Gender Pay Gap Policy
Contact: info@thema-healthcare.co.uk
1. Purpose
Thema Ltd is committed to fairness, equality of opportunity, and transparent reward practices. This policy explains our approach to understanding, monitoring, and (where applicable) reporting our gender pay gap.
We recognise that gender pay gap reporting is different from equal pay. Gender pay gap measures average differences across the workforce; equal pay relates to pay equality for the same or equivalent work.
2. Legal requirements (when in scope)
This policy is based on the Equality Act 2010 (Gender Pay Gap Information) Regulations 2017, which apply to employers in England, Scotland and Wales that have 250 or more employees on the relevant “snapshot date”.
Snapshot date (private and voluntary sector): 5 April each year.
Reporting deadline (private and voluntary sector): publish and report within 12 months, by 4 April the following year.
If a business is a public authority employer, different snapshot dates and deadlines apply (commonly 31 March / 30 March).
3. What must be reported (when in scope)
Where Thema Ltd is required to report, we will calculate and publish the six statutory metrics:
Mean gender pay gap (hourly pay)
Median gender pay gap (hourly pay)
Mean gender bonus gap
Median gender bonus gap
Proportion of men and women receiving a bonus
Proportion of men and women in each pay quartile band (lower, lower-middle, upper-middle, upper)
Key statutory definitions we will apply:
Hourly pay calculations and pay quartiles use “full-pay relevant employees”; employees on reduced or nil pay due to leave (e.g., maternity/paternity/adoption/shared parental, sick leave, etc.) in the relevant pay period are excluded from “full-pay” calculations.
Bonus calculations cover bonuses paid in the 12 months ending on the snapshot date (and are calculated in line with the GOV.UK methodology).
4. Agency workers and contractors
As a recruitment business, we may engage a mixture of employees, workers and contractors. For gender pay gap reporting, we will determine who is included in the headcount and calculations by applying the statutory definitions of “relevant employee” and “full-pay relevant employee”, and the GOV.UK reporting guidance for employers.
5. Publication, written statement and where we publish (if required / voluntary)
If Thema Ltd is required to report (or chooses to report voluntarily), we will:
Submit our figures via the UK Government Gender Pay Gap service, and
Publish the figures on our website (or intranet/parent company website if applicable) and keep them available for at least 3 years, and inform employees where to find them.
Written statement (private/voluntary sector): When submitting, we will upload a written statement confirming the accuracy of the reported data, signed by an appropriate senior person (for a limited company, typically a Director).
We may also publish (optional but recommended):
A supporting narrative explaining the results
An action plan with measurable steps and timelines
6. Our approach (whether or not we are required to report)
Whether or not we meet the 250-employee threshold, we will:
Monitor pay and progression practices for fairness and consistency
Review recruitment, promotion and allocation practices to minimise bias
Encourage inclusive leadership and equal access to training and development
Consider flexible working and job design where possible
Investigate drivers of any identified pay gap and implement improvement actions
7. Responsibilities
Directors/Leadership: overall accountability for policy effectiveness and (where applicable) approval/sign-off of published reporting
HR/Compliance: data quality, analysis, reporting, publication and action planning
Managers: fair recruitment, allocation, performance and development processes