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Review of the Equal Opportunity for Women in the Workplace Act 1999 – Submission

Qantas Airways Limited

28 October 2009

Dear Tanya

Re: Review of the Equal Opportunity for Women in the Workplace Act 1999

I refer to your letter of 9 June 2009 to Mr Alan Joyce inviting Qantas' comments in relation to the above review.

We welcome the opportunity to provide comments on the key themes raised in the Issues Paper. The Qantas Group is committed to developing our diverse workforce, with priority given to reflecting the wide range of customers across the world, and the representation of women across the organisation is an integral aspect of this.

We would be pleased to provide any further information if it would be of assistance and to participate in stakeholder consultations if invited to do so.

Yours sincerely

David Epstein signature

DAVID EPSTEIN

Group Executive

Government and Corporate Affairs



Qantas Airways Submission

This submission covers the following topics:

As a major Australian employer, the Qantas Group seeks to nurture and utilise Australia's diverse talents, a key element of which is the representation of women across the organisation.

The Qantas Group aims to ensure that all employees are equipped, empowered and encouraged to contribute to their fullest potential. The Group offers a broad range of initiatives which focus on women, such as leadership development programs and encouraging the representation of women in non-traditional roles. These employment initiatives have been introduced with positive results and the Group continues to build on these advancements, focusing on attracting, retaining and developing women across the organisation.

Given the economic conditions and changes in workplace relations legislation, this is a timely review of the efficiency and effectiveness of Australia's equal opportunity framework. Overall, Qantas has seen positive benefits from the introduction of the Equal Opportunity for Women in the Workplace (EOWW) Act and Agency and supports the continuation of this framework. Beyond the concept of promoting equality, advancing equal opportunity for women in the workplace will have a positive effect on the international competitiveness of Australian organisations.

The Qantas Group's commitment to equal employment opportunity

Against the background of the EOWW framework, the Qantas Group has a range of initiatives in place to promote equal employment opportunity.

Qantas recognises the importance of enabling employees to combine their child care needs with the opportunity for continued participation and career development in Qantas. To support this, parental leave for births and adoptions is available to eligible employees and includes 12 weeks' paid maternity leave and up to two years unpaid maternity leave and one week paid paternity leave.

The availability, affordability and accessibility of child care can be an obstacle to women's employment and the Qantas Group provides eligible employees with access to affordable, high quality employer sponsored childcare centres in Melbourne, Sydney and Brisbane. Around 600 families have been supported through access to the Qantas sponsored child care centres since 2003.

Qantas recognises that, at times, some employees may need support in striking a better balance between their work and personal commitments, especially carer and family responsibilities. Qantas aims to provide practical policies and programs that assist employees in achieving greater flexibility and work life balance. Qantas views it as important for the advancement and participation of women, as well as good business sense to provide flexible work options and support such as part time, job share, working from home, extended parental/eave and leave without pay and onsite child care.

The issues paper notes that indigenous women can also experience distinct obstacles in the workplace and the Group has made a particular commitment to Indigenous Australia as part of the Reconciliation Action Plan (RAP). Employment initiatives are one of the priorities of the RAP, alongside strategic partnerships and promoting respect for Indigenous cultures, with the aim of ensuring the Group's indigenous workforce is supported, engaged and provided with improved opportunities for career and skills development.

Qantas, like other organisations, is making progress in these areas and it is helpful to have legislation and government agencies that can provide practical assistance in advancing workplace strategies.

Suggestions to enhance the EOWW framework

Objects of the EOWW Act

The objectives of the EOWW Act, based on the concepts of merit and the elimination of discrimination, is shared by other existing legislation which have direct roles to address workplace discrimination. In Qantas' opinion, there is an opportunity to update the objectives of the Act to specifically encourage and inspire organisations to review work practices to accommodate the role of the family (both men and women) both on a day-to-day basis and in relation to career paths.

The role of men as fathers and carers

The EOWW Act could provide a greater focus on enabling men and women to share paid work and caring responsibilities more equally. Qantas is currently reviewing policy to consider opportunities to use more inclusive language such as referring to "primary carer".

Content of workplace programs, including the specified 'employment matters'

The seven employment matters allow for reporting on a broad range of organisational activities, however, consideration could be given to reviewing these to ensure they remain relevant to contemporary workplaces. Many large organisations such as Qantas are taking a more strategic approach towards equal employment opportunity by focusing on leadership, engagement and cultural change and there may be a need to reflect how these types of initiatives/approaches impact women in the workplace. For example, employment matters could be more specific in relation to participation rates, leadership and development and flexible work arrangements.

In Qantas' opinion, the content of workplace programs could be enhanced by adopting a more tailored approach to the reporting and assessing process in terms of the industry, size of the organisation and available resources. This could be achieved by varying the employment matters an organisation is required to report on depending on the size of the organisation, for example.

In developing workplace programs, all organisations should be encouraged to set action plans in relation to increasing female representation at senior and board levels. Qantas has specific talent initiatives aimed at increasing women in senior management roles and supporting their development to do so.

Requirements regarding the content of reports

As a reporting organisation, the primary basis of the Qantas Group's relationship with the EOWW Agency is in relation to reporting and there are a number of opportunities to enhance this process, improving outcomes for both women and business.

The Act requires that organisations submit a report to EOWA on the actions that have been taken, demonstrating the outcomes of the workplace program. The format of the report could provide a greater focus on outcomes for women in the workplace by asking five to 10 key questions at the beginning of the report in relation to outcomes for that reporting year. These questions could be generally based on the criteria to be an EOWA Employer of Choice for Women.

Under the EOWW Act, organisations are required to report in May each year based on 31 March data and while this alleviates additional reporting requirements at peak times of the year, data collection would be simpler if the reporting period was aligned with either the financial or calendar year reporting cycles.

Reviewing workplace programs and reports

Organisations considered to be 'highly compliant' with the Act, such as Qantas, would benefit from enhancements to the assessment process such as encouraging the sharing of best practice by EOWA assessors. For example, this could include tailored advice and suggestions for new strategies and programs which have been effective in similar organisations. Ideally, EOWA assessors would possess expertise in particular industries and be able to meet with senior leaders and key HR representatives to discuss the report, assessment and most importantly, next steps in more detail.

For large organisations, it would also be useful if EOWA could produce more benchmarking data to allow organisations to measure progress against others.

Regulatory role of the government

Qantas welcomes the Australian Government's decision to introduce a national Paid Parental Leave scheme, which has been designed to impose minimal new costs on employers and would support the extension of this scheme to include paid paternity leave.

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