Better Europe Alliance

Transcription

1 Better Europe Alliance Irish Civil Society Organisations for a Social and Sustainable Europe Response to 2014 Country Specific Recommendations for Ireland July 2014 The Better Europe Alliance, Irish Civil Society Organisations for a Social and Sustainable Europe, involves a range of social and equality NGOs, the Environmental Pillar and the SIPTU trade union. The members of the Alliance are affiliated to organisations involved in an EU level Alliance. The overall objective of the Alliance is to strengthen progress towards the social and environmental goals of the Europe 2020 strategy and to improve the level debate and engagement of all stakeholders in progressing the Europe 2020 Strategy and the European Semester. The Alliances at EU and Irish level are coordinated by the European Anti-Poverty Network (EAPN) with support from the European Commission. The members of the Better Europe Alliance are: Disability Federation of Ireland National Association of Building Cooperatives Environmental Pillar National Women s Council of Ireland EAPN Ireland SIPTU Irish National Organisation of the Unemployed Social Justice Ireland National Adult Learner Agency For further information contact: Paul Ginnell, EAPN Ireland, Equity House, 16 Upper Ormond Quay, Dublin 7. Tel: ; paul@eapn.ie

2 1. Introduction Contents 1. Introduction 2. What is the EU Semester and Europe 2020 Strategy? 3. General Comments on Recommendations 4. Analysis of specific Recommendations Recommendation 1: Macroeconomic Goals Recommendation 2: Cost of Health Recommendation 3: Employment and unemployment Recommendation 4: Low-work intensity households Recommendation 5: SME Sector Recommendation 6: Banking Recommendation 7: Cost of legal services On 2 nd June 2014 the European Commission published its Country Specific Recommendations for all EU Member States. i There are seven Country Specific Recommendations for Ireland and these are accompanied by a more detailed Commission Staff Working Document. ii Since this process started in 2011, Ireland has been in a Troika programme during which its only recommendation each year was to implement its Memorandum of Understanding with the European Commission. 2. What is the EU Semester and Europe 2020 Strategy? The European Semester is the annual reporting and coordination process at EU level from whereby EU Member States, under the coordination of the European Commission, work together towards agreed, economic, social and environmental goals. iii The economic goals are agreed as part of the Growth and Stability Pact and these are binding, while the social and environmental goals are part of the five targets agreed to as part of the Europe 2020 Strategy for smart, sustainable and inclusive growth. The five Europe 2020 targets are: 1. Raise to 75% the employment rate of women and men aged Spend 3% of GDP on research and development. 3. Reduce greenhouse gas emissions by 20% by 2020, increase the share of renewables in energy consumption by 20% and move towards a 20% increase in energy efficiency. 4. Reduce school drop-out rates to less than 10% and increase the share of years old having completed tertiary or equivalent education to at least 40%. 5. Lift at least 20 million people out of risk of poverty and exclusion by The Irish Government has agreed on national targets to contribute to the overall EU targets and these are reported on annually in the National Reform Programme. Commitments at EU level will have a direct bearing on the policies being implemented at national level. To date the Alliance strongly believes that the process has been driven by economic goals and dominated by austerity policies, which have undermined the strategy and the social and environmental goals. Page 2 of 18

3 3. General Comments on Recommendations The Better Europe Alliance believes that economic and financial considerations dominate the 2014 Country Specific Recommendations for Ireland. This is reflected in the macroeconomic objectives set out in the first Recommendation and then sets the tone for how issues such as health and access to the legal system are addressed. However, some of the objectives, if implemented in a positive manner, could bring about improved social and environmental outcomes. This relates in particular to elements of Recommendation 1 and Recommendations 3 and 4. For this to happen, it is essential that measures taken to implement budget deficits in Recommendation 1 take into account their social and environmental impact. However there is a real danger that achieving the budget deficit and debt thresholds outlined in the Growth and Stability Pact can have the effect of undermining the commitments signed up to in the Europe 2020 strategy aimed at bringing about smart, sustainable and inclusive growth. Since the introduction of Europe 2020 strategy consistent poverty in Ireland has increased from 4.2% to 7.7% of the population. iv The impact of Ireland s economic recession is evident in the rise of poverty and deprivation and it is essential to ensure the policies that are pursued to restore fiscal stability and to bring about economic recovery do not exacerbate the difficulties being experienced by the most vulnerable. This document outlines shortcomings in the current policy approach and points to improvements that need to be made. The Recommendations also present a somewhat disjointed approach, lacking any sense of strategic direction which would support a balanced approach to achieving both the goals of Europe 2020 and the Growth and Stability Pact. What is missing? The Country Specific Recommendations (CSR) do not include recommendations on some key areas which should be addressed if Ireland is to bring about balanced smart, sustainable and inclusive growth. This includes the areas of climate change, resource efficiency, poverty reduction, gender mainstreaming, pensions and access to quality housing, health and long term care. The overall goal of the European Semester and Europe 2020 must be on improving the wellbeing of all people in Ireland and the EU. It is important therefore that the European Semester process is put back on track and is genuinely focused on delivering a balanced and coherent approach with economic, social and environmental policies complementing and supporting each other. The CSR do not address the 2020 targets for containing climate change. The headline of smart, green, inclusive growth is in danger of being abbreviated to a narrow version of growth with little regard to longterm social or environmental sustainability. Greater care must be taken to ensure that the mistakes that led Page 3 of 18

4 us to a European-wide recession, the disintegration of the banking sector, the resulting fragmentation of economies and the weakening of the Euro itself must not be repeated. It is very surprising that there is no mention of the property market within the Country Specific Recommendations, with the exception of a brief mention of property taxes. The potential of the property market (and housing in particular) to cause serious economic disturbance is also omitted from the economic overview. This is despite the European Commission recognition that the collapse of the property market was the cause of the wider economic collapse v and the current housing crisis with a lack of affordable and social housing in many areas and rapidly increasing house prices in areas such as Dublin. While house values can be expected to recover somewhat from dramatic falls during the property crash, rapidly rising house prices pose a serious risk to the macroeconomic situation if left unchecked for a longperiod, not just because of the risk of a speculative bubble but because of the significant impact that housing affordability has on the well-being of individuals. Currently there is a dearth of supply compared to the level of demand for social and other forms of housing. This issue must be addressed as a social priority and in order to dampen the pressure on prices, in the context of responsible planning requirements and other supportive measures. Labour market mobility, for example, is seriously undermined by lack of access to affordable housing options. Similarly, households trapped in poor quality or over-crowded housing because of affordability issues experience worse educational and health outcomes. Page 4 of 18

5 4. Analysis of specific Recommendations The following are the Better Europe Alliance comments on Recommendations 1 7 taking account of the Commission s Staff Working Document. Recommendation 1: Macroeconomic Goals What it says Fully implement the 2014 budget and ensure the correction of the excessive deficit in a sustainable manner by 2015 through underpinning the budgetary strategy with additional structural measures while achieving the structural adjustment effort specified in the Council recommendation under the Excessive Deficit Procedure. After the correction of the excessive deficit, pursue a structural adjustment towards a medium-term objective of at least 0.5% of GDP each year, and more in good economic conditions if needed to ensure that the debt rule is net in order to put the high general government debt ratio on a sustained downward path. Enhance the credibility of the fiscal adjustment strategy, effectively implement multi-annual budgetary planning and define broad budgetary measures underlying the medium-term fiscal targets. Make the government expenditure ceiling more binding by limiting the statutory scope for discretionary changes. To support fiscal consolidation, consideration should be given to raising revenues through broadening the tax base. Enhance the growth and environmental friendliness of the tax system. Better Europe Alliance Analysis This Recommendation is dominant in that it influences the implementation of all other recommendations. It outlines the path Ireland has to take to comply with the commitments made in the Fiscal Treaty on budget deficits and debt and the annual targets to achieving these that are outlined in the Irish Stability Programme. The Commission highlights that achieving these targets will involve both a certain level of economic growth and continuing to implement reductions to government expenditure and/or increased taxation. If the Government continues with its current approach to achieving its economic targets, then the result will be continued austerity in Ireland at least until The Alliance therefore strongly believes that if the Government is to enhance the credibility of the fiscal adjustment strategy this must mean greater social credibility. Otherwise the result will be greater in order to combat poverty and social exclusion and to allay increased public disquiet with the direction being taken. The Alliance is extremely alarmed by the statement to make the government expenditure ceiling more binding by limiting the statutory scope for discretionary changes. While the Alliance supports the principle of greater transparency in discretionary spending, imposing restrictive expenditure ceiling runs counter to the Europe 2020 Strategy vision of smart, sustainable and inclusive growth. It will also prevent Europe Page 5 of 18

6 addressing core issues such as poverty and inequality, unemployment, long term care, pensions, environmental degradation and the necessary investments in reducing the carbon footprint of Ireland. The Alliance calls for all expenditure and tax measures to be submitted to a process of poverty, equality, gender and environmental impact assessment. This process must be transparent and clearly outline the link between the impact assessment and the decisions being made. A detailed ex-ante social and environmental sustainability impact assessment would help generate an understanding of the interaction between social, environmental and economic and policies. The pending introduction of a new positive duty for public bodies in relation to equality should strengthen and support increased use of such approaches. The Alliance agrees with the proposal to broaden the tax base which is necessary to fund social and public services and particularly supports the need for taxation measures to avoid negative environmental harm, and the removal of subsidies for environmentally harmful activities. The Commission Staff Working Document highlights Irish tax to GDP at 28.7% in 2012 compared to an EU average of 39.4%. vi The lower levels of taxation are mainly related to the areas of social insurance and corporate income. The Alliance believes that over the next number of years Ireland needs to increase its taxation levels closer to the EU average. We are however aware of additional taxes since 2012 and the burden of taxation on those on the lowest income has significantly increased their cost of living over a short period of time. Increasing taxation levels must therefore be based on the following principles: The focus must be on strengthening the fairness and progressiveness of the taxation system, which must reduce inequality and avoid environmental harm. This includes a more progressive effective tax rate, broader than just in the area of income tax. Those who have benefited the most from the present system and are furthest from the risk of poverty should contribute the most, this includes the corporate sector. Additional taxation must be addressed through ongoing review and cost-benefit analysis of tax expenditures, as proposed by the European Commission, including consideration of standardisation and the elimination of tax expenditures with little environmental, economic or social benefit. In broadening the tax system there is a need to find an appropriate balance to reflect both environmental and social goals, for example in terms of carbon taxes and water charges. The polluter pays approach must be part of tax policy. There must be a focus on addressing the effective corporation tax rate paid by companies. There is a need for a wealth tax based not just on income but also on all other financial and fixed assets. vii A financial transaction tax should be introduced to provide additional revenue for delivery of services which have been cut back over the last decade. Page 6 of 18

7 Recommendation 2: Cost of Health What it says Advance the reform of the healthcare sector initiated under the Future Health strategic framework to increase cost-effectiveness. Pursue additional measures to reduce pharmaceutical spending, including through more frequent price realignment exercise for patented medicines, increased generic penetration and improved prescribing practices. Reform the financial management systems of the national health authority to streamline systems across all providers and to support better claims management. Roll out individual health identifiers starting in January Better Europe Alliance Analysis The focus of Recommendation 2 is on cost-effectiveness. The Alliance agrees with proposals to address the cost of medicines, including ensuring access to more generic medicines. It is essential that the focus on cost-effectiveness and savings in the area of health does not result in making health services less accessible or effective. Any further savings should be consistent with the vision in the Healthy Ireland framework which is of a Healthy Ireland, where everyone can enjoy physical and mental health and wellbeing to their full potential, where wellbeing is valued and supported at every level of society and is everyone s responsibility. viii This framework recognises the need to reduce health inequalities. This can be done through a range of measures including ensuring adequate investment in health services, equal access, systematic reporting, monitoring and political accountability. ix The objective of improving health outcomes, particularly among disadvantaged socio-economic groups, should be central to reforms in the health sector and in other fields that contribute to quality of life e.g. housing, transport and planning. Gender Mainstreaming should also be at the heart of any reform of the healthcare sector. Recent research and pilot initiatives within the HSE have again confirmed that this approach leads to better health outcomes for men and women and therefore medium term cost savings. Cuts to the health service over the past number of years have had a serious impact on access to services. A narrow focus only on cuts as a means of achieving cost effectiveness in health services results in a displacement of costs to other areas of the health service or to other departments and in negative outcomes for those with health needs. Such an approach is not only ineffective it can also prove inefficient, leading to longer term increase in healthcare costs. Cuts to the health budget over the past number of years have adversely affected access to services. A focus only on cuts as a means of achieving cost effectiveness in health services results in a displacement of costs to other areas of the health service or to other departments and in more negative health outcomes for those with health needs. People working in the health service have also endured salary cuts and changes in Page 7 of 18

8 working arrangements. Staff are under considerable pressure, doing more with less and it is not sustainable to target further savings from payroll beyond what is agreed in the Haddington Road Agreement. The Alliance believes that the principles for bringing about cost effectiveness must address the following: The goal should be to develop a universal health care model for Ireland. Cost effective measures should include increase the provision of preventative, community and primary care approaches in the delivery of health service. Cost effectiveness must avoid a situation where savings in provision result in increased costs in other areas or in negative health or social outcomes. Cost reductions can be achieved by removing the environmental causes of ill-health such as dirty domestic fuels. The introduction of a unique health identifier for each person in the population and for each healthcare provider has the potential to generate significant administrative efficiencies through streamlining and transparency. Building on this development, the health information system should be at the heart of health planning and policy and be further enhanced to allow for more comprehensive data collection on outcomes for different social categories so as to address health inequalities and specific needs relating to gender, age, ethnicity, disability and age. Page 8 of 18

9 Recommendation 3: Employment and unemployment What it says Pursue further improvements in active labour market policies, with a particular focus on long-term unemployment, the low-skilled and in line with the objectives of a youth guarantee, young people. Advance the on-going reform of the further education and training (FET) system, employment support schemes and apprenticeship programmes. Offer more workplace training; improve and ensure the relevance of FET courses and apprenticeships with respect to labour market needs. Increase the level and quality of support services provided by the Intreo Labour offices. Put in place a seamless FET referrals system between Intreo offices and Education and Training Boards. Better Europe Alliance Analysis Active labour market policies which support people into employment must be closely linked to labour market conditions, addressing the quality of working conditions of employees and ensuring that people can progress towards quality jobs. Currently there is a shortage of jobs, particularly for those with lower skills levels and alongside this is a growth in precarious jobs. Availability of jobs also differs depending on location. Moreover while a job can provide a route out of poverty this is not always the case. As of 2012 one in eight of those at-risk of poverty was at work. x The Alliance supports the proposal to increase the level and support provided by Intreo and also on the need for a seamless referral system between Intreo and the Education and Training Boards. We fear however that the tone and focus of Recommendation 1 throws up serious obstacles to implementing this Recommendation. There are also a number of issues that need to be addressed if the Recommendation is to be implemented in a positive manner. These include the following. Supports need to be provided in a positive and enabling culture rather than an over-emphasis on control and sanction. While conditionality has a certain role to play in the reach and implementation of employment activation services, it currently dominates much policy and practice in this area. This emphasis often neglects opportunities to support positive motivation or facilitate voluntary engagement with activation services. Control and sanction should therefore be a last resort after all other avenues have been exhausted and the client is refuses to engage constructively. The State needs to fully take on its responsibility to ensure unemployed people and others distant from the labour market are supported to access the most meaningful progression option for them. There is a need for greater balance and recognition of the mutual and respective obligations of the State, the person accessing the service and any potential employer. For example in the case of employers, this Page 9 of 18

10 might indicate an obligation to provide decent jobs for decent pay - no-one should be activated into insecure or poorly paid employment. While many Intreo staff provide a good service, in general there is a need to improve the provision of quality support and information. Intreo staff must be trained in dealing with people who are unemployed who have multiple needs, such as addiction, mental health, literacy and numeracy issues and specific learning difficulties. There must be choices and options for all those who are accessing the service, with particular needs considered. Training around the intersection of care and employment and tackling of issues such as gender bias within certain employment sectors should also be provided. A strong emphasis on the live register and those on jobseeker payments within the activation and the public employment system are resulting in structural exclusion and effective discrimination against many of the groups and individuals disproportionately represented in low-work intensity households. This is a major inequity which must be addressed. It impacts most directly on people in receipt of the One Parent Family Payment and Disability Allowance who may wish to access activation or training opportunities on a voluntary basis. It also perpetuates a situation where individuals who become distant from the labour market are blamed while the system is at fault. An example of this is the European Youth Guarantee which should seek to offer opportunities and options for all young people and not just those on the Live Register. As the CSR encourages action in line with the objectives of the youth guarantee, it is also important to note that there is an explicit commitment that any training, education or employment opportunities under the guarantee must be of high quality. The Education and Training Boards should strengthen their engagement with people with intellectual disabilities and put in place relevant supports for inclusion in all programmes. Supporting people to move from welfare supports into work needs to be implemented within the context of a balanced active inclusion approach adopted by EU Member States. This involves access to adequate income and quality services and an inclusive labour market including decent work. This is relevant across all groups including the implementation of the Youth Guarantee. The reduced social welfare payment to those under 26 years old undermines this approach. In supporting people to move from welfare into work it is also important that a careful activation approach be taken, supporting the development of labour market attachment while giving due regard to care responsibilities. The Alliance welcomes the Commission s recommendation to enhance the apprenticeship system in Ireland. The benefits of dual learning combining practical work experience and formal education to enhance employability are well established in countries such as Germany and Austria where youth unemployment are at low levels. The potential to expand current provisions beyond the traditional Page 10 of 18

11 craft trades has been identified in a Report commissioned by the Department of Education. xi The Alliance urges action in this area without delay in order to establish common professional standards and career prospects in sectors such as hospitality, childcare, administration, the Green Economy, ICT etc. While access to a quality job often enhances a person s well-being, it is essential to underline the fact that a person s well-being is not defined by a person s employment status. This fact must be recognised in the provision of Further Education and Training supports. A strengthened focus on labour-market needs should not be allowed to obscure or override an educational focus on the needs of the student or citizen and their personal development or long term progression. Providing positive opportunities for learning, training or work experience should enhance wellbeing and create the conditions for increasing a person s self-motivation and personal and social engagement whether or not they are in a position to transition to employment. Research has shown that persons with low levels of education remain at greater risk of unemployment and find it harder to progress in the workplace. The current Adult Literacy Service delivered by the 16 local Education and Training Boards (ETBs) offers individuals between two and six hours per week this is the equivalent to two or three week s full-time education a year. Whilst this is an important level of service for the wider community, it is simply not enough time to improve a person s basic skills for employment purposes. We need a new intensive adult literacy programme for people who are unemployed with low educational attainment to enable people to improve their education and be in a better position to move out of long term unemployment. Page 11 of 18

12 Recommendation 4: Low-work intensity households What it says Tackle low work intensity of households and address the poverty risk of children through tapered withdrawal of benefits and supplementary payments upon return to employment. Facilitate female labour market participation by improving access to more affordable and full-time childcare, particularly for low income families. Better Europe Alliance Analysis The Alliance supports the tapering withdrawal of benefits and supplementary payments as people on social welfare payments return to paid employment. This approach should help address issues of poverty traps but must be carried out in the context of ensuring adequate income and services for those in or out of work. The Minimum Essential Standard of Living developed by Vincentian Partnership for Social Justice presents the minimum income levels necessary for a number of different family types to have a decent standard of living. xii The Alliance makes the following points in relation to the recommendation on low work intensity households. Addressing child poverty must involve a holistic approach across a range of policy areas. Measures to address the low work intensity of parents are only one dimension. xiii The Recommendation does not deal with structural inequality which acts as a barrier to the full social and economic participation of many people. In this context we urgently need measures to address discrimination and the particularly low employment rates of certain groups and communities. Implementing the Recommendation must be in the context of an active inclusion approach ensuring access to adequate income, quality services and an inclusive labour market. It must also involve addressing the range of barriers faced by those distant from the labour market. One group who face significant barriers are Qualified Adults who are not only distant from the labour market but distant from the Social Protection system as most, in the absence of individualisation, do not claim payments in their own rights and are excluded from access to a majority of activation supports. Recognising the potential of Qualified Adults increases the options for low work intensity households. Access to training or labour market activation could be opened up on a voluntary basis, recognising care responsibilities by piloting part-time activation schemes and increasing childcare access. Many low-work intensity households, particularly those with children, are caught in a cycle of social welfare payments and poorly paid employment, which is often precarious. Many individuals in lowwork families often suffer from low self-esteem. If this cycle is not broken through positive activation Page 12 of 18

13 and in particular lifelong learning measures, alongside addressing the issue of quality work, it is hard to see how any serious anti-poverty targets can be achieved. The state also needs to seriously address what people can do who for specific reasons will never be employed, for example, how to facilitate greater access to volunteering. Access to affordable Childcare The Alliance strongly supports the recommendation to improve access to affordable childcare as one essential measure to improve female labour market participation. Ireland s ongoing failure to provide adequate, accessible and affordable childcare makes it difficult for parents, and women in particular, to access or retain employment, as recognised by the Commission Staff Working Document. Alongside addressing childcare costs it is also essential to ensure that childcare provision is of high quality and that staff have the relevant qualifications and the opportunity to progress in their profession. In order to achieve these goals it is necessary that there is public investment in ensuring that quality childcare is available. State supports help reduce costs and ensure affordability. In addition to the strong economic arguments for increasing public investment in quality childcare, as it facilitates greater retention and take up of employment, xiv there are also long term benefits from investment in the development of children. Currently, public spending on childcare and early education in Ireland as a percentage of GDP is amongst the lowest in Europe or the OECD and private childcare costs are amongst the most expensive anywhere. The lack of affordable and accessible childcare pushes many families below the line economically and women in particular often feel that they cannot afford to seek or stay in employment. This can be seen in 2011 CSO figures on labour market participation for men and women age While participation for men and women without children was almost equal at 85%, with a youngest child under 3, women s participation rate plummeted to 57% and even after a youngest child has reached 6 or over, women s participation still remains at only 58%. It is important to recognise that care work delivered within the home does make its own social and economic contribution and greater balancing of care and work for both men and women should be accommodated within both workplaces and family leave policies. However the current childcare situation leaves many women without options. The huge take up of the ECCE free year of pre-school education highlights that many women do make different choices when childhood care is supported. A second year of ECCE is needed and provision and promotion of appropriate out-of-school-hours and afterschool care is also essential. Page 13 of 18

14 Access to childcare can be a particularly serious obstacle for those in low paid employment and for loneparents. This is one reason why public provision offers a more appropriate solution than tax relief. A specific review on Accessibility and Affordability in Childcare has been planned for a number of months and should now press ahead. The Preschool Quality Agenda is also important and should be regarded as just a first step in a reform programme to support professionalisation of childcare, guaranteeing good pay and conditions and ensuring that staff have both the relevant qualifications and the opportunity to progress in their profession. Page 14 of 18

15 Recommendation 5: SME Sector What it says Develop further policy initiatives for the SME sector including policy initiatives to address the availability of bank and non-bank financing and debt restructuring issues. Advance initiatives to improve SME's access to bank credit and non-bank finance. Introduce a monitoring system for SME lending in the banking sector. In parallel, work to ensure that available non-bank credit facilities, including the three SME funds co-funded by the National Pensions Reserve Fund, Microfinance Ireland and the temporary loan guarantee scheme, are better utilised. Promote the use of these and other non-bank schemes by SMEs. Enhance the Credit Review Office's visibility and capabilities in mediating disputes between banks and prospective SME borrowers who have been refused credit. Better Europe Alliance Analysis The Alliance supports the need to ensure SMEs have access to credit and financing. In relation to the Recommendation it is important to fully understand why SMEs are not accessing the credit facilities that are available. The Alliance supports the Jobs Plus scheme, which provides a grant to employers who employ someone who is long term unemployed. The Alliance also notes the stated intention of the Government to open up a substantial investment fund targeting SME s. It is however important that any such incentives or investment be recognised as social transfers from public finances to private companies. It is therefore essential that there is complete transparency in the allocation and use of these funds. It is also essential that there are clear standards of best practice are promoted in these companies across all areas of operation, including their recruitment, employment and environmental practices. It is important that the focus is on investment as opposed to subsidies. The newly established Strategic Investment Fund (absorbing the National Pensions Reserve Fund) should be swiftly deployed, providing a route for SMEs and other companies to gain financing for strategic projects. There is considerable scope for the SME sector and, in particular, social enterprise to gain access to finance through the Credit Union movement. However, increased regulation that was necessary to ensure the ongoing viability of the banking sector is having the effect of undermining the long-term sustainability of the Credit Union movement. One consequence is a failure to achieve potential levels of lending support to the SME sector. Almost half of the increase in employment in 2012 and 2013 was in self-employment and many people who are unemployed are encouraged to take up the Back to Work Enterprise Allowance and to enter self- Page 15 of 18

16 employment. This move involves a high level of risk and a lack of security for many of those who make this move, directly impacting on their access to social supports if their enterprise fails. It is also a matter of some concern that recent restrictions have made it far more difficult for individuals to make Voluntary Social Insurance Contributions and therefore contribute to their long term security and Ireland s social insurance revenue, this particularly affects women who may be returning to the workforce after a period of absence and seeking to secure a future pension. The SME sector and new social enterprises can be supported to deliver better social and employment outcomes through greater participation in the public procurement process. In particular, the additional flexibility in Directive 2014/24/EU to promote professional integration for disabled and disadvantaged workers should be fully exploited. Social and/or employment clauses should be included in public contracts to ensure recruitment from the live register and/or other social goals. Pilots are already underway in this regard and should be expanded. In this context the roll-out of the recently transposed EU Directive 2010/41/on the application of equal treatment between men and women engaged in self-employment activity will also be an important development within those SMEs that are family businesses. This directive extends the liability and entitlement to social insurance contributions in order to ensure that a spouse or civil partner of a selfemployed person who is not a business partner or employee but performs similar tasks can benefits from social protection and insurance. Page 16 of 18

17 Recommendation 6: Banking What it says Monitor banks' performance against the mortgage arrears restructuring targets. Announce ambitious targets for the third and fourth quarters of 2014 for the principal mortgage banks to propose and conclude restructuring solutions for mortgage loans in arrears of more than 90 days, with a view to substantially resolving mortgage arrears by the end of Continue to assess the sustainability of the concluded restructuring arrangements through audits and targeted on-site reviews. Develop guidelines for the durability of solutions. Publish regular data on banks' SME loan portfolios in arrears to enhance transparency. Develop a strategy to address distressed commercial real-estate exposures. Establish a central credit registry. Better Europe Alliance Analysis The recommendation for mortgage arrears to be substantially resolved by the end of 2014 without further detail on the means to achieve this goal is alarming. Approximately 93,000 households are in mortgage arrears of greater than 90 days (Central Bank Q1 2014). These arrears are tackled through negotiated solutions such as restructuring or use of the Mortgage-to-Rent scheme, through personal insolvency, or through repossession of the dwelling. It is important to address shortcomings that emerge in relation to personal insolvency arrangements in order to reduce complexity; address cost barriers; ensure a fair and sustainable agreement for households who find themselves in difficulty and facilitate people to remain in their homes to the greatest extent possible. Any increased reliance on forced home repossessions, in the context of an extremely challenging housing market, would be very unwelcome. Recommendation 7: Cost of legal services What it says Reduce the cost of legal proceedings and services and foster competition, including by enacting the Legal Services Regulation Bill by the end of 2014, including its provision allowing the establishment of multidisciplinary practices, and by seeking to remove the solicitor's lien. Monitor its impact, including on the costs of legal services. Take executive steps to ensure that the Legal Services Regulatory Authority is operational without delay and that it meets its obligations under the legislation, including in terms of publishing regulations or guidelines for multi-disciplinary practices and the resolution of complaints. Improve data collection systems to enable quality and efficiency of judicial proceedings. Better Europe Alliance Analysis The Alliance agrees with the need to ensure that those on low income can have access to low cost or free legal services in order to ensure that everyone has equality in access to the law and in the vindication of their rights. In particular, the Aarhus Convention requires Ireland to provide access to Justice in relation to the environment: Each Party shall provide adequate and effective remedies, including injunctive relief as appropriate, and be fair, equitable, timely and not prohibitively expensive. xv Page 17 of 18

18 Notes i ii iii European Commission webpage iv CSO 2014, Survey of Income and Living Conditions v European Commission 2014, Results of in-depth reviews under Regulation (EU) No 1176/2011 on the prevention and correction of macroeconomic imbalances. depth_reviews_communication_en.pdf vi Eurostat vii Thomas A. McDonnell, TASC, Wealth Tax: Options for its Implementation In the Republic of Ireland. viii Department of Health 2013, ix ignore x CSO, Survey of Income and Living Conditions xi xii Vincentian Partnership for Social Justice, Minimum Essential Standard of Living. xiii EU Commission Recommendation 2013: Investing in children: breaking the cycle of disadvantage. xiv According to the OECD (OECD (2011), Doing Better for Families, Paris: OECD), for example, childcare supports are a key factor in the determination of maternal employment behaviour during the early years (p. 141). In its report Going for Growth: Economic Policy Reforms, the OECD highlights the fact that, in Ireland, women s labour market participation rates are well below those of best-performing OECD economies, especially for mothers, and high childcare costs and limited supply are major obstacles to participation. The European Pact for Gender Equality reaffirms the importance of integrating a gender perspective into all policies and particularly urges member states to improve the supply of affordable and high-quality childcare services and promote flexible working arrangements. xv Aarhus Convention, Article 9.4 In conjunction with the EU level Semester Alliance The Alliance is supported by the European Commission Page 18 of 18