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In its “Discussion Paper on a template for recovery plans”, the European Banking Authority (EBA) suggests some concrete steps and measures to be taken in the case of a bank recovery procedure. UEF welcomes the opportunity to contribute to EBA’s proposal and calls for consideration for the potential consequences on employees and employment.

In addition to the important role a financial institution plays for economy at large, these institutions are also large purveyors of employment and have a social responsibility.

The key preventive role employees can play in the first stages of crisis management is not taken into account in EBA’s proposals. “Whistle-blowers” should have access to independent authorities and enjoy full protection.

In addition, companies should take their responsibilities to inform and consult employees – so that they can help in anticipating change and can also reveal specific situations management might otherwise not be aware of. This can prevent crisis situations.

Banks should take their responsibility for continuous training of employees seriously and thus contribute to preserving employment and to reinforce the employability in case of permanent staff reduction in the firm or/and sector.

Corporate governance should not only include short term profitability indicators and maximization of value for the shareholders. There should also be indicators of long term strategic goals, based on economic and social performance, such as the long term impact of strategic decisions on employment and working conditions.

For more information, find EBA’s discussion paper on the EBA website: http://www.eba.europa.eu/Publications/Discussion-Papers/Year/2012/EBA-DP-2012-2.aspx.

This document must also be seen in relation to the Commission's proposed directive on bank resolution and bank recovery, which has been presented on 6 June 2012: http://ec.europa.eu/internal_market/bank/docs/crisis-management/2012_eu_framework/COM_2012_280_en.pdf.