In the position, the main issues raised by CESI relate in particular to the following:
• European legislators should make a clear commitment to the continued existence of an EU postal directive and advocate, in the case of a revision, for its further development. The central objective must be the maintenance/establishment of a balance between competition, consumer needs, a functioning and economically viable universal service as well as the maintenance of decent employment in the postal and parcel sector. Wage dumping, undue discrimination and the exploitation of workers must be precluded;
• Offering a universal postal service must be conditional upon the provision of a minimal postal infrastructure and the continued achievement of an ambitious minimum level of quality service;
• Given that the employment situation in the postal and parcel service sector often leads to marked social distortions and violations of the laws and rules, the EU should ensure appropriate national-level frameworks fit to counter this undesirable development. In so doing, minimum wage payments, for example, as well as the respect for applicable driving and rest times must be subject to permanent and transparent controls carried out by the competent national authorities. The legislator should intervene, should the rules not be adhered to.
• The distribution of letters and parcels could be subject to licensing for providers. Delivery licences c´should ensure the respect for environmental protection as well as, beyond, the obligation to provide social insurance as well as further non-environmental criteria. In the framework of binding licences, all companies that provide services relating to the delivery of letters and parcels should obliged to report to the national regulatory authorities in a standardised manner, on (1) social data such as number of employees, nature of contractual agreements, staff fluctuation, and pay gaps; (2) social standards including employment standards; and (3) environmental standards;
• The member states’ national legislation should also introduce subcontractor liability in the post and parcel industry. Should a service partner (subcontractor) of a postal service provide violate the law, it should also be possible to hold the postal service provider accountable;
• Beyond this, the legislator should encourage work in the sector within the EU to be part of a collective agreement. It is only through involving the social partners in all EU member states that minimum standards and acceptable wages can be guaranteed and any exploitation and old age poverty precluded;
• As work becomes increasingly digital and online-based, the protection of the personal data of employees and their private lives is more important than ever before. In the framework of the EU postal directive, but also beyond this in the context of the EU general data protection regulation (GDPR), employees and staff must be protected from inadequate surveillance and control by digitial technology potentially deployed by employers. Digital systems purely for the purposes of monitoring staff and employees should be rejected.
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