Submission form for: proposed changes to the Skilled Migrant Category LABOUR, SCIENCE AND ENTERPRISE GROUP

Transcription

1 Submission form for: proposed changes to the Skilled Migrant Category LABOUR, SCIENCE AND ENTERPRISE GROUP

2 Purpose of the Skilled Migrant Category The Skilled Migrant Category (SMC) is a policy for people who want to live permanently in New Zealand and have the skills to contribute to New Zealand s economic growth. Why the SMC is being reviewed The SMC is being reviewed to improve how we identify the most highly skilled migrants. The current points system has been in place since the SMC opened in However, it no longer appears to be effectively prioritising the migrants with the highest skill levels. A growing number of SMC applicants are working in low-wage occupations and in roles where the level of skill is difficult to assess objectively using the current criteria. How SMC works: points based system SMC applicants submit expressions of interest and are assessed using a points based system. If their expression of interest is successful, applicants are offered the opportunity to apply to gain residence. The points-based system recognises people who have skills to fill identified needs and opportunities in New Zealand, who can contribute to New Zealand economically and socially, and who can successfully settle here. When submitting an expression of interest, applicants can claim points for having: skilled employment in New Zealand (ongoing employment or a job offer), relevant work experience, and recognised qualifications. There are bonus points available under each of these areas. There are also points for age, and for the employment and qualifications of an applicant s partner. The following links have more information on the SMC: Skilled Migrant Category visa Skilled Migrant Category information for employers Immigration Instructions SM6: Summary of points for employability and capacity building factors Objectives of the consultation This consultation is to: inform our understanding of the impacts of the options being considered, especially on employers and industries identify any unforeseen or unexpected risks, and inform the advice provided to Ministers to help with their decisions on the detailed components of the policy. We are consulting on specific detailed proposals, not on the overall review. 2

3 How to make a submission The Ministry of Business, Innovation and Employment (MBIE) seeks written submissions by 5pm on Sunday 30 October You can use the submission form on the consultation web page, or in a digital format that best suits you. Your submission may respond to any or all of the issues. Where possible, include evidence to support your views, for example salary and remuneration information for your workplace, sector or group, or examples of how the proposals will impact you. MBIE will treat all information received as confidential and with the appropriate sensitivity. We will maintain its confidentiality within the bounds of the Official Information Act Please identify any commercially sensitive information clearly. Please include your contact details in the accompanying your submission. You can make your submission by sending it as a Microsoft Word or PDF document to: SMCReview@mbie.govt.nz Please direct any questions that you have in relation to the submissions process to: SMCReview@mbie.govt.nz MBIE will report back to Ministers for Cabinet decisions on the Skilled Migrant Category Review before the end of Treatment of confidential information submitted during consultation MBIE is particularly interested in salary/income information from affected sectors. This will complement our current analysis that uses anonymised tax data on the incomes of SMC migrants. Where available and relevant, provide supporting evidence with details of the salary bands or remuneration structures of your business or sector/industry. MBIE undertakes to treat information received in confidence with appropriate sensitivity and to maintain its confidentiality within the bounds of the Official Information Act. Please identify any commercially sensitive information clearly. How to use this form This form is only editable in the marked areas. When you download this form, you may need to first click Enable editing at the top of the page. Contact details Please provide your name and phone number, and preferred address for contact if it is different from the one used to send this form: Rachael Shadbolt GM Accommodation, Partnerships and Communication Hospitality NZ and AccommodationNZ rachael.shadbolt@hospitalitynz.org.nz 3

4 Background questions In what capacity are you providing feedback? e.g. on behalf of: your company, the company you work for, an industry organisation, a union, licensed immigration adviser etc. Hospitality NZ, and its sub-association AccommodationNZ, is providing feedback on behalf of our 3,000 members. Hospitality NZ is a voluntary trade association representing almost 3,000 hospitality and commercial accommodation businesses. Through our members we are able to gauge the views and experiences of a wide variety of New Zealand hospitality operators including restaurants, café bars, hotels, taverns, off-licenses, casinos and a wide array of short and long term accommodation providers. AccommodationNZ is an independent association within Hospitality NZ. Of the 3,000 Hospitality NZ members, 1,000 are accommodation providers and it is this sub group that Accommodation NZ represents. Businesses range from hotels, motels, country hotels, luxury lodges, backpackers and serviced apartments. If you are representing a company or group, what is the name of that group? N/A What industry or industries does that group work in? Hospitality, Tourism and Commercial Accommodation sectors In your company or industry, what are the most common occupations for migrant workers? For the purpose of this submission, which focuses on the Skilled Migrant Category (SMC), the most common occupations (relevant to the Hospitality and Tourism sectors) likely to be impacted by the proposed changes are Chefs (ANZSCO ) and Café/Restaurant Managers (ANZSCO ). Both have a Skills Level 2 rating. Immigration NZ statistics indicate that YE June ,218 work visa applications were approved for Chefs. 950 Chefs had applications approved under the SMC. 2,045 work visa applications were approved for Café/Restaurant Managers and 600 had applications approved under the SMC. It should also be noted that the hospitality, tourism and commerical accomodation sectors are heavily reliant on migrant workers for many roles within the industry, from entry level roles such as kitchen hands and housekeeping, through to management positions such as Chefs, Café or Restaurant Managers, Hotel General Managers etc. The latest Hospitality NZ Remuneration Survey which covered 102 roles, across 664 member businesses and 10,298 staff, indicated that 17% of the surveyed workforce were on some sort 4

5 of work visa ie: working holiday visas through to skilled migrant category applications. Hospitality NZ is aware that Immigration NZ is in the process of reveiwing a number of migration channels, starting with the SMC. We have been advised that other visas such as working holiday visas, work visas may also be reviewed by the end of We are concerned that changing the application critieria too quickly across a number of visa or migration channels, or making it too hard for people to gain temporary or more permanent migrant visas, could have a detrimental flow on effect into our actual visitor numbers, as many come in on working holiday visas. It could also impact international student numbers as students looking to New Zealand as a potential place to settle may become less attractive. More worrying, any rapid immigration changes across a number of channels would likely impact on the local hospitality and tourism sectors ability to appropriately staff their businesses. We acknowledge the New Zealanders first approach and wish to emphasis that the sector would happily take willing and qualified New Zealand workers if they were available. Unfortunately there simply aren t enough of them to go around and this has been an issue for many years. Therefore, the question Hospitality NZ asks of Immigration NZ when undertaking these reviews is what is being done in the New Zealand education space via other Ministries to encourage New Zealanders into the hospitality and tourism industry as a career choice. Reducing the ability to attract skilled migrate workers needs to be backfilled with skilled and willing New Zealanders. Should the proposed changes go through we do not have confidence that this gap would be filled quickly enough with New Zealanders, if at all, if the ability to attract skilled migrant workers was significantly curtailed. What visa categories are commonly used by those workers? i.e. resident visa, Essential Skills work visa, Work-to-residence work visa (under the Talent or Long Term Skill Shortage List categories), Post-study work visa (open or employer assisted), open work visa. Most visa categories are used by the hospitality, tourism and commercial accommodation sectors. At the entry job level, such as kitchen hands, housekeeping, portering it may be that these roles are filled by, but not limited to, people on working holiday visas or post-study work visas. As the seniority of the role increases it is more likely that the visas will reflect the commitment that person has to the employee, their career path and to staying in New Zealand. As such Resident Visas, Skills work visas, Work-to-residence work visas (particularly for Chefs on the Long Term Skill Shortage List) are more common. Only answer the following questions if you directly employ migrant workers. How many migrant workers do you currently employ? 5

6 N/A Have you supported a Skilled Migrant Category visa application for any of these workers? N/A 6

7 Proposals for consultation The consultation is targeted at detailed proposals that relate to: introducing the use of salary levels to help define skilled employment strengthening the use of work experience to define skilled employment, and realigning the points system to better recognise highly skilled migrants Proposals 1, 2 and 3 will affect how migrant workers claim points for skilled employment under the SMC. Points for skilled employment are not always necessary to meet the selection threshold. However, the majority of SMC applicants do claim the points for skilled employment. How skilled employment is currently defined under SMC: using ANZSCO Skilled employment is defined using the Australian and New Zealand Standard Classification of Occupations (ANZSCO). There are five ANZSCO occupational skill levels. Levels one, two and three are classified as skilled for the purposes of the SMC. Jobs at these levels can currently be used to claim SMC points, as long as the job description substantially matches the ANZSCO occupation description, and the applicant has the recognised relevant qualification or work experience required. You can search the ANZSCO register here. The limitations of the current definition of skilled employment ANZSCO provides an objective and consistent classification of occupations. However, it is not an accurate description of the actual level of skill required for a particular job or the skills of a person employed in a particular job. It cannot be easily used to differentiate between senior and junior roles (particularly in managerial positions). The growth in SMC migrants who work in lower-income occupations indicates that some jobs that meet the ANZSCO definition of skilled work may not in fact be highly skilled. On the other hand, there have been examples of migrant workers in highly paid positions unable to use SMC because their job description matches a low skilled occupation under ANZSCO. Using salary levels to help define skilled employment We propose two changes using salary/wage levels. The proposal is to have both options available for applicants under the SMC. Proposal 1: Minimum salary/wage for claiming points for skilled employment In order to claim points for skilled employment, applicants must have a job (or job offer) in an occupation at ANZSCO level 1, 2 or 3, AND earn more than a minimum salary/wage level. Options for minimum salary/wage level: Note: options for the minimum salary/wage level would be indexed to the New Zealand Income Survey (NZIS), which publishes New Zealand median hourly earnings annually. The salary and wage levels provided below are for the 2015 NZIS. The final salary and wage level would be updated when the 2016 NZIS data is available. 7

8 Proposed minimum salary thresholds for SMC Hourly rate of pay Annual rate of pay (30-hour work week) Annual rate of pay (40-hour work week) Indexed to Option 1A $22.83 $35,614 $47,486 1x median earnings Option 1B $25.11 $39,171 $52, x median earnings Option 1C $27.40 $42,744 $56, x median earnings What this means: Someone working as a retail manager (ANZSCO skill level 2), earning $40,000 p.a. and working 40 hours a week can currently claim 50 or 60 points for skilled employment, and possibly bonus points for working in a skill shortage area. Under proposal 1, they would no longer be able to claim points for skilled employment. Questions What impacts or implications do you foresee from this proposed change? Give details of the occupations and salary levels you are thinking of. Proposal 1: Minimum salary/wage for claiming points for skilled employment - In order to claim points for skilled employment, applicants must have a job (or job offer) in an occupation at ANZSCO Level 1,2 or 3 AND earn more than a minimum salary/wage level Using the example of Chefs (ANZSCO Skill Level 2) and comparing the proposed minimum salary thresholds for SMC to the 2016 Hospitality NZ Remuneration Survey, only chefs at Executive Chef, Head Chef and Sous Chef level would make the salary threshold. Likewise, using the example of Café and Restaurant Managers (ANZSCO Skill Level 2), Café Manager would only make the threshold in Option 1A and Restaurant Manager would make the threshold in Options 1A and 1B. See Table 1: Proposal 1 attached The SMC is designed to prioritise and identify, as part of the applications process, skilled migrant workers with the highest skill levels. The addition of a salary range as part of the critieria may, in some cases, assist in identifying those applicants who truly fit the SMC criteria. However, a wage/salary threshold cut off at Sous Chef level is too high up the kitchen brigade management structure and does not allow Chefs in kitchen middle management roles of Pastry Chef, Senior Chef de Partie and Chef de Partie to get a foot on the SMC ladder. It is these middle management kitchen roles that are in critically short supply nationally and businesses need to be able to access chefs at this level from the global, as well as, domestic market. These middle kitchen management roles earn an average of (Hospitality NZ Remuneration Survey 2016): 8

9 Pastry Chef Senior Chef de Partie Chef de Partie $49,250 per annum $45,867 per annum $41,399 per annum The reason for the vacuum of available local staff at the Chef de Partie level is due to the traditional offshore migration of New Zealand chefs when they reach this level to try their hand at more senior roles such as Sous, Head and Executive Chef. This results in less appropriately skilled and experienced local staff at the Chef de Partie level to fill these roles, which gives rise to needing to source these positions from the international market. Essentially these middle kitchen management roles are very transient as Chefs seek experiences in other countries to development their skills. New Zealand chefs go overseas to gain experience and likewise chefs from other countries come here to hone their skills. They may come temporarily or they may decide to stay. It should also be noted that globally there is a massive shortage of chefs. So not only is the industry competing with each other for staff, they are also competing with the rest of the world. A search on seek.co.nz on 31 October 2106 indicated 430 chef roles ranging from Executive Chef through to Chef de Partie being advertised indicating a significant demand for these middle to high kitchen management roles. With regard the Café and Restaurant Managers, this is another role within the hospitality sector that is very hard to recruit for domestically and relies heavily on access to skilled migrant workers as evidenced by the 2045 approved work visa applications YE June 2016 and the 600 approved SMC applications. Seek.co.nz currently has 480 roles with these job titles advertised. Hospitality NZ asserts that the requirement to have a job (or job offer) AND earn more than a minimum salary/wage level as per this proposal would cut too many worthy, skilled migrant Chefs and Café/Restaurant Managers from the SMC that the industry desparately needs. Recommendation: We recommend that the minimum salary/wage levels outlined in Proposal 1 are reduced to better reflect the current market rates being paid to attract the middle management kitchen roles (Chef de Partie) and up ie: from $41,000. Hospitality NZ also recommends that the wage/salary levels paid in the regions need to be taken into account, as these can fluctuate considerably region to region and city to city. If Immigiration NZ want to attract skilled migrants into the country, but away from Auckland, then the lower wages/salary levels in some smaller or rural regions, that are not on the traditional tourist routes, need be taken into account. Would the different minimum salary thresholds have different impacts? As the current minimum wage/salary thresholds stand Executive Chefs would easily meet or exceed the thresholds. Head Chefs and Sous Chefs would meet the proposed thresholds in Options 1A and 1B only and Pastry Chefs would only meet the threshold in Option 1A. Chefs looking for middle management kitchen roles like Chef de Partie would not make the threshold. As mentioned above it is these roles that are the hardest to fill domestically. Café Managers would only meet the proposed threshold in Option 1A and Restaurant Mangers 9

10 would meet the threshold in Option 1A and 1B. See Table 1: Proposal 1 attached Are there any skilled occupations that you think should be exempt from a minimum salary threshold? Give details of the occupation(s) and the salary range(s), and reasons why they should be exempt. Hospitality NZ considers that the inclusion of a minimum salary threshold is a good measure to include in the SMC applications as it provides another layer of information to accurately assess if the applicant is bringing high skill levels and valuable knowledge into the country. However, Hospitality NZ cautions that the minimum salary thresholds need to be set appropriately, based on the going market rates of these professions. Hospitality NZ has previously provided Immigration NZ with the 2016 Remuneration Survey which we trust will help further inform the setting of appropriate wage/salary thresholds for this sector. Proposal 2: Using salary/wage level as a means of identifying highly skilled employment, regardless of the ANZSCO level of an occupation Applicants with a job (or job offer) with an income above a certain (higher) level can claim points for skilled employment regardless of the ANZSCO skill level of their occupation. Relevant work experience and/or qualifications would also be required. Options for salary/wage level: Note: options for the salary/wage level would be indexed to the New Zealand Income Survey (NZIS), which publishes New Zealand median hourly earnings annually. The salary and wage levels provided below are for the 2015 NZIS. The final salary and wage level would be updated when the 2016 NZIS data is available. Proposed salary level for highly skilled employment Hourly rate of pay Annual rate of pay (30-hour work week) Annual rate of pay (40-hour work week) Indexed to Option 2A $31.96 $49,857 $66, x median earnings Option 2B $34.25 $53,430 $71, x median earnings Option 2C $38.80 $60,528 $80, x median earnings 10

11 What this means Someone working as an experienced crane operator (ANZSCO skill level 4), earning $91,000 p.a., cannot currently claim points for skilled employment. Under proposal 2 they would be able to do so. Questions What impact or implications do you foresee from this proposed change? Give details of the occupations and salary levels you are thinking of. The roles of particular interest to Hospitality NZ (Chefs and Café and Restaurant Managers) are ANZSCO Skill Level 2, therefore making the roles eligible to claim points for skilled employment. Hospitality NZ does however consider that salary/wage levels being used as a means to identify highly skilled employment, regardless of the ANZSCO level is a useful measure to have in place. It has been acknowledged for a long time that the ANZSCO system is a fairly blunt instrument, therefore the addition of wage/salary levels as another way to measure skill levels is prudent. Recommendation: Introduce the use of salary/wage levels as a means of identifying highly skilled employment, regardless of the ANZSCO level of an occupation. Would the different thresholds have different impacts? Hospitality NZ does not feel it has enough background data with respect to the types of jobs that would fall into this category, to make comment. Chefs and Café/Restaurant Managers sit at Skill Level 2 and therefore are eligible to claim points for skilled employment. Using work experience to define skilled employment We propose one change to how work experience is used to claim points for skilled employment. This would require migrants in certain jobs to have a minimum level of work experience. Under current policy, in order to claim points for skilled employment, the job description must substantially match the ANZSCO description for that occupation, and the applicant must generally have either: a relevant recognised qualification at the level required by ANZSCO or work experience for the number of years required by ANZSCO. Proposal 3: Requiring a minimum number of years of relevant work experience In order to claim points for skilled employment, we propose applicants must have a minimum of three years of recognised work experience that is relevant to their job (or job offer) and that 11

12 this would apply regardless of whether they hold a formal qualification. This proposal would apply to all skill level 3 occupations, and some skill level 2 occupations, such as managerial roles. Requiring work experience for managerial roles and trades jobs will help show that Skilled Migrants are operating at a high level. What this means Someone working as a baker (ANZSCO skill level 3) can currently claim points for skilled employment as long as they have either a relevant recognised Level 4 Certificate OR at least three years of relevant recognised work experience. Under the proposed changes, they would need to have at least three years of work experience relevant to their employment as a baker in order to claim the points for skilled employment, even if they also have a Level 4 Certificate. Questions What impact or implications do you foresee from this proposed change? Using Chefs as an example: the current requirement is a relevant recognised Level 4 qualification (or international equivalent) AND/OR at least three years of relevant recognised work experience. Under the new proposal, a minimum of three years of relevant recognised work experience would become a compulsory requirement. Hospitality NZ is concerned with the proposal to make recognised work experience a minimum of 3 years. Most Chefs operating at a senior management level within a kitchen brigade would have a relevant recognised Level 4 qualification (or international equivalent) and/or atleast 3 years of relevant recognised work experience, therefore easily fulfilling the current requirements. However, to make work experience a minimum of 3 years could stop some highly motivated and skilled candidates, who have worked their way quickly through the kitchen brigade, from applying for SMC. Hospitality NZ recommends that status quo remains ie: relevant recognised qualifications AND/OR at least three years of relevant work experience. Are there any level 3 or level 2 occupations that you think should be exempt? Give details of 12

13 the occupation(s) and reason(s). As noted above, Hospitality NZ recommends that the current status quo of relevant recognised qualitifications AND/OR at least three years of relevant work experience. Should relevant work experience of a minimum of 3 years become compulsory, then Hospitality NZ asserts that Chef and Café/Restaurant Managers should be exempt. When looking to hire migrant workers in your company or industry, is the same value placed on qualifications and relevant work experience, or is one valued more than the other? Specify the occupation(s) you are thinking of, and reasons. Hiring migrant workers can come with some risk and businesses are generally more cautious with regard to reference and qualification checks. Qualifications, especially if they are internationally recognised - like City&Guilds, give the employer a certain level of comfort that the migrant worker has the necessary skills the do the job. Relevant work experience, particularly if it comes from well known international restaurant names or celebrity chef brands can also add some weight to the application, as it provides further insight into the sorts of kitchen/restaurant someone has worked in, their ability to work in that environment and the amount of people and management experience that person might have had. Hospitality NZ considers that both factors are important, however it is likely that once the migrant worker is operating at senior management level it is their experience, and potentially who they have worked for, that carries greater value. Equally for Café and Restaurant Managers, relevant work experience is often valued more highly than qualifications, particularly if that person is bringing in skills from international markets where hospitality and guest service is a highly regarded profession. As an example, a Chef or a Restaurant Manager with experience in a Michelin star kitchen or restaurant is a skill set that would add huge value to a business in New Zealand and would certainly be given significant weight by an employer. When looking to hire migrant workers in your company or industry, is relevant overseas work experience valued differently to relevant work experience in New Zealand? Specify the occupation(s) you are thinking of, and reasons. As noted above 13

14 Realigning the points system to better recognise highly skilled migrants While there are still highly-skilled and highly-paid migrants coming through the SMC, the current skill composition of SMC migrants does not fully reflect the Government s wider objectives to lift skills levels and incomes. Current settings prioritise current employment and qualifications over skilled work experience. This does not align with existing evidence on the relationship between the quantity and quality of a migrant s work experience and their employment outcomes. Proposal 4: Realigning the points system to better recognise highly skilled migrants The following changes to the points system are proposed: a. Focus the points system more on skilled work experience, including by: require work experience to be in skilled employment (defined by a job at ANZSCO skill levels 1-3) increasing work experience points b. Increase the points available for a post-graduate qualification c. Increase the level of qualification required for points to be awarded for a partner s qualification, to a bachelors degree or higher d. Award additional points for high salary levels for skilled employment in New Zealand e. Reduce the points awarded for migrant aged 20-29, to the same level as migrants aged 40-44, to reflect increased skill levels in the age group f. Remove bonus points that do not have a strong association with migrants labour market outcomes, including points currently available for identified future growth areas (creative industries, ICT and biotechnology) points for qualifications in an area of absolute skill shortage (Long Term Skill Shortage List occupations) points for close family in New Zealand g. Reduce the points available for work experience in New Zealand (including removing extra skilled employment points for ongoing employment of 12 months or longer in New Zealand) h. Adjust the rules for comparable labour markets, including by: What this means reviewing the list of countries that are assessed as comparable, and removing the current exceptions that allow points to be awarded for work experience in a non-comparable country. Under the proposed changes, skilled work experience and higher-level qualifications would be given greater preference in the points system. A range of redundant points (outlined above) would be removed in order to simplify the overall policy. 14

15 These proposals relate to the underlying system of how skilled migrants are identified for the purpose of SMC. They do not refer to any set points selection level, but would influence where to set the selection level. Once the new points system is in place a new points selection level (currently 160 points) will need to be set. Questions What impact or implications do you foresee from these proposed changes (please identify the specific change(s) you refer to in your response)? Realigning the points system to better recognise highly skilled migrants; a. Focus the points system more on skilled employment - Hospitality NZ does not agree that skilled work experience should only be relevant if that experience was gained while in a job at ANZSCO Skill Level 1-3 as this would preclude any work experience points being gained in roles that staircase into the Level 1-3 roles ie: A senior waiter should be allowed to claim points for this role if they are applying for a Restaurant Manager role b. Increase the points available for a post-graduate qualification - This might be relevant in some sectors but it carries very little weight in the Hospitality industry particularly for the roles of Chef and Café/Restaurant Manager - Hospitality NZ does not agree that post-graduate qualification should be given any special treatment, unless that level of qualification is absolutely vital to a particular role or sector. c. Increase the level of qualification required for points to be awarded for a partners qualification, to a bachelor degree or higher - This could be potentially prohibitive for skilled migrant workers who are the main salary earners within a family. - Hospitality NZ questions the rationale behind this policy realignment d. Award additional points for high salary levels for skilled employment in New Zealand - As is evidenced by the remuneration data provided for Chefs and Café and Restaurant Managers, skilled employment does not necessarily translate to high salary levels. Highly skilled people who chose to work in sectors that might not be as high paying as others should not be penalised for that. - Hospitality NZ does not agree e. Reduce the points awarded for migrants aged 20-29, to the same level as migrants aged 40-44, to reflect increased skill levels in the age group - Hospitality NZ suggest the migrants aged should be able to claim the same points as the age group (25 points). For the hospitality and tourism sectors this would better serve the young and eagar age group that the industry is heavily reliant on at the Chef de Partie role level, as well as, the age group who may be in the more senior roles. Both are equally important to the sector. f. Remove bonus points that do not have a strong association with migrants labour market outcomes, including - identified future growth area Hospitality NZ agrees - point for qualifications on the LTSSL Hospitality NZ does not agree. If the 15

16 role is identified on the LTSSL, which therefore suggests a long term skill shortage, then an applicant should be able to claim bonus points for this. - points for close family in New Zealand HospitalityNZ agrees g. Reduce the points available for work experience in New Zealand (including removing extra skilled employment points for ongoing employment of 12 months or longer in New Zealand - Hospitality NZ does not agree. Skilled workers should be able to claim points for experience working in the New Zealand business environment and their commitment to working in New Zealand for an extended period of time. But only on the basis that the skilled employment and relevant work experience truly reflects the desired outcome of the SMC. h. Adjust the rules for comparable labour markets - Hospitality NZ does not feel the discussion paper has provided enough details as to what comparable and non-comparable markets are to be able to respond to this question with confidence. 16