Similarly, legislation is varyingly monitored and enforced by existing government bodies, separate public bodies or specifically established independent bodies or is unenforced.305 The imposition of penalties for non-compliance and the nature of the penalties themselves also vary from fines to bans on contract work for public entities, although penalties are recommended.306 In particular reference to pay transparency, it is clear that some cities, states and provinces do not apply a comprehensive pay transparency programme and instead mandate or encourage one of the three tenets of pay transparency – prohibiting employers from requesting a prospective employee’s wage or salary history, requiring that job advertisements include the expected compensation for the role and forbidding pay secrecy. This irregularity is possibly in relation to opposition from large businesses concerning competitive, high-level roles.307 Although the legislation in France, Iceland and Germany is too recent for valid results to have been collated, the relatively older policies of Australia, Denmark and the UK have seen signs of success, perhaps indicating a route of best practice.308 Significantly, research suggests that workplaces must be involved in their own solutions for ethnic pay gaps.309 However, there has also been indication from workplaces that, in some instances, particularly within smaller organisations, human resources departments do not have the means to provide extensive reporting.310 Therefore, it is recommended that governments or enforcing bodies engage in consultation with employers to establish the most effective policy.311 Specifically in terms of mandatory reporting, governments must take an active role in monitoring the information they gather.312 For example, the Canadian Government publishes extensive and detailed annual reports that synthesise findings based on employer reports.313 Finally, there is also a recommendation for setting targets and developing action plans to uphold commitments made by both workplaces and policy makers.314 305 Ministry for Women, Country Case Studies, 1-21. 306 Chifley Research Centre, Closing the Gender Pay Gap, 18-19; Ministry for Women, Country Case Studies, 2, 8, 17; Pay Transparency Act, 2018, chap. 5, (Ontario, Canada); Senate Bill No. 973, 2020, chap. 363 (California, United States of America). 307 New Zealand Human Rights Commission, Equal Pay and Pay Equity, 1. 308 Ministry for Women, Country Case Studies, 2-3, 6-7, 11, 14-15, 18, 21. 309 Brown, Rickard, and Broughton, Tackling Gender, Disability and Ethnicity Pay Gaps, 47-48, 50. 310 PricewaterhouseCoopers, Ethnicity Pay Gap Reporting, 3. 311 Equality and Human Rights Commission, Fair Opportunities for All, 26. 312 Equality and Human Rights Commission, Fair Opportunities for All, 26; Chifley Research Centre, Closing the Gender Pay Gap, 30. 313 Employment and Social Development Canada, Employment Equity Act, 3, 7. 314 Equality and Human Rights Commission, Fair Opportunities for All, 23; Chifley Research Centre, Closing the Gender Pay Gap, 30. Pacific Pay Gap Inquiry Literature Review 43