Response to consultation Paper on Draft Guidelines on sound remuneration policies under Directive 2013/36/EU
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In the definition of “Gender pay gap” we propose to replace “earnings” with “remuneration” (earnings are not defined in the document) and “hourly” with “monthly/yearly remuneration”. Hourly earnings are not commonly used in the financial sector. Moreover, remuneration of employees is set on a monthly basis, according to the Labour law.
Instead of documenting the job descriptions we suggest to focus on categories or groups of job positions (e.g. related to particular business lines, or products, or customer categories) in compliance with the proportionality principle. The proposed solution will make the documenting more practical for all the parties involved and at the same time will not adversely influence the monitoring target.
In the statement “determine which positions are considered as equal or of equal value per unit of measurement or time rate”, the wording “per unit of measurement or time rate” is not a fully clear concept, which in practice could complicate the measurement or comparison of banks in various settings.
Question 1: Are the amendments to the subject matter, scope and definitions appropriate and sufficiently clear?
Section 2, Definitions, paragraph 11:In the definition of “Gender pay gap” we propose to replace “earnings” with “remuneration” (earnings are not defined in the document) and “hourly” with “monthly/yearly remuneration”. Hourly earnings are not commonly used in the financial sector. Moreover, remuneration of employees is set on a monthly basis, according to the Labour law.
Question 2: Are the amendments regarding gender neutral remuneration policies sufficiently clear?
Section 4, Guidelines, paragraph 26:Instead of documenting the job descriptions we suggest to focus on categories or groups of job positions (e.g. related to particular business lines, or products, or customer categories) in compliance with the proportionality principle. The proposed solution will make the documenting more practical for all the parties involved and at the same time will not adversely influence the monitoring target.
In the statement “determine which positions are considered as equal or of equal value per unit of measurement or time rate”, the wording “per unit of measurement or time rate” is not a fully clear concept, which in practice could complicate the measurement or comparison of banks in various settings.
Question 3: Are the guidelines on the application of the requirements in a group context sufficiently clear?
yesQuestion 4: Are the guidelines regarding the application of waivers within section 4 sufficiently clear?
yesQuestion 5: Is the section 8.4 on retention bonuses sufficiently clear?
yesQuestion 6: Is the amended section 9 on severance payments sufficiently clear?
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