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Attorneys we surveyed as of late August were unaware of any litigation or claims arising yet in relation to the state's wage disclosure law, and they had not yet seen any in their practices. e Wage and Workplace Standards Division at the state Department of Labor reported that as of late Au- gust, there were no complaints about violations of the wage disclosure law, according to department spokeswoman Juliet Manalan. Ensuring compliance Nick Zaino, a partner with law firm Carmody, Torrance, Sandak & Hen- nessey, who is principally based in Waterbury, said employers can comply with the law multiple ways. One is to put the wage range right in the job posting, he said. Some online postings have a place for applicants to click to get more information about the wage range. "e other way to deal with it is to put it in the offer letter," Zaino said. According to Zaino, some employers have decided to put the information directly in job postings because they have loca- tions around the country. Some states are passing legislation similar to what Connecticut has, while others are more stringent. Colorado, for example, requires all job postings to include the hourly or salary compen- sation. Some Connecticut employers that also operate in other states are putting the wage information in all of their postings to be consistent, he noted. Many employers prefer not to put it in the job posting, and put it in an offer letter, which Zaino said "is fine." Employers can help avoid running afoul of the law by doing an honest self-assessment, according to Strange. "What I would say to employers is — take a big step back, and look at how you pay in your workplace," Strange said. "Determine — do you have any pay equity issues overall? at's proba- bly your biggest concern." She suggested evaluating if you have jobs where men are being paid more than women for performing the same duties. Do the same self-assessment when it comes to other groups in your workplace, Strange advises. "at's what these laws are trying to get at — to have employers look and see what they are paying for the position, and if it is fair for everybody," Strange said. Lizz Acee, a partner at law firm Bar- clay Damon, said her firm recommends a pay equity audit and advises employ- ers to have formal job descriptions in place for their workers, along with salary ranges for each job. Competition and challenges Employers are encountering chal- lenges with the new law, legal experts said. ose challenges include competi- tion with other employers when trying to attract talent, and negotiating a salary they want to pay. "is (law) is a fairly new concept," Strange said. "I think employers are start- ing to try to figure out how to deal with it. What companies are struggling with is what does 'wage range' mean?" Employers may have the gut instinct to put out broad wage information, Strange noted. "e problem with that is — everyone you want to hire is going to want the highest of that range," Strange said. If candidates see an impressive, narrowly-defined wage range, they'll be more likely to apply, she added. "Employers can use this law to get a competitive edge," Strange said. Many Connecticut employers are looking at what their competitors are doing with their job postings when fash- F O C U S : L a w Nick Zaino ioning their own. According to Zaino, the main reason employers cite for not posting wage ranges directly in job listings is for "competitive reasons." So, is the wage disclosure law working the way lawmakers hoped? According to Zaino, it is hard to know, and probably too early to tell. "It has definitely forced employers to think about it," Zaino said. "And it is definitely requiring employers to revisit their compensation methodologies and strategies." n Lizz Acee

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