Regarding Title I, section 1, paragraph 26 of the Draft Guidelines
We would propose adding a detailed catalogue of criteria for gender-neutral job descriptions as an Annex referring to paragraph 26 of the Draft Guidelines.
Reasons:
We agree that uniform guidelines for job descriptions and positions are needed to implement gender neutral remuneration policies as set out in paragraph 26 of the Draft Guidelines. Nevertheless, we would like to suggest that a detailed catalogue of criteria should be included into the Guidelines on sound remuneration policies, based on which an investment firm has clear guidance for the creation of a gender-neutral job and position description. The aspects mentioned in paragraph 27 of the Draft Guidelines are certainly helpful in this respect. However, we understand that these aspects are only to be used in addition. In this respect, we consider that the inclusion of a detailed catalogue of criteria in the Guidelines should be necessary.