Pay Transparency Policy Statement

The contractor (Arnold & Porter Kaye Scholer LLP) will not discharge or in any other manner discriminate against employees or applicants because they have inquired about, discussed, or disclosed their own pay or the pay of another employee or applicant.  However, employees who have access to the compensation information of other employees or applicants as a part of their essential job functions cannot disclose the pay of other employees or applicants to individuals who do not otherwise have access to compensation information, unless the disclosure is (a) in response to a formal complaint or charge, (b) in furtherance of an investigation, proceeding, hearing, or action, including an investigation conducted by the employer, or (c) consistent with the contractor’s legal duty to furnish information. 41 CFR 60-1.35(c)

Good judgment and care must be exercised by all employees who have access to confidential pay information as part of their job responsibilities in any of the Firm’s departments to include but not limited to our Human Resources, Information Technology, and Finance & Accounting Departments. At all times, these employees should avoid unauthorized or improper disclosures.  It is the responsibility of each such employee to take whatever practicable steps are appropriate to preserve and protect the confidentiality of pay information.  A prudent guide is to resolve any doubts in favor of confidentiality and to avoid unnecessary discussions of pay.  No employee may access or attempt to access pay information, whether electronic or in some other form, at the Firm or residing on Firm equipment unless there is a business reason for doing so.  Any employees who violate this policy may be subject to further disciplinary action, up to and including termination from the Firm.