro rated bonuses paid to part-time employees should not be converted to a full-time equivalent figure, it is the actual amount of the bonus that should be included in the calculation. Therefore, if an employer has a significant number of female part-time employees, this could potentially distort its gender bonus gap.

An employer in this situation may wish to explain the effect of part-time working on its gender bonus gap in a narrative accompanying its figures. If it has a policy of encouraging flexible working with the aim of recruiting and retaining a diverse workforce, and it has a significant number of female part-time employees because of this, it could point to this when explaining its gender bonus gap figure.