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There are many problems with the British equal value legislation, mostly the result of its complaint‐driven nature. Some Canadian provinces responded to a similar legal inadequacy with statutory pay equity – an employer‐driven approach. Most Canadian legislation covers the public sector; Ontario law also applies to the private sector. All provinces require pay equity bargaining in ununionised workplaces. Indications are that effective pay equity bargaining is separate and co‐operative, but equity maintenance may be undermined. However, the initial impact of the proactive schemes has been positive. For British women to benefit from this alternative approach,political will is crucial.

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