Females in Vice President job code paid less than similarly situated males even with similar or more experience, tenure with company and time in position
During a routine compliance evaluation starting in January 2013, the New York District Office asserted that DJE Holdings discriminated against females employed in Job Code 2011 position, which includes employees in the Vice President job title, by paying them less than similarly-situated males between October 1, 2012 through October 1, 2013. Based on data received during the review, OFCCP performed a regression analysis that combined all employees in the job code which revealed that a statistically significant disparity in compensation remained even when legitimate factors affecting pay were taken into account.
Additionally, OFCCP obtained anecdotal information of females making less than males who were in the same position and practice area but had similar or more experience, time with the company, and time in the job code. OFCCP determined that after October 1, 2013, after reviewing DJE Holding’s compensation database and self-analysis that there was no continued statistically significant disparity warranting salary adjustments.
The settlement included $269,000 in back pay and $28,832 in interest and the affected class included 66 females. DJE Holdings will also:
• Review its policies and revise them if necessary to eliminate all practices having an adverse effect on compensation of females in that job code;
• Review its guidelines for determining starting salaries, the salaries of individuals promoted into, as well as, salary changes in this job code;
• Review its procedures and revise them if necessary to ensure compensation decisions are tracked and evaluated for compliance with all policies and that all documents are retained;
• Train all individuals involved in any way in determining compensation for employees in this job code; and
• Continue to monitor compensation for employees in this job code for any indication of disparities based on gender.
It is clear that OFCCP is not letting up on its evaluation of compensation practices. Please contact us at (888) 414-2410 if we can help you proactively review your pay practices and employee compensation.
Conciliation Agreement text.