EU Pay Transparency: What Counts as Working Conditions?
Learn what “working conditions” mean under the EU Pay Transparency Directive and how they factor into equal pay for work of equal value.
If you’re like most organizations moving towards pay transparency, you’re already taking steps to make sure all employees receive equal pay for work of equal value.
Perhaps you’ve started the hard work of mapping out the skills, effort, and responsibilities required at each level of your job architecture.
But a job’s content only tells one part of the story. Are you also clear on the context in which employees do their work?
- The physical environments they enter every day?
- The hazards they might be exposed to on the job?
- The psychological and emotional strain they experience?
- The irregular or unpredictable schedules they might have to work?
At a Glance
Situation
The EUPTD requires employers to assess work of equal value.
Challenge
Working conditions are often overlooked but can significantly affect job value.
Opportunity
Getting working conditions right can strengthen both pay fairness and compliance.
These factors make up a job’s working conditions, and they can vary significantly from one role to another.
If you’re implementing pay transparency under the EU Pay Transparency Directive (EUPTD), working conditions are another factor you must account for when assessing whether work is of equal value.
Why Working Conditions Matter Under the EU Pay Transparency Directive
"The value of work should be assessed using objective, gender-neutral criteria."
Harm van Vijfeyken, Senior Client Partner
To comply with the EUPTD, employers need a fair and consistent way to compare the value of different jobs.
“The value of work should be assessed using objective, gender-neutral criteria,” says Harm van Vijfeyken, a senior client partner in Korn Ferry’s Work Measurement practice.
Those criteria include skills, effort, responsibility, and working conditions.
Many organizations have ways to assess skills, effort, and responsibility. Working conditions can be harder to pin down because they depend on the context in which the work is performed.
What Counts as Working Conditions for the EUPTD?
Working conditions can include four key dimensions:
1. Physical Environment
“This is about adverse conditions in the working environment that may be uncomfortable or unpleasant,” explains Karin Visser, vice president of Korn Ferry’s global center of research and innovation, the Korn Ferry Institute.
If employees regularly do their jobs in less-than-ideal spaces, then these factors must be considered. Examples might include work settings with extremely loud noise, variable temperatures, bad odors, excessive moisture, intense vibrations, or lots of dust or dirt.
2. Hazard Exposure
Some jobs carry inherent dangers, even with safeguards and precautions in place. Hazard exposure reflects the degree to which employees interact directly with dangerous equipment, substances, processes, creatures, or activities.
“It’s a measure of unavoidable exposure to situations with potential of material harm, like injury or ill health,” says Visser.
3. Emotional or Psychological Strain
This accounts for sustained on-the-job exposure to trauma, aggression, crisis, and other emotionally or psychologically distressing situations.
“This is about exceptional emotional labor or strain beyond the job-content-related mental and emotional demand,” says Visser.
4. Work Patterns
This is the extent to which a job entails disruptive or challenging working time arrangements.
Work patterns that involve night work, shift work, irregular hours, extended hours, on-call duties, or unpredictable schedules should all be considered in determining pay fairness.
Why Are Working Conditions Hard to Assess?
Working conditions don’t always fit into clean categories, even within jobs that seem identical.
Consider two colleagues who both work as forklift operators.
On paper, they have the same job:
- Both are trained and certified to operate the machinery safely.
- They solve comparable problems each day.
- Their work has a similar impact on the organization.
But there are important differences:
- The first employee works in an ambient distribution center from nine to five, Monday to Friday.
- The second does her job in a frozen warehouse on a schedule that changes with supplier deliveries, which often arrive overnight.
Because the second employee is regularly exposed to freezing temperatures, cold air transitions, noise, and condensation, and because she works irregular hours, her working conditions are significantly different from those of her colleague.
“Employers can't ignore the specific circumstances in which each role operates,” says Claire Field, a senior client partner at Korn Ferry. “Working conditions can vary greatly even when the job title is the same.”
How to Assess Working Conditions Under the EUPTD
Once you’ve identified which working conditions may be relevant to a role, the next step is to assess how significant they are. This assessment assumes that any protective equipment, safety measures, and workplace controls are already in place.
Review these three factors:
1. Intensity
How intense or extreme is the condition? For example, is the cold the forklift operator works in a minor temperature change, an extreme one, or somewhere in between?
2. Frequency
How often is the condition experienced? Does the forklift operator work in the frozen warehouse every day, or only occasionally?
3. Duration
How long does the condition last? Is the forklift operator in the freezer for brief periods or for hours at a time?
Looking at intensity, frequency, and duration gives employers a more consistent way to assess job context alongside job content. That matters for EUPTD compliance, and it can also help employees understand why pay differences exist.
A structured approach, such as the Korn Ferry Hay Method of job evaluation, can help employers apply these assessments consistently.
Where to Start in Assessing Working Conditions
1. Review existing practices
Many organizations already address working conditions through shift premiums, allowances, job weightings, or other reward policies.
“Understand what already exists, where these provisions have been documented, and how they may interact with the principle of equal pay for work of equal value,” says Andrew Erhardt-Lewis, senior client partner at Korn Ferry.
2. Map where working conditions matter
Review your job architecture to identify where working conditions should be considered—and where they might not be relevant.
“We recommend reviewing your job architecture broadly, recognizing that many roles will ultimately not have working conditions that require consideration,” Erhardt-Lewis explains.
3. Prepare people for the changes
Managers, leaders, HR professionals, and employees need to understand what is changing, why it matters, and how decisions have been made, says Erhardt-Lewis. Clear communication will be critical to building trust while supporting compliance.
Get Working Conditions Right
Working conditions can make equal-pay decisions more complex than they first appear. Two roles may look the same on paper, yet the circumstances in which people do that work can be very different.
That’s why the distinction between job content and job context matters. Get that right, and it becomes much easier to assess working conditions consistently and explain why pay differences may exist.
Watch our on-demand webinar, What the EU Pay Transparency Directive Means for Compensation Strategy, to learn more about how working conditions can affect job evaluation, pay outcomes, and compensation decisions under the EUPTD.
Understand Equal Pay for Work of Equal Value
Working conditions are just one of the factors employers must assess under the EU Pay Transparency Directive. Watch our on-demand webinar to learn how job evaluation, pay transparency, and compensation strategy come together in practice.
