Nordic Financial Unions (NFU)

What NFU is missing in EBAs proposed Outsourcing Policy are procedures for informing and consulting with employee representatives if core competences are being outsourced to a service provider. Where applicable, collective agreements, or other arrangements provided for by social partners should be complied with in this regard.

NFU means that the draft Outsourcing Policy should include an impact assessment of how the planned outsourcing affects the employees of the home institution, including an assessment of any associated costs, and a description of envisaged procedures to consult with staff during the outsourcing process, considering national systems for dialogue with social partners where applicable.
NFU welcomes and strongly supports EBAs writings on that service providers must act in a manner consistent with the financial institution’s values and code of conduct. It is crucial for the institution to ensure that the service provider adheres to international standards on human rights and environmental protection. NFU strongly supports EBAs references to both working conditions and prohibition on child labour under point 56 but considers it important to add labour rights and the right to social dialogue to the list as it would incorporate further social protection. Social dialogue is recognized by the European Commission as improving and boosting economic competitiveness and social cohesion at the same time. NFU therefore advises the Commission to add labour rights & social dialogue to the list.

EBA writes that the adherence to human rights and environmental protection is specifically important when the service provider is in a third country. NFU understands the reference to third countries but would like to note that it is equally important that the financial institution ensures that the service provider located in another EU Member State adheres to labour rights, the right to social dialogue and environmental protection.
NFU finds the risk assessment sufficiently clear and appropriate but would nevertheless like to raise other risks connected to outsourcing experienced by employees and local trade unions. Some of the risks that have been raised are that organizational costs of outsourcing are often underestimated, the process takes longer than expected and the challenges with different cultures and language are taken too lightly on. It is important to also assess these risks when planning for outsourcing arrangements.
Nordic Financial Unions (NFU)