Pay Equity Report
Key is strongly committed to the principle of gender equity. Key is the nation's only large regional bank with a female Chief Executive Officer, has several prominent female executives on its Executive Leadership Team, and has strong gender diversity on its Board of Directors.
Key's commitment to gender equity extends to gender pay equity and we support this commitment by maintaining a formal pay structure, making pay decisions based on objective job-related criteria, and rigorously analyzing pay decisions that are made, as follows:
- First, we maintain a formal compensation structure to establish pay opportunity on the basis of objective factors such as external survey data, required education and experience. We regularly review this structure in light of market trends and internal equity. We also provide our employees with a clear sense of career progression.
- Second, we have a pay for performance philosophy in which pay decisions are based on the assessment of individual performance, business unit performance and the performance of Key. These decisions also consider performance against risk expectations and whether an employee has exhibited behaviors consistent with our values. We provide extensive resources and work closely with our managers to help them make equitable decisions about pay.
- Third, we regularly conduct robust statistical analyses of pay and performance decisions. The analyses compare compensation and performance ratings of employees in similar roles to assess whether males and females and minorities and non-minorities are compensated equitably. Where employee groups are large enough, a regression analysis is conducted to compare race and gender against variables which should impact pay (e.g., time in job, length of service, experience). Where employee groups are not large enough, a mean analysis is conducted analyzing average pay distributions. To the extent that statistical disparities are identified, further analysis is conducted to identify whether valid job related factors explain the disparity. Otherwise, the disparity is remediated. In our most recent review, differences were found for less than 0.5% of employees and adjustments were made to resolve the disparities. All other differences were determined to be based on job-related reasons, and no adjustments were necessary for those employees.
- In compliance with various state and local laws, salary history is no longer solicited from applicants in certain geographic areas which account for a substantial percentage of our geographic footprint. We are currently evaluating the impact of this growing regulatory trend and considering expanding the practice enterprise-wide.
We continually assess and enhance our practices. For example, the framework used to analyze pay discrepancies has been in place for more than 10 years, and it has evolved over this time to become even more comprehensive. Therefore, we believe our practices are an effective control to monitor and address pay inequities.