This is a selection of responses to the IIA. For the purpose of the simulation, please focus on these and do not read all responses on the Commission website.
03 February 2020 | Non-governmental organisation (NGO)
COFACE Families Europe (Belgium)
Equal pay for women and men is one of the cornerstones of Gender Equality and goes hand in hand with closing the gender care gap and supporting work-life balance. Hence closing the gender pay gap must be one of the key components of the next Commission’s Gender Equality Strategy, based on core European values of social inclusion and non-discrimination. This can only become a reality through comprehensive policies and legislation. Terefore, COFACE Families Europe welcomes the European Commission public consultation on the revision of the Directive 2006/54 to strengthen enforcement mechanisms and increase pay transparency.
03 February 2020 | Business association
Ceemet, the European Tech and Industry Employers across the EU, supports the objective of reducing the pay gap between men and women. Actual pay discrimination between men and women is unacceptable – and already prohibited by existing EU and national legislation. In the general discussion, pay differences between men and women are however often mistaken with pay discrimination. The often quoted figures are thus not an indicator of possible discrimination, because they compare non comparable jobs. Pay differences in comparable jobs, both in favour for men or for women, can be further explained due to performance related policies, individual engagement of the worker, more relevant experience, but not due to gender.
03 February 2020 | Trade union
CEC European Managers (Belgium)
For CEC European Managers, the European social partner organization representing the European managerial workforce, gender equality is fundamental. Improving the presence of women in the labor force, and especially in decision-making positions, is a priority that CEC has been focusing upon for many years. Gender pay gap is only one of the many ways in which discrimination is declined. Legal protection of the principle of “equal pay” (to which the persistence of gender pay gap clearly constitutes a violation) is sufficient: the scope of national, European and international law forbidding discrimination based on individual grounds is wide and solidly anchored as a fundamental legal principle.
03 February 2020 | Company/business organisation
In the world of cooperatives, which is not exempt from imbalances linked to the wage gap and to the different employment position of women, even though the percentage of female employees is close to the expected targets and despite a great advantage due to the co-operative entrepreneurial formula, where women find space and very broad professional expression, work is being done to better understand what actions can be taken to remedy unequal economic measures, in different geographical areas, in different production sectors, and for the management of work/life balance, entrepreneurial development and financing possibilities, etc.; this is done through surveys and studies, as well as through training and ad hoc seminars.
03 February 2020 | Business association
Closing the gender pay gap is an important challenge linked to many underlying factors. SMEunited is committed to promote the equal pay principle and to combat all forms of discrimination at the workplace. However, the gender pay gap is broader than the concept of equal pay for equal work or work of equal value, making it a complex issue to tackle. Therefore, it is crucial that the gender pay gap debate is based on evidence and facts and that a more holistic approach is taken to address the root causes. Accordingly, there is a need for a more hands-on approach through social dialogue, moving away from a punitive approach focused on sanctions.
03 February 2020 | Public authority
French labour ministry (France)
The French authorities welcome the European Commission’s proposed initiative on the transparency of pay between women and men. Equality between women and men must be a priority for the European Union, because of the values shared by all Member States, but also for economic reasons in view of the economic loss induced by the employment gap between women and men. In this context, France has adopted a law in 2018 for the freedom to choose one’s professional future in which framework we have created a Professional Equality Index which sets up an obligation of results for companies with 50 or more employees. This tool, based on four or five indicators depending on the size of the company, makes it possible to provide an objective measurement of professional equality within the company.
03 February 2020 | Company/business organisation
Confederation of Danish Employers (Denmark)
The Confederation of Danish Employers shares the view of the European Commission that there is a case for addressing equal pay issues at the European level. Pay transparency can be a useful tool if it is used wisely. However, specifically on this tool, the Commission should not impose a rigid and detailed transparency measure which disrupts the right to negotiate wages freely. In many EU member states, wages are negotiated either by individual workers or as part of a collective agreement. If the Commission decides to address equal pay through a directive, it is crucial that this is done in a manner which allows for country-specific approaches and initiatives.
02 February 2020 | Non-governmental organisation (NGO)
EU Delegation Make Mothers Matter (Belgium)
Pay transparency is a tool against the gender pay gap, but it is not the final aim and it does not solve the internal causes of the gap. In fact, the underlying cause of the gender pay gap arises from the unequal distribution of unpaid care work. The wage gap between men and women cannot be solved without substantive action on care work, both paid and unpaid, most notably undertaken by mothers. Without transparency, it will not be possible to compare salaries and provide proof for redressing inequalities through legal complaints. We believe that pay transparency, understood as the right for employees to be informed of pay levels in their workplace, is a good tool to be implemented in combination with others.
31 January 2020 | Public authority
Netherlands Institute for Human Rights (Netherlands)
With interest the Netherlands Institute for Human Rights has taken note of the European Commission’s initiative to assess the possibility of developing a binding instrument regarding pay transparency. The Institute regards it an important and first step for individuals to be able to request information about payment from their employers. Such may empower them to ensure their right to equal pay. At the same time, to address the issue of wage discrimination earnestly and effectively, employment organisations should at least be required to comply with their already existing legal obligations. Such compliance can be enhanced when employers are obliged to provide transparency on pay.
31 January 2020 | Trade union
EPSU – European Public Service Union (Belgium)
EPSU welcomes the road map for the initiative “strengthening the principle of equal pay between men and women through pay transparency” because closing the gender pay gap is a matter of urgency and priority. Pay transparency can play a crucial role in ensuring substantial progress in addressing the gender pay gap. It helps unveiling the systematic undervaluation of women’s work at the heart of the persistent gender pay inequalities. It highlights the feminisation-segregation of occupations and the insufficient appreciation and remuneration of the work performed by women in specific jobs or whole sectors. Thus, EPSU welcomes and encourage the European Commission to introduce compulsory measures such as staff rights to information.
31 January 2020 | Company/business organisation
Confederation of Swedish Enterprise (Sweden)
The Confederation of Swedish Enterprise are staunch advocates for greater work life equality. It is our firm conviction that achieving greater gender equality is essential for the realization of the full potential of all individuals and undertakings. Research shows that workplaces where both men and women work achieve better business results and build better workplace communities. As regards the wage gap, as the situation differs greatly between the member states of the EU, there are no one-size-fits all solutions. Priorities and measures have to be set according to the specific needs, conditions and prevailing culture and attitudes in the different national labour markets. Sweden has the highest female labour market participation rate in the EU, resulting from decades of active policy and individual preferences and should be thus taken as an example.
31 January 2020 | Trade union
FH – FH- Danish Trade Union Confederation (Denmark)
FH – Danish Trade Union Confederation strongly support the aim to strengthen the principle of equal pay between men and women. The struggle for equal pay is a high priority to our unions/member organizations and their members and is constantly at our aim. The Danish gender pay gap is approx. 15 percent, and although it has moved slightly in recent years, it is moving very slowly. Hence, we welcome obligating member states to ensure pay transparency, and we are thankful for the opportunity to provide the Commission with our point of view on the matter. We endorse a better definition of the value of the work, as it will make it easier for our members to realize their rights and to pursue them with support from our unions/member organizations.
31 January 2020 | Business association
MOL Group supports the initiative of strengthening the principle of equal pay between men and women. MOL makes concrete steps to ensure equal treatment and overcome any unconscious biases in selection and hiring process. We put our people first and there is no differentiation between men and women when it comes to salaries or promotions/job applications. When we are talking about transparency we need to consider data protection and sensitivity of pay strategies in the market competition. It has to be well considered what is possible and worth to publish and what mechanisms should ensure consistent use of the defined metrics. As in terms of daily process management within large companies with hundreds of job roles, job types, feasible needs to be built up focusing more on reporting and policy making.
31 January 2020 | Other
Bundesarbeitskammer Österreich (BAK) (Austria)
The Federal Chamber of Labour thanks you for the opportunity to provide feedback on the important topic of income transparency. We see gender equality as an essential element of a socially just society. In particular, the unequal pay of women and men must be brought into focus. Pay transparency is an important approach to combating the gender pay gap. The Commission Recommendation of 7 March 2014 on strengthening the principle of equal pay for women and men through transparency includes important measures that would contribute significantly to fair pay: a) the right of workers to information on pay levels; b) regular reporting by employers on wages and salaries, broken down by groups of workers or positions; c) the clarification of the concept of work of equal value.
30 January 2020 | Business association
BDA | Bundesvereinigung der Deutschen Arbeitgeberverbände (Germany)
BDA is the leading organisation dealing with social policy on behalf of the entire German private sector. It represents the interests of small, medium-sized and large companies in all sectors and all issues linked to social policy and collective negotiations, labour legislation, labour market policy and education. Employers underline the importance of not mixing up the overall (unadjusted) gender pay gap (i.e. 16 % – as outlined here by the EU Commission) with the concept of pay discrimination. BDA highlights that the current legal framework is sufficient to protect individuals from pay discrimination. The gender pay gap can only be durably closed if the root causes are addressed and framework conditions are put in place which further upgrade the professional activity and career opportunities for women.
30 January 2020 | Other
National Commission for the Promotion of Equality (NCPE) (Malta)
The National Commission for the Promotion of Equality acknowledges that pay transparency should be mandatory as it enables employees to identify discrimination and to access justice. Binding measures providing for transparency in pay and pay systems will indeed strengthen the implementation of the equal pay principle. Employees should have the right to request information about their pay and how it is reflected in the pay system. In this regard, a clear definition of the concept ‘equal pay for work of equal value’ is required. The proposed Directive can recommend various measures that are applicable to organisations according to their size, as per the 2014 Recommendation. This Directive can also strengthen the role of equality bodies to ensure that proper enforcement can be carried out for its effective implementation.
30 January 2020 | Business association
Wirtschaftskammer Österreich (Austria)
The Austrian Federal Economic Chamber (WKÖ1) is committed to the goal of reducing the gender pay gap. However, we are expressly opposed to mandatory pay reporting at European level. Austria has already introduced pay reporting for companies with more than 150 employees, which has resulted in a considerable additional administrative burden for these companies, as the preparation of such reporting has had to be outsourced to external payroll. If companies with less than 150 employees were also required to prepare pay reporting, this could lead to comparison groups not being large enough, thus allow drawing conclusions on individuals. This would no longer guarantee anonymity and therefore constitute a breach of data protection.
25 January 2020 | EU citizen
I very much agree with this initiative. Without infringing on the confidentiality of information, it would be possible, for example, to publish tables of average staff salaries (including hourly, for example, to sterilise the effect of part-time work) and above all the average grading (contractual levels) to see what the gender mix is according to levels of responsibility. All too often women end up in almost all-female groups in administration or similar, while technical and command areas remain off-limits to them. How much potential is lost! Perhaps certificates on transparency and internal equality could be awarded.
24 January 2020 | Trade union
Julkisten ja hyvinvointialojen liitto JHL ry (Finland)
The Public and Welfare Sector Association JHL considers the initiative very important. Effective measures need to be taken urgently to reduce the gender pay gap. Wage knowledge plays an important role both in advancing equal pay and in detecting pay discrimination.In the opinion of JHL, in order to reduce the pay gap, pay transparency should be extended to all sectors as well as the salaries of employees, salaried employees and management. In addition, pay transparency should apply to all pay components (all cash benefits). It is also important to define work of equal value so that wages can be better compared. Legal certainty must be increased so that unjustified pay gaps can be resolved quickly and cost-effectively. This requires an increase in low-threshold remedies. It is also appropriate to develop provisions on the burden of proof in order to increase legal certainty.
22 January 2020 | Business association
HOTREC is the umbrella Association of hotels, restaurants, bars and cafés in Europe, which brings together 45 national associations in 33 European countries. HOTREC fully supports the idea that men and women developing the same work with the same performance shall be paid equally. HOTREC believes that the principle of “Equal pay for equal work or work of equal value” is well addressed both at EU level and national legislation in the different Member States. For this reasons, HOTREC considers that no further legislation is needed on the matter. Correct enforcement of the existing legislation should be the goal to achieve. HOTREC also concludes that when studies where developed, conclusions show that the measures, such as the ones included in the Commission Recommendation (2014/124/EU),did not have a real impact on the internal salary schemes of the companies.