Our consultations
Have your say on policy issues relating to OSH and what affects you the most
Response to the HM Treasury Spending Review 2020 (SR20)
About this consultation
The UK Government through the HM Treasury requested feed on its Comprehensive Spending Review 2020. This review will allow the government to consider its priorities across all spending over multiple years.
Background
The UK has a well-established budgeting framework, through which a spending review is carried out approximately every 3 years to allocate funding to departments. This provides certainty for departments to plan ahead.
Consultation questions
Interest groups, individuals and representative bodies can submit a written representation to HM Treasury to comment on government policy or suggest new policies to include in Comprehensive Spending Review 2020.
HM Treasury welcomes representations from stakeholders as part of the policy-making process.
Menopause and the workplace inquiry
About this consultation
The House of Commons Women and Equalities Committee launches a new inquiry, scrutinising existing legislation and workplace practices, and asking if enough is being done to address the issue.
Background
The Government Equalities Office 2019 ‘roadmap’ on gender equality commits the Government to conduct research into “what works to improve women’s reproductive health, across the life course” and “develop indicators relating to women’s health experience and impact on their work.” The Government has also recently sought views to help inform the development of a Women’s Health Strategy. This inquiry examines the extent of discrimination faced by menopausal people in the workplace and investigates how Government policy and workplace practices can better support those experiencing menopause.
Consultation questions
The Committee is seeking written submissions addressing any or all of the following topics:
- How can businesses factor in the needs of employees going through the menopause?
- How can practices addressing workplace discrimination relating to menopause be implemented? For example, through guidance, advice, adjustments, or enforcement.
- What are examples of best or most inclusive practices?
- How should people who experience the menopause but do not identify as women be supported in relation to menopause and the workplace?
- How well does current legislation protect women from discrimination in the workplace associated with the menopause?
- Should current legislation be amended?
- What further legislation is required to enable employers to put in place a workplace menopause policy to protect people going through the menopause whilst at work?
- How effective has Government action been at addressing workplace discrimination related to the menopause, and what more can the Government do to address this issue?
Women’s Health Strategy: Call for Evidence
About this consultation
This call for evidence is seeking to collect views on women’s health.
Background
The Women’s Health Strategy for England will set out an ambitious and positive new agenda on women’s health, with women’s voices at the centre. We are launching this call for evidence to inform the priorities, content and actions within the Women’s Health Strategy. This exercise will ensure that the strategy is evidence-based and reflects what women identify as priorities.
The Department of Health & Social Care want to understand more about issues that only affect women (for example, gynaecological conditions or menstrual health), and also issues that affect both men and women but may be more prevalent in women or affect men and women differently. The evidence gathered through this exercise will inform the priorities, content and actions in the new Women’s Health strategy for England. It will ensure that the strategy is evidence-based and reflects what women identify as priorities.
Consultation questions
This call for evidence seeks views on 6 core themes that connect different areas of women’s health across the life course.
- health topics
- women’s voices
- information and education on women’s health
- women’s health through the life course
- women’s health in the workplace
- research, evidence and data Impact of COVID-19 on women’s health
WISH Covid-19
Response to the European Commission Health & Safety at Work
About this consultation
This initiative will contribute to improving health and safety at work, including helping to prevent workers from having accidents at work and getting avoidable work-related illnesses. The initiative will also improve productivity and contribute to preventing unnecessary health costs, such as medical or rehabilitation costs, as well as to reducing public healthcare spending, so improving the sustainability of social security systems.
This requires an inclusive and crosscutting strategic approach to address the main challenges which will be identified for this decade and ensure that workers in the EU can benefit from the highest standard when it comes to health and safety at work.
Background
The current consultation concerns an initiative for a future Strategic Framework on Health and Safety at Work. The workers’ safety and health at work is a matter of broad interest. For this reason, this public consultation is collecting the views of all interested citizens and organisations. Contributions are particularly sought from OSH professionals.
The Commission has committed to ensuring the right of EU workers, both to a high level of protection of their health and safety at work, and to a working environment adapted to their professional needs, which enables them to prolong their working life. The current EU Strategic Framework on Health and Safety at Work ends in 2020 and a new one will be adopted in 2021.
Proposed changes
The aim of this open public consultation is to take stock of the quality and implementation of the Strategic Framework on Health and Safety at Work 2014-2020 and to receive input for the future Strategic Framework 2021-2027.
The objective of this public consultation is twofold. The information and opinions collected will be used to take stock of the current EU Strategic Framework. At the same time, it will also provide input to prepare and improve the new one for the period (2021-2027).
Consultation questions
We invite IOSH members to send us comments on the European Commission consultation on the Health & Safety at Work – EU Strategic Framework (2021-2027) to help inform an IOSH submission. Please complete the comments form and send it to consultation@iosh.com by 15 February 2021.
You can contribute to this consultation by addressing the following set of questions from the European Commission:
- Thinking about the situation in your country / the EU, has workplace safety and health in your opinion become better since 2014? Please specify why: 500 character(s) maximum.
- Do you agree or disagree that the EU Strategic Framework on Health and Safety at Work 2014-2020 contributed to better work place health and safety for specific groups of workers who may be identified as potentially facing specific risk factors, such as women, older workers, workers with disabilities, seasonal workers, migrant workers, etc. as well as the self-employed? Please provide further details regarding the specific group potentially at risk and/or risks faced. 500 character(s) maximum.
- In your opinion, what were the most significant barriers to fulfilling the EU Strategic Framework on Health and Safety at Work 2014-2020 objectives. Please specify what other barrier(s) you perceive? 500 character(s) maximum.
- Please briefly explain why you believe the EU Strategic Framework on Health and Safety at Work 2014-2020 contributed – or not – to improved health and safety at work. 500 character(s) maximum.
- Thinking about the future (the next seven years), what priorities a new EU Strategic Framework on Health and Safety at Work should focus on? Please specify: 500 character(s) maximum
- Thinking ahead to the next 7 years (2021-2027): What are the key challenges that are common across the EU and require further OSH policy action? 500 character(s) maximum. What practical solutions do you suggest to address all or some of these key challenges? 2500 character(s) maximum.
- Should a new EU Strategic Framework on Health and Safety at Work define in detail a list of objectives, actions, timelines and actors involved in the implementation of such actions, or should it set a vision for the future, and a definition of goals and priorities? 500 characters maximum.
- In your view, what main issues should be included in the successor to the current EU OSH Strategic Framework, covering the next seven years? 2500 character(s) maximum.
- You may share any additional remarks or statement(s) regarding the topic of this public consultation here. 500 character(s) maximum.
Response to the Sustainability Accounting Standards Board for an initiative on Human Capital research
About this consultation
The research project is part of SASB’s launch of its project-based model, which enables SASB to more agilely review and address key issues in the SASB standards. Since human capital is an issue that cuts across many industries, the human capital research project’s objective is to create a market-informed and evidenced-based framework that identifies the financially material impacts of relevant human capital management issues, which will enable the assessment of these themes on an industry-by-industry basis.
Background
Currently, SASB standards address three relevant, financially-material issues related to human capital management (in industries where sufficient evidence of financial impact and investor interest has been demonstrated): employee health and safety; employee diversity, inclusion, and engagement; and labor practices.
However, as firms become increasingly exposed to technological innovation combined with broader macroeconomic trends of shifting demographics and changing societal values toward human capital, the re-evaluation of the standards in context of these evolving and emerging trends is increasingly important.
Consultation questions
SASB is seeking feedback from stakeholders highly knowledgeable in the impacts of human capital management issues at an industry-specific level related to either the investors’ views on meaningful points of data to assess these themes or how companies are managing and tracking these issues to enhance corporate strategy and long-term value creation.
Response to the European Commission proposal for an initiative on Sustainable Corporate Governance
About this consultation
This initiative is complementary to the review of the Non-Financial Reporting Directive (NFRD, Directive 2014/95/EU), which currently requires large public-interest companies to disclose to the public certain information on how they are affected by non-financial issues, as well as on the company’s own impacts on society and the environment. The NFRD also requires companies to report on their social and environmental policies and due diligence processes if they have them, or otherwise explain why they do not have any (comply or explain approach). While the NFRD is based on incentives “to report”, the sustainable corporate governance initiative aims to introduce duties “to do”.
The initiative would build upon relevant international standards on business and human rights and responsible business conduct, such as the United Nations’ Guiding Principles on Businesses and Human Rights and the OECD Guidelines for Multinational Enterprises and its Due Diligence Guidance for Responsible Business Conduct.
Background
This initiative looks to strengthen the respect of human rights, including labour rights and corporate social responsibility criteria throughout the value chains of European companies.
Sustainability in corporate governance encompasses encouraging businesses to frame decisions in terms of their environmental (including climate and biodiversity), social, human and economic impact, as well as in terms of the company’s development in the longer term (beyond 3-5 years), rather than focusing on short-term gains.
Reporting to the public on the application of sustainability in corporate governance and on the fulfilment of directors’ and corporate duties would enable stakeholders to monitor compliance with these duties, thereby helping to ensure that companies are accountable for how they mitigate their adverse environmental and social impacts.
Proposed changes
This public consultation aims to collect the views of stakeholders with regard to a possible Sustainable Corporate Governance Initiative. It builds on data collected in two studies: the study on directors’ duties and sustainable corporate governance; and the study on due diligence requirements through the supply chain; as well as on the feedback received in the public consultation on the Renewed Sustainable Finance Strategy.
It includes questions to allow the widest possible range of stakeholders to provide their views on relevant aspects of sustainable corporate governance.
Consultation questions
Here are the key questions from the European Commission:
- Human rights, social and environmental due diligence requires companies to put in place continuous processes to identify risks and adverse impacts on human rights, health and safety and environment and prevent, mitigate and account for such risks and impacts in their operations and through their value chain. In the survey conducted in the context of the study on due diligence requirements through the supply chain, a broad range of respondents expressed their preference for a policy change, with an overall preference for establishing a mandatory duty at EU level.
- Do you think that an EU legal framework for supply chain due diligence to address adverse impacts on human rights and environmental issues should be developed?
- Do you consider that corporate directors should be required by law to (1) identify the company´s stakeholders and their interests, (2) to manage the risks for the company in relation to stakeholders and their interests, including on the long run (3) and to identify the opportunities arising from promoting stakeholders’ interests?
- Do you believe that corporate directors should be required by law to set up adequate procedures and, where relevant, measurable (science – based) targets to ensure that possible risks and adverse impacts on stakeholders, ie. human rights, social, health and environmental impacts, are identified, prevented and addressed?
- Do you believe that corporate directors should balance the interests of all stakeholders, instead of focusing on the short-term financial interests of shareholders, and that this should be clarified in legislation as part of directors’ duty of care?
- Which risks do you see, if any, should the directors’ duty of care be spelled out in law? How could these possible risks be mitigated?
- As companies often do not have a strategic orientation on sustainability risks, impacts and opportunities, do you believe that such considerations should be integrated into the company’s strategy, decisions and oversight within the company?
For the purposes of this consultation, “due diligence duty” refers to a legal requirement for companies to establish and implement adequate processes with a view to prevent, mitigate and account for human rights (including labour rights and working conditions), health and environmental impacts, including relating to climate change, both in the company’s own operations and in the company’s the supply chain. “Supply chain” is understood within the broad definition of a company’s “business relationships” and includes subsidiaries as well as suppliers and subcontractors. The company is expected to make reasonable efforts for example with respect to identifying suppliers and subcontractors. Furthermore, due diligence is inherently risk-based, proportionate and context specific. This implies that the extent of implementing actions should depend on the risks of adverse impacts the company is possibly causing, contributing to or should foresee.
Please explain whether you agree with this definition and provide reasons for your answer
- How could companies’- in particular smaller ones’- burden be reduced with respect to due diligence? Please indicate the most effective options.
- Enhancing sustainability expertise in the board Current level of expertise of boards of directors does not fully support a shift towards sustainability, so action to enhance directors’ competence in this area could be envisaged. Please indicate which options are in your view effective to achieve this objective.
- Do you consider that any other measure should be taken at EU level to foster more sustainable corporate governance? If so, please specify.
- A clarified duty of care and the due diligence duty would be expected to have positive impacts on stakeholders and the environment, including in the supply chain. According to your own understanding and assessment, if your company complies with such requirements or conducts due diligence already, please quantify / estimate in quantitative terms the positive or negative impact annually since the introduction of Improvements on health and safety of workers in the supply chain, such as reduction of the number of accidents at work, other improvement on working conditions, better wages, eradicating child labour, etc.
A matter of principles: The future of corporate reporting – discussion paper
About this consultation
The UK’s Financial Reporting Council (FRC) has issued a discussion paper proposing The future of corporate reporting founded on a principles-based framework. The paper outlines a model for what FRC describe as “a more agile approach to corporate reporting which challenges existing thinking about how companies can more effectively meet the information needs of investors and other stakeholders.”
FRC highlight that companies and society face significant challenges, heightened by the Covid-19 pandemic, and that stakeholders are increasingly interested in companies’ wider actions and the reporting that supports these.
The paper considers a common criticism that corporate annual reports are too lengthy, and that information is difficult to access. FRC intends that its proposals are tested with stakeholders and stimulate discussion about the future landscape of corporate reporting.
Please view FRC’s supporting literature review and the results of the FRC’s initial survey.
Background
The UK’s FRC regulate auditors, accountants and actuaries, and set the UK’s Corporate Governance and Stewardship Codes. It seeks to promote transparency and integrity in business, with its work aimed at investors and others who rely on company reports, audit and corporate risk management.
The FRC is working towards becoming the Audit Reporting and Governance Authority (ARGA), which will require primary legislation. It is looking to implement the recommendations of the Independent Review of the FRC; The Competition and Markets Authority (CMA) review; and Sir Donald Brydon’s review into the quality and effectiveness of audit, using six workstreams as one holistic programme.
The six workstreams are: setting up the new regulator; audit scope & regulation; corporate regulation; corporate reporting; corporate governance; and market reform. Activities include a new governance structure, due in January 2021; enhanced complaints handling processes; and engagement with prospective signatories of the revised UK Stewardship Code, which took effect from 2020, with reporting due in 2021.
Proposed changes
The FRC discussion paper proposals include:
- unbundling the existing purpose, content, and intended audiences of the current annual report by moving to a network of interconnected reports;
- a new common set of principles that applies to all types of corporate reporting;
- objective-driven reports that accommodate the interests of a wider group of stakeholders, rather than the perceived needs of a single set of users;
- embracing the opportunities available through technology to improve the accessibility of corporate reporting; and
- a model that enables reporting that is flexible and responsive to changing demands and circumstances.
FRC believes that these proposals are consistent with the themes in the independent Kingman and Brydon reviews. FRC assert that to build trust in the system for corporate reporting, it needs to be supported by a framework for audit and assurance and regulation.
Consultation questions
We invite IOSH members to send us comments on FRC’s discussion paper on The future of corporate reporting to consultation@iosh.com, to help inform an IOSH submission, by 05 January 2021.
IOSH members wishing to also respond individually to the FRC directly can do so by completing the FRC survey or by sending comments to futurereporting@frc.org.uk by 05 February 2021.