Answer to the Commission consultation on the Quality Framework of Traineeships

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1 31 January 2013 Answer to the Commission consultation on the Quality Framework of Traineeships EUROCHAMBRES Recommendations: 1. Do you consider that the option set out in section 5.1 could provide an acceptable framework for addressing the concerns expressed in your replies to the first stage consultation? Elements included in section 5.1 can contribute to the further development of an EU traineeship framework. In the further development of the framework it is however necessary to bear in mind the needs and capacities of enterprises, in particular of SMEs. SMEs do not have human capacity comparable with large companies and that should be taken into account. Such quality framework for traineeships should also reflect the need to encourage companies to offer more traineeship and have clear advantages for doing so; in other words, the framework should address the quality aspect from the company perspective as well as the trainee s. However, EUROCHAMBRES would like to point out that such framework should rather serve as a guideline for the design of traineeship and should not impose legal obligations on the parties involved. Companies need to enjoy a certain level of flexibility when traineeships are considered. Otherwise, the risk to policy makers, companies and trainees alike is that less traineeship would be offered. The duration of traineeships should be decided on a case by case basis, and similarly when the remuneration/compensation is considered. Internships that last longer than 6 months are already an exception in most Member States. In the view of Chambers of Commerce and Industry, in a limited number of cases, unpaid internships can be also considered, for example, for students or for very short periods. EUROCHAMBRES Position Paper

2 2. Do you consider that the option set out in section 5.1 should be limited to open-market traineeships, or should it cover all types of traineeships? Various types of traineeships should not be mixed in the proposed framework. Chamber of Commerce and Industry firmly believe that there has to be clear separation between traineeship offered as part of obligatory training and the so-called free market placements. EUROCHAMBRES can agree that minimum requirements should be introduced, such as a written agreement defining obligations, rights and the goals of the traineeship for the free market placements. However apprenticeships done during the dual vocational system should be excluded from such a framework as there is already legislation in place. 3. What are your views on the other options set out in sections 5.2 and 5.3? Quality assurance of traineeship is by all means of great importance because it can contribute to higher level of employability for trainees. Labelling of SME s would contribute in quality assurance of traineeship but it could also present an obstacle to involve a higher number of SMEs. Quality labelling can be introduced in the longer time framework, in the situation of improved economic situation. However, the introduction of such a quality label should not create additional bureaucracy for companies, especially SMEs. If such label is to be introduced, it should be possible for businesses to commit themselves to the quality criteria without being obliged to undergo an assessment. In case of reasonable complains, the label could be deprived. Other suggestions could prove very costly. It is also necessary to have a web platform where all the necessary information about the traineeship will be available, but the question is who will be in charge for coordinating this web platform. Such information portal would definitely ensure a better overview of the supply and demand and simultaneously provide a good overview of the legal situation in the Member States. 4. Are the EU social partners, at cross-industry or sectorial level, willing to enter into negotiations on the basis of the elements set out in section 5.1 of this communication with a view to concluding an agreement on a quality framework for traineeships under Article 155 TFEU? As a stakeholder in the consultation process we consider that EUROCHAMBRES on behalf of Chambers of Commerce and Industry are ready and committed to enter negotiations that could lead to the agreement on a Quality Framework for Traineeships. European Chambers of Commerce and Industry play a pivotal role in the training policy. In a typical year, over 2.5 million people receive training qualifications from Chambers. In some countries, Chambers are the second largest training providers after the public sector. They cooperate closely with businesses and thus recognise the importance of onthe-job training at all levels EUROCHAMBRES Position Paper Page 2 of 5

3 Further information: Ms. Anna Szatkowska, Tel , szatkowska@eurochambres.eu Press contact: Ms. Guendalina Cominotti, Tel , cominotti@eurochambres.eu All our position papers can be downloaded from EUROCHAMBRES The Association of European Chambers of Commerce and Industry represents over 20 million enterprises in Europe 93% of which are SMEs through members in 44 countries and a European network of 2000 regional and local Chambers. ASSOCIATION OF EUROPEAN CHAMBERS OF COMMERCE AND INDUSTRY Chamber House, Avenue des Arts, 19 A/D B Brussels Belgium Tel Fax eurochambres@eurochambres.eu EUROCHAMBRES Position Paper Page 3 of 5

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