MR HASSAN ADEMOV
CHAIRMAN OF
LABOR COMMISSION,
SOCIAL AND DEMOGRAPHIC POLICY
TO THE NATIONAL ASSEMBLY
MR IVAILLO CALFIN
DEPUTY MINISTER-PRESIDENT
ON DEMOGRAPHIC AND SOCIAL POLICY,
MINISTER OF LABOR AND SOCIAL POLICY I
CHAIRMAN OF THE NATIONAL COUNCIL
FOR TRIPARITE COOPERATION
REGARDING: Bill to amend and supplement the Social Security Code, No. 654-01-5, submitted by Valeri Simeonov and a group of people's representatives
DEAR MR ADEMOV,
DEAR MR CALFIN,
In connection with the draft law submitted to us to amend and supplement the Social Security Code, No. 654-01-5, submitted by Valeri Simeonov and a group of people's representatives, related to the proposal to supplement the Social Security Code /CSO/ with a new provision, and namely: Art. 69 "Acquiring the right to a pension for sailors who sailed under the Bulgarian flag", our opinion is as follows:
The Confederation of Employers and Industrialists in Bulgaria, as it has already expressed its opinion on this matter, supports any initiative to change in a more favorable direction the legislation regulating the order of insurance and subsequent retirement of seafarers. In this regard, we also support the idea of creating Article 69d (new), accepting it as a deliberate but alternative option for the retirement of seafarers.
In our opinion, the proposed provision should be considered at least in the direction of:
Defining the term "seafarer/seafarers" to be included in the CSR itself. Until now, paragraph 5a of the DR of the CSR contains only a definition of the term "sea person".;
Regulation of the procedure for establishing under which flag the voyage was carried out - with what document, issued by whom, etc., which should also be regulated in a law or by-law, i.e. we believe that in retrospect establishing this circumstance would have been very difficult.
We also consider it expedient that the unspecified moments causing questions like those commented above should be further discussed.
With respect,
Eugene Ivanov
Ex. director
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