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Yes
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I don’t believe the added paragraphs are sufficient to fully enforce the intent of this section. As such, I am proposing to modify paragraph 98 to also cover situations where the credit institution policies may not directly violate but indirectly violates the rights of the staff based on the prohibited bases and include marital status as an additional category.

Proposed edited version:
98. Credit institutions should have policies and monitoring that ensure that there is no direct or indirect discrimination of staff based on gender, race, color, ethnic or social origin, genetic features, religion or belief, membership of a nationality or minority group, property, birth, disability, age, or sexual orientation.


Paragraph 99 does not provide clear enough expectations of closing the gender gap as it does not include equal pay and ongoing oversight, which could create a risk where the credit institution closes the gender gap but the pay gap is unresolved (gender discrimination) or there is no ongoing and active monitoring to ensure the policies are being implemented appropriately.

Proposed edited version:
99. Credit institutions policies should be gender neutral and credit institutions should implement measures and oversight to ensure equal opportunities for all genders, including with regard to career perspectives, equal pay, and to improve the representation of the underrepresented gender in management positions.
Yes
Additional clarification is needed and data collection is needed.

I would recommend inclusion of additional guidelines or limits for secured vs. unsecured exposure credit exposure extended to insiders and also require annual submission of the related interest attestation from the members containing a list of all organizations in which they have regulatory significant interest in or are in a position to make or influence significant business decisions or impacting financial profitability of the related company.
Yes
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