Draft law amending and supplementing the Labor Code No. 554-01-180, submitted by Georgi Kadiev on 19.11.2015/XNUMX/XNUMX.

MR IVAILLO CALFIN
DEPUTY MINISTER PRESIDENT
ON DEMOGRAPHIC AND SOCIAL POLICY
MINISTER OF LABOR AND SOCIAL POLICY
AND CHAIRMAN OF THE NATIONAL COUNCIL
FOR TRIPARITE COOPERATION

REGARDING: Draft law amending and supplementing the Labor Code No. 554-01-180, submitted by Georgi Kadiev on 19.11.2015/XNUMX/XNUMX.

DEAR MR CALFIN,

The Confederation of Employers and Industrialists in Bulgaria considers the proposal to change Article 155, Paragraph 4 of the Labor Code by increasing the minimum paid annual leave from 20 to 25 days absurd at the present time. It in no way corresponds to the economic realities in Bulgaria and would have an extremely negative effect on a large number of Bulgarian companies and the economy as a whole.

We categorically do not share the argumentation of the proponent of the proposal for the ZID of KT, based on the poor health of the population. Effective measures to reduce stress should be part of the overall company policy, not introduced by law.

In addition, we should note that the proposed change largely limits the role of voluntary collective bargaining, introducing an administrative approach instead.

In a number of companies, collective agreements have been concluded, in which larger amounts of the basic paid annual leave and the additional paid annual leave for work under specific conditions and risks to life and health and for non-standard working hours than those defined in the Labor Code have been agreed upon. In view of the existing and now legal possibility, taking into account the specific conditions in individual enterprises, to negotiate more favorable conditions than those established in the CT, the proposed amendment is unacceptable and restrictive.

In our opinion, the example of the countries with a larger number of paid holidays, which is indicated in the rationale for the draft of the KT's ZID, is not adequate. In essence, they are countries, with few exceptions, where labor productivity and the health status of the population far exceed those in Bulgaria, and this is not at all due to the number of days of paid leave, but to a number of other structural factors such as education, social and health systems etc.

In view of the above, KRIB considers that the time is extremely inappropriate for such a change in the Labor Code. It would further undermine the already low level of foreign investment in our country, as well as the overall business climate, especially in the industrial sector. We believe that such a discussion should not be put on the public agenda at all before the GDP per capita reaches, or at least approaches, the average level for the European Union.
 

With respect,
Eugene Ivanov
Ex. director