Ms Alice-Mary Higgins:

I thank the committee for the opportunity to present. The establishment of a low pay commission is a positive step and a very welcome recognition of the problem of low pay in Ireland. It is critically important that the commission will have a strong gender perspective in its analysis and recommendations. We know from our members and from statistics that this is an issue which affects women in particular. Some 60% of people on low pay are women and 50% of women in Ireland are currently earning €20,000 or less. Many of the sectors in which women predominate have been at the frontline of often aggressive casualisation in terms of the erosion of wages and hours. We have a clear indicator of this in that Ireland's gender pay gap is now widening from 12.6% in 2009 to 14.4% currently. Historically, one of the only measures which has narrowed this gap was the original introduction of the minimum wage. This is therefore of crucial importance for the council.

I would love to discuss these issues in detail but we have been asked to focus on the heads of Bill. The National Women's Council of Ireland have a number of concerns and suggested amendments to the wording of the legislation which should be considered in order to ensure that the Bill genuinely delivers the scope and ambition for the commission which is in the spirit of the Bill.

Head 2, section 12, sets out the functions of the commission. Subsection 2 lists a number of items to which, in making a recommendation, the commission shall have regard. Given the gender concerns I have outlined, the council believes it is crucial that the low pay commission should be mandated in this section to have regard to gender equality and other equality factors, as a named aspect, in its deliberations. As well as the key issues of gender equality, explicit regard to equality would also be appropriate in line with the new positive duty which requires all public bodies, including presumably newly formed bodies, to have regard to equality in their operations. The detail of the recommendations is listed in the written submissions and I will therefore not enumerate them now.

In regard to looking at low pay, anyone would recognise that it is crucial to look at the cost of living as experienced by workers. However, there is an anomaly in the current phrasing of the Bill. Cost of living is not named as an overall area to which the commission should have regard. It is a subparagraph of paragraph (g), which provides for looking at the potential effects that an order might have on the cost of living. The problem is that, as currently phrased, the commission is not being asked to consider the impact the cost of living should have on a minimum wage, but rather the impact a minimum wage might have on the cost of living.

This is an anomaly or oversight that should be addressed. The cost of living should be listed as a concern in its own right and it should be high up on that list. We would recommend it as the second concern.

We feel two other areas should be included in matters of which regard should be taken. One that was previously mentioned was in-work poverty levels. It is a very concrete measure. It is clearly part of the motivation behind the Bill and it should be listed as something on which the commission is deliberating when making its recommendations. We know now that 16% of those below the poverty line are currently in work and that is a real concern.

We draw attention to the social and economic impact of wage levels and the associated cost or benefit to the State. Again, that is a concrete measure to be considered when we look, for example, at the level of reliance on family income supplement from the Department of Social Protection. It would behove the low pay commission to look wider than the employment context and at the wider socio-economic costs of low pay when making its recommendations.

We suggest that two areas need examination. One is the inclusion of the need for quality job creation. That is point (e). Under point (f), we already have employment and unemployment, rightly so. There is a danger when we talk about the need for job creation that we are including a rhetoric that doubles up on that and might imply a trade off, which we believe is unproven assumption. It would be more in the spirit of the Bill to refer to the need for quality job creation, which is the goal of the Bill.

I will skip through my other points and turn to two last areas. One thing we had suggested is that in terms of international comparison it might be enough to say "international comparison" rather than to tie us to the UK over Europe, for example. In terms of the focus on the minimum hourly rate of pay, we now know there is a huge body of work that is saying it is not about the hourly rate of pay. My colleagues in the Vincentian Partnership have highlighted that. Given the precarious work, we would suggest the inclusion of "other minimum wage instruments or measures as required" because an hourly focus does not capture the reality of most women in Ireland, or a third of all workers.

We welcome the gender balance in the commission and congratulate all of the new members. Our final suggestion is that sociology should perhaps be included as one of the areas of expertise given that the social impact of low wages is part of the picture.