Pay equity compliance was not a one‐time event. The Pay Equity Commission of Ontario has stepped up enforcement
When the Ontario Pay Equity Act was first passed, it led to a flurry of activity as employers selected job comparison systems, evaluated jobs, negotiated pay equity, and posted pay equity plans. Where necessary, wage adjustments were made. Pay equity did not end there, however. The Pay Equity Act imposes ongoing obligations to maintain compensation practices that provide for pay equity. In addition, no employer or union may bargain for or agree to compensation practices that do not provide for pay equity.
Many employers have forgotten about these ongoing pay equity obligations and very few have a system in place to monitor compliance.
You need to be aware that the Ontario Pay Equity Office runs a monitoring program under which it selects employers and sends them a detailed questionnaire asking about their pay equity compliance. In the past, the Pay Equity Office focused on various geographic areas (for example, in 2008, retail, hotel and motel establishments in Peel Region) or industrial sectors (for example, manufacturing in 2004 and food processing in 2002). Their selection of employers is now random and province‐wide.
As a result, it is important for an employer to keep copies of its original pay equity documentation. In addition, keep in mind the pay equity consequences and requirements when establishing new job classifications, reclassifying positions, eliminating male job comparators, using a new job evaluation system, restructuring an organization, purchasing a business, negotiating wage increases with a union, or substantially changing benefit plans. A good idea is to conduct a self audit of your pay equity compliance. Remember, your organization can be selected for an in‐depth audit by the Pay Equity Office at any time.
The Pay Equity Office has posted a "Compliance Self‐Audit Tool" at http://www.payequity.gov.on.ca/peo/english/pubs/mp_selfaudit.doc.