We are a signatory to the HM Treasury Women in Finance Charter and view the widespread support for the Charter from across financial services as emblematic of the pro-diversity and inclusion stance adopted across our membership. We consider that progressive employment practices should be seen as defining a well-run company in modern Britain.

We welcome the opportunity to comment on the BEIS consultation on ethnicity pay reporting. We are supportive in principle of the initiative and have provided answers to the specific questions below. In discussion with members, a question that has been put to us is whether it is right to use ?white? as the benchmark for comparing ?other ethnicities?. While a binary approach has the benefit of simplicity, it provides only a starting position and there is a case for suggesting that a better approach might be to compare all categories used against an overall employee average hourly earnings.