Iain StarkInternational Compensation & Benefits LeaderMarch 21, 2026

The structure worked well and after 60 minutes as we broke it down by area there was clarity on what mattered, overall and then by country, and the follow ons - the project lead, actions by whom, by when, updates to the CEO and others, with a plan for the rest of 2026.

Also some other questions! Including the impact of the EU AI Act coming into effect this year and the Data Privacy Act already in effect.

The questions below. ☐ Yes ☐ No ☐ WIP. "Yes" was sometimes a debate. "Work In Progress" was really interesting as it revealed where the client had not focused and needed to do more and "No" was clearer with the same action.

The ownership with dates in 2026 was key. It will evolve as countries react -- the announced delays vs the June 2026 transposition deadline, Denmark, France, Ireland, and the Netherlands, Sweden from delay to renegotiate and Germany with "low bureaucracy", with many countries silent may push reporting if 150+ and individual communication into 2028.

The client found that it was the opportunity for the gap analysis and action right now and also consider beyond the EU as they have business in the UK, the US and Switzerland.

Governance, Ownership, Policies and Communication

• We have clear Group CHRO-level ownership of pay transparency implementation that the CEO, the Board and other key stakeholders know. ☐ Yes ☐ No ☐ WIP
• We have clear written global policies on how we categorise and evaluate jobs, and managers and employees know and use this. ☐ Yes ☐ No ☐ WIP
• We have assessed the differences between current reporting requirements and the directive by country and also vs the CSRD. ☐ Yes ☐ No ☐ WIP
• We are are very careful about dashboards that may create more questions than answers. ☐ Yes ☐ No ☐ WIP
• We have the external C&B, ER/LR and Legal support required. ☐ Yes ☐ No ☐ WIP
• We understand the articles of the directive including that it applies even if only 1 worker in 1 EU country and reporting may be in addition. ☐ Yes ☐ No ☐ WIP
• We know how to count workers allowing for country variations - calendar year, snapshot or a 12-month period - for entities with 150+ workers for reporting in 2027 or 2028 if countries are late. ☐ Yes ☐ No ☐ WIP
• We also know which countries, eg, France, may require reporting earlier than 2031 if 50-149 ☐ Yes   ☐ No   ☐ WIP
• Our country HR teams understand, receive regular updates and share feedback. ☐ Yes ☐ No ☐ WIPWe know the overlaps with non-EU countries — for example the US, especially California, the UK, and Switzerland. ☐ Yes ☐ No ☐ WIP
• We have a budget for the internal and external resources to execute. ☐ Yes ☐ No ☐ WIP
• We have a management system for execution with dates and responsibilities. ☐ Yes ☐ No ☐ WIP

Country Readiness — 27 different implementations plus implications for non-EU countries

• We are tracking transposition status in all our EU countries, have assessed our gaps versus current country requirements, and have local capability to execute in each country. ☐ Yes ☐ No ☐ WIP
• We also know the requirements in other key countries — US, UK, Switzerland and others as relevant — and how the directive differs from and may change how we execute or report there. ☐ Yes ☐ No ☐ WIP

Compensation & Benefits — Job Architecture and Grading for Work of Equal Value

• We have consistent job architecture and grading across our entities. ☐ Yes ☐ No ☐ WIP
• We know how our current job evaluation method and collective bargaining agreements align with the directive as our categorisation method satisfies the 'work of equal value' requirement. ☐ Yes ☐ No ☐ WIP
• We used this for salary planning in 2026. ☐ Yes ☐ No ☐ WIP
• Our pay definition includes elective employee benefits and discretionary LTI. ☐ Yes ☐ No ☐ WIP
• We have tested at least the largest entities for gender pay gap analysis. ☐ Yes ☐ No ☐ WIP
• We have communication material for workers about how their pay is set. ☐ Yes ☐ No ☐ WIP
• Our works councils and unions know our current job evaluation approach. ☐ Yes ☐ No ☐ WIP
• We apply narrow bands by job category for equal value for precision. ☐ Yes ☐ No ☐ WIP

Legal

• We have the external legal expertise we need to track legislation and support our legal team on the implications overall and by country. ☐ Yes ☐ No ☐ WIP
• We understand the legal requirements on categorisation such as in Germany, France, Italy, the Netherlands and Spain ☐ Yes ☐ No ☐ WIP

Employee & Labour Relations

• Our employees and their managers know how their compensation and benefits are set. ☐ Yes ☐ No ☐ WIP
• We are clear on which collective agreements impact by country entity and populations, eg, non-dirgenti/dirigenti in Italy ☐ Yes ☐ No ☐ WIP
• We have a Group strategy for consulting works councils on job categorisation. ☐ Yes ☐ No ☐ WIP
• This includes where works councils and unions need to agree, be consulted, or be informed. ☐ Yes ☐ No ☐ WIP
• We are clear on which executives/senior managers are excluded from collective agreement pay ranges. ☐ Yes ☐ No ☐ WIP
• We understand the different actions required for works councils versus unions/sector agreements. ☐ Yes ☐ No ☐ WIP
• Where we have no workers' representatives today, we have a plan for engaging directly or will create a new body. ☐ Yes ☐ No ☐ WIP
• We have a plan for sharing category data with workers and their representatives. ☐ Yes ☐ No ☐ WIP

Data & Systems

• We can extract and analyse gender pay data by job category by entity in every country, including elements such as benefits and LTI. ☐ Yes ☐ No ☐ WIP
• We understand and can manage the risks of dashboards that require individual worker explanation. ☐ Yes ☐ No ☐ WIP
• We have the related data beyond what is in payroll — for example benefits in kind and LTI. ☐ Yes ☐ No ☐ WIP
• We understand and can manage data privacy versus transparency. ☐ Yes ☐ No ☐ WIP
• We understand and can manage the EU AI Act high-risk implications. ☐ Yes ☐ No ☐ WIP

Recruitment Transparency

• We have defined pay ranges for all roles and are ready to publish in job postings where required. ☐ Yes ☐ No ☐ WIP
• We can communicate salary or salary ranges and comment on benefits and LTI. ☐ Yes ☐ No ☐ WIP
• Our talent acquisition teams are trained on the requirements. ☐ Yes ☐ No ☐ WIP

Execution: KEY

• We have a clear plan with a calendar on how to execute and who is leading this. ☐ Yes ☐ No ☐ WIP