Mind the Pay Gaps!

RMT submitted the following comments to TfL / London Underground's consultation on its pay gap reports and plans.


RMT comments on TfL pay gap action plan (and associated reports)


The pay gap reports show that the persistence (and in some aspects, worsening) of pay disadvantage experienced by women, black, ethnic minority and disabled workers arises from two main areas:

  1. the over-representation of these groups in lower-paid grades and under-representation in higher-paid grades
  2. bonuses, which are disproportionately awarded to white, non-disabled and male workers.

TfL’s approach to reducing these gaps is to attempt to distribute people more evenly across its pay and bonus structures. While this may produce improvements, it leaves the structures themselves untouched, despite the evidence that they are inherently discriminatory.

RMT argues that significant reduction of the pay gaps requires changing the pay and bonus structures themselves.

Moreover, we believe that TfL’s action plan is replete with buzzwords and aspirations, but is very short on specific proposals that will bring about immediate change.

RMT proposes ten measures that we believe will make an immediate and significant impact in reducing the pay gaps:

  1. award a higher pay rise to the lowest-paid grades, by making a pay award which is RPI+ for everyone with a minimum figure that represents a larger percentage for the lowest-paid
  2. introduce a maximum salary linked to (eg. five times) the lowest wage
  3. abolish performance-related pay and bonuses – for all but the highest-paid, consolidate the money into the basic wage
  4. make domestic leave paid rather than unpaid
  5. amend the flexible working policy to ‘yes by default’, where there is an assumption that a flexible working request is agreed, unless there are insurmountable grounds to refuse
  6. fill vacancies, thus reducing the need for overtime: award a compensatory rise in basic pay where overtime has become endemic
  7. abolish the CSA2 grade on London Underground stations – reintroduce the single grade of CSA, on CSA1 pay, with all current CSA1s and 2s moved into that grade
  8. provide better career progression opportunities for part-time staff, by ensuring that all roles are open to part-time working
  9. provide workplace nurseries
  10. remove unnecessary restrictions on disabled staff, introduce adjustments passports; improve workplace accessibility; train all managers in managing disabled staff.


1. and 2. Evidence shows that the wider the pay gap between top and bottom pay, the wider gender pay gaps are as well. TfL’s own reports identify that concentration of women, black, minority ethnic and disabled workers in lower-paid grades is a root cause of the pay gaps.

The median hourly ethnicity pay gap has increased, according to the ethnicity pay gap report summary, “owing to a greater increase in Black, Asian and minority ethnic representation in the lower pay bands and lower paid operational roles” and a decrease at Director level. However, this only widens the pay gap because those jobs are low-paid and very highly-paid respectively.

3. Evidence shows that performance-related pay discriminates. There is evidence of this in TfL’s pay gap reports, and evidence across employment. The ethnicity pay gap report summary shows that 40.6% of white, and 37.2% of black and minority ethnic, employees receive bonuses. The summary states that because there is no fixed pay rate for non-operational position, “pay is more flexible, [and] there is therefore potentially more scope for importing wider societal market factors that affect pay”. This is a euphemistic way of admitting that this pay structure is
discriminatory, as it imports societal racism into TfL’s pay decisions. The obvious answer is to scrap that discriminatory system.

Deferring senior management bonuses reduced the ethnicity bonus gap [Ethnicity pay gap report, 2.9, p.9]. The logical conclusion of this is that abolishing them altogether will reduce the gap on a more permanent basis.

Please note that although TfL’s documentation includes long service awards under the heading ‘bonuses’, we are not proposing that long service awards are scrapped!

4. Women are more likely to have caring responsibilities, and are penalised by losing pay when these responsibilities make them unavailable for work.

5. There is evidence that flexible working facilitates reduction in the gender pay gap. Too many of our members have their requests rejected. A policy of default acceptance would reduce the gap.

6. Men work more overtime, mainly due to women’s greater caring responsibilities outside work. This contributes to their higher average pay.

7. 62.7% of CSAs are black and minority ethnic.

8. The pay gap for part-time workers is significantly wider than for full-time workers, at 29.9% median. [Ethnicity pay gap report, Table 6, p.13]

9. Workplace nurseries enable parents (particularly mothers) to work longer hours and earn more. Motherhood may still account for about one third of the overall gender wage gap 20 years after childbirth [Institute for Fiscal Studies report, 2018].

10. RMT has members who have unnecessary medical restrictions which are preventing them achieving promotion. We also have members who have to ‘start again’ with adjustments when they change job, location and/or manager, a problem that would be overcome by the introduction of adjustments passports, which RMT has been requesting for several years.

The plan refers to working with “external organisations” on best practice for adjustments. However, we would like the company to prioritise working with its own staff and trade unions.

The training plan does not include training managers in managing disabled staff. The lack of this training is causing widespread mistreatment of disabled staff, including hampering their earning potential.


TfL still employs a smaller proportion of black and minority ethnic people than the proportion of London residents, and of economically-active London residents [ethnicity pay gap summary].

The plan focuses on increasing diversity in senior roles. This is a legitimate area for attention, but will make no difference to lower-paid women, black, minority ethnic and disabled staff.

The plan has an imbalance towards non-operational roles. The presentation only gives figures for non-operational employees, and some actions assume non-operational status (eg. ‘lunch and learn’.)

It is notable that while the media ethnicity hourly pay gap has increased [report, 2.5, p.8], it has decreased among operational employees [2.6, p.8] and among non-operational employees [2.7, p.9]. This illustrates that breaking down statistics can disguise inequality, an issue which RMT has raised previously.

The ‘Change’ column in the ethnicity pay gap Table 3 [p.10] misrepresents the degree of change. The figures are presented as the percentage change, but are actually the change in percentage points. For example, a change from 6.8% to 5% (Directors) is presented as -1.8% but is actually -26.5%; the change from 37% to 37.8% (Band 2) is presented a +0.8% but is actually +2.2%.

The plan aspires to higher rates of declaration. We would like to be able to recommend that our members disclose, but can not as present, as we can not be sure that it will not lead to discrimination.

The plan includes [3.1] “Re-design graduate and apprentice on-line assessments ensuring barriers are removed for all minority groups and with a particular focus on the needs of those who are neurodivergent.” This must include the scrapping of situational judgement tests, an issue which RMT has repeatedly raised.