Fair & Equal Pay Policy

1. Policy Overview

Enlighta Inc. (“Enlighta”) is a global Software-as-a-Service (SaaS) provider headquartered in San Ramon, CA. Enlighta Inc. specializes in providing hosted supplier governance and service management software solutions to clients.

The purpose of this policy is to establish controls to ensure compliance with all applicable fair & equal pay regulations, and to ensure that the Company’s business is conducted in a socially responsible manner.

Enlighta supports the principle of equality of opportunity for all staff. It recognizes the importance of and is committed to, providing a fair, objective, and transparent pay system which is free from gender bias. As a good business practice and in the interests of equity and fairness, Enlighta is committed to taking action to ensure that it provides equal pay for men and women for like work, work of equal value, and work rated as equivalent.

Pay, therefore, includes access to, and level of benefits under, occupational pension schemes, contractual and discretionary bonuses, and sick pay as well as any other additional benefits.

2. Scope

This policy applies to all individuals working at all levels and grades, including senior managers, officers, directors, employees (whether permanent, fixed-term, or temporary), consultants, contractors, trainees, seconded staff, homeworkers, casual workers and agency staff, volunteers, interns, agents, sponsors, or any other person associated with us, or any of our subsidiaries or their employees, wherever located (collectively referred to as employees in this policy). 

3. Objectives

Enlighta has implemented this Fair & Equal Pay Policy to address the following objectives:

• Eliminate any unfair, unjust, or unlawful practices that impact pay.
• Take appropriate remedial action.
• Review other Company policies to ensure consistency with equal pay principles.

4. Roles and Responsibilities

• Executives – Ensure that the Fair & Equal Pay Policy is established, periodically reviewed, and communicated to employees and contractors.
• Human Resources – Ensure that the key provisions of this policy are incorporated into employment and consultant agreements as required by the program. Establish a cadence of communication of policy review by employees and contractors.
• Management at all levels is responsible for ensuring those reporting to them are made aware of and understand this policy and are given adequate and regular training on it.
• If you believe that you are not being paid equally to another employee of the same/opposite sex for the same or similar work, for work rated as equivalent (following a job evaluation scheme), or for work of equal value, you should raise your concerns with your Manager OR Enlighta Executives or send an email to compliance@enlighta.com as soon as possible.

5. Policy

5.1 Equal Pay

5.1.1  Staff have a right to receive equal pay in their contract of employment where they are employed on;

• ‘like work’
• work rated as ‘equivalent’
• work of ‘equal value’ (also referred to as equal work)

To bring a claim for equal pay, a claimant must identify an actual comparator of the same/opposite sex. The comparator must be in the ‘same employment’ as the claimant. 

It is in the overall interest of Enlighta, and good business practice, that pay is awarded fairly, equitably, and not on an arbitrary basis.

We recognize that to achieve equal pay for employees, Enlighta should operate a transparent pay system, based on objective criteria, and free from bias.

5.1.2  To achieve and maintain equal pay, Enlighta will:

• Have a transparent pay system, which all staff is informed of in terms of what pay points apply throughout the company and where they are placed on the pay point scale.
• Ensure all part-time, temporary, and agency workers are covered by the pay policy, and not treated any less favorably.
• Reward fairly and equitably all staff, ensuring no one is disadvantaged because of career breaks linked to caring responsibilities.
• Evaluate and grade all new posts per clearly defined processes.
• Benchmark pay on an annual basis. 

5.1.3  Enlighta may legitimately pay comparable staff differently, however, they must be able to show that this is due to a “material factor, such as different hours of work, market forces or rewarding productivity and these roles must be taken through the evaluation process, led by Enlighta Executives to ensure a fair process is applied.

5.2 Unfair Discrimination

Enlighta will seek to avoid unfair discrimination and ensure that it awards equal pay, in all aspects of its business, including recruitment and promotion of its employees.

Enlighta has the objectives of eliminating any unfair, unjust, or unlawful practices that impact pay as well as taking any appropriate remedial action as and when necessary.

To attain its objectives, key approaches taken by Enlighta will include:

• Providing training for managers and all staff involved in determining pay.
• Keeping employees informed about how practices used by the company to determine pay point scales work, as well as any monitoring of pay statistics and equal pay review undertaken by the company.
• Plan and implement actions in consultation with relevant employee representatives.
• Respond to any grievances raised on equal pay issues.
• Ensure transparency in determining evaluation criteria for pay point scales.
• Evaluation of posts to determine appropriate pay scales.
• Monitoring of applications for jobs to determine whether jobs applied for by women are being appointed at lower pay points and to devise remedial action plans if so required.

5.3 Complaints

Enlighta will provide a supportive environment for staff who wish to claim pay inequality.

Employees should raise an equal pay claim to Enlighta Executives or send an email to compliance@enlighta.com.

A claim for equal pay can be brought at any time during the employment, irrespective of employees’ length of service for the company.

5.4 Terminologies

5.4.1 Like Work

There are considerations to be made when determining ‘like work’.

It must first be established whether the two comparators are employed in work that is the same or of a broadly similar nature. This involves a general consideration of the work and the knowledge and skills needed to do it.

If the work is broadly similar, a second point to be clarified is whether any differences between the individual’s work and that done by the comparator are of practical importance having regard to;

• The frequency with which any differences occur in practice.
• The nature and extent of those differences.

It is for the company to show that there are differences of practical importance in the work performed. Differences such as additional duties, level of responsibility, skills, the time at which work is done, qualifications, training, and physical effort could be of practical importance.

A difference in workload does not preclude a like work comparison unless the increased workload represents a difference in responsibility.

The following should be considered to determine whether or not employees are performing like work:

• Comparison of employees at the same grade.
• Comparison of jobs above and below grade boundaries.
• Occupational banding or zoning.
• Looking behind job titles to determine the nature of work; jobs could be like work even when they first seem dissimilar.

5.4.2 Equivalent Work

Work is rated as equivalent if the company’s job evaluation study gives equal value to their work in terms of the demands made on the employee, by reference to factors such as effort, skills, and decision making.

Because the focus is on the demands of the job rather than the nature of the job overall, jobs that may seem to be very different may be rated as equivalent.

The company’s job evaluation scheme is careful to not be influenced by gender stereotyping or assumptions about work.

5.4.3 Equal Work

Equal pay can be claimed if it can be shown that work is of an equal value in terms of the demands made on the individual. The work can be different but regarded as being of equal worth, having regard to the nature of the work performed, the training or skills necessary to do the job, the conditions of work, and the decision-making that is part of the role.

The most reliable and objective approach to determining equal value is to use a single job evaluation scheme designed and implemented to take account of equal value considerations and specific job populations and should include effort, skills, decision, and responsibility.

5.4.4 Gender Pay Gap

The gender pay gap is the difference in the average pay between women’s and men’s earnings, expressed as a percentage of men’s earnings, and can be explained by several factors including working hours and type of job. Whereas equal pay deals with the pay differences between men and women who carry out the same jobs, similar jobs, or work of equal value. It is unlawful to pay people unequally because they are a man or a woman.

Note: This policy may be amended at any time.