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The contribution of occupational pensions to a
sustainable pensions system from the employers’
perspective
European Chemical Industry Social Partners Conference
April, 2013, Dublin
Stefanie Lomb
© Bundesarbeitgeberverband Chemie
Who we are…
 BAVC =
The German Federation of Chemical Employers’
Associations
 Wage and social policy
 1.900 chemical companies
 550.000 employees
 11 regional member associations
 Large Section of Small and medium enterprises (SME)
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Starting point
Green Paper – White Paper – Directive on minimum standards –
IORP Directive
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European Commission: the driving force
Green Paper – White Paper – Directive on minimum standards –
IORP Directive
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7 July 2010 Green Paper: start public consultation
15 November 2010 end public consultation
16 February 2012 White Paper
1 March 2012 Public hearing IORP Directive
7 June 2012 hearing EMPL/ECON
6 December debate on draft reports
“fight for competences” EMPL/ECON
- ECON: Solvency
- EMPL: Minimum standards
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European Commission: the driving force
Green Paper – White Paper – Directive on minimum standards –
IORP Directive
 26 february 2013 vote ECON
(Rapporteur: Thomas Mann, EPP)
 21 March 2013 vote EMPL
(Rapporteur: Ria Oomen-Ruijten, EPP)
 April vote plenary
 2012/2013/2014: Revision Directive on minimum
standards and IORP Directive?
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EIOPA: advisor
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30 March 2011 Call for Advice COM to EIOPA
2nd half of 2011 public EIOPA consultations
15 February 2012 Advice EIOPA to COM
15 June 2012 Start public consultation on “technical
specifications” for a quantitative impact assessment (QIS)
 “Holistic Balance Sheet” approach which follows a Solvency
II logic
31 July 2012 end public consultation
2 October 2012 EIOPA sends “draft technical specifications” to
COM
16 October 2012 Start QIS
17 December 2012 end QIS
Spring 2013 QIS report EIOPA to COM
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What is at stake?
 Commission’s view on occupational pensions: financial products
that should freely circulate in the internal market
 Solvency II as a basis for regulating institutions for occupational
retirement provision (IORPs); “level playing field”
 Solvency II-like regulation would overstrain IORPs financially
(2nd pillar of the pension system)
 Initiatives already announced: revision IORP Directive (summer
2013), directive on the acquisition and preservation of
supplementary pension rights (2013)
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Solvency II:
Neither „good starting point“ nor „benchmark“
IORPS versus financial products:
Social institutions with a
non-for-profit approach
Employer
backed pension
systems
IORPs differ
considerably from
financial products
Highly
customized
and efficient:
high coverage
and low costs
Involvement of
employees in
supervisory
boards
Collective
elements
Longterm investments
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The concept of occupational pension schemes
Occupational pension schemes vs.
individual pension products of the financial markets:
 Occupational pensions are employer-backed pension concepts
 Long-term benefit plans and collective elements, no extensive
options for the beneficiaries
 No third party interests
 Safeguarding of employee and employer interests at the level of
labour law
 Employers and employees are represented on the bodies of the
pension funds to guarantee interests
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The employers‘ view
Improvement of Retirement age and statutory pension systems
 Careful distinction between the different pillars of the pension
system – statutory, occupational and individual pension schemes
 Principle of subsidiarity must be observed: reforms are up to
Member States
 More effective to convince people to work longer on a voluntary
basis and develop flexible working time models
 Long term pension reforms are better than several reforms that
lead to uncertainty among the employees (and at least employers)
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The employers‘ view
Improvement of Occupational Pension Systems
 Institutions for Occupational Retirement Provision (IORPs) are
social institutions organised by the employers and
employees (non-profit-organisations)
 IORPs do not sell any financial market products traded on the
free market. Occupational pension schemes do not cross
borders. There is no market for cross-border products of social
institutions and no added value compared to existing systems in
view of the manifold interfaces to national tax and social security
systems.
A pan-European “level playing field” is neither required nor does it
make sense.
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The employers‘ view
 Occupational pension schemes are a proven, reliable pillar of the
pension system which corresponds to the objectives in terms
of sustainability, safety, portability, and information
 Additional regulation of occupational pension schemes would
overstrain the institutions and carriers of occupational pension
schemes financially - however money must be invested
permanently f.e. in research and development to maintain the
company’s innovative strength in an competition pressure
environment
 Moreover additional regulation would only increase bureaucracy
and costs and would jeopardize the willingness of employers
to offer (higher) occupational pensions on a voluntary basis
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Effects of additional regulations
IORPs
Beneficiaries
Financial burdens and
overstrain
because of increasing
capital requirements
Lower future benefits,
because employers cannot
afford to increase its costs,
-> less efficient and attractive
Employers
Financial burdens and
competitive disadvantages,
if capital has to be set aside for safety
purposes and cannot be invested for
innovations and growth
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The formation of alliances is important
The promising approach: social partnership
 Common position paper ECEG (European Chemical Employers
Group) und EMCEF (European Mine, Chemical and Energy
Workers‘ Federation) (January 2011)
 Common position paper BAVC und IG BCE (October, 2011)
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Common position paper (September 2012)
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Our targets
 No additional regulations, especially solvency II based (HBS
approach or similar models)
 The social partners should be given more weight in the
consultation process, because the subject of the consultation
clearly concerns the “social policy field”
 Occupational pension schemes negotiated by the social
partners provide the best guarantee for people to receive an
adequate pension
 Tailor-made solutions should be carefully developed via social
dialogue - Indeed, a clearer role for social partners is required
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What’s next?
Initiatives to be expected:
Directive on minimum standards;
beginning 2013
IORP Directive;
mid-2013
Parliament and Council will be decisive –
and the social partners!
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Thanks a lot for your attention!
Bundesarbeitgeberverband Chemie e.V.
Abraham-Lincoln-Straße 24
65189 Wiesbaden
Telefon +49 611 77881- 0
Fax +49 611 77881- 23
[email protected]
www.bavc.de
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