Submission on the Exposure Draft of the Superannuation Fund Notification Bill by the Association of Professional Engineers, Scientists and Managers, Australia's Translators and Interpreters Group August 2012
Submission by APESMA's Translators and Interpreters group on the Exposure Draft of the Superannuation Fund Notification Bill Contents Page Foreword... 3 Background... 4 Submission... 4 Translating and Interpreting industry... 4 Proposed changes... 4 APESMA's view... 5 Conclusion... 5 "It is APESMA's view that the notice requirements set out in the proposed Superannuation Fund Notification Bill will help protect superannuation entitlements by providing a mechanism by which members can note discrepancies between their entitlements and employer payments into their accounts sooner." APESMA submission, p.5 Association of Professional Engineers, Scientists and Managers, Australia August 2012 2
Foreword The Association of Professional Engineers, Scientists and Managers, Australia (APESMA) considers assisting members with the protection of their employment-related entitlements a fundamental part of our role. It is our view that the new notice requirements set out in the proposed Superannuation Fund Notification Bill are an important step toward improving the protection of the superannuation entitlements of our members, particularly in the case of more vulnerable workers. APESMA thanks you for the opportunity to make a brief submission on this issue. Chris Walton APESMA CEO 3
Background The Association of Professional Engineers, Scientists and Managers, Australia (APESMA) is an organisation registered under the Fair Work Act 2009 representing over 25,000 professionals including professional engineers, scientists, veterinarians, surveyors, architects, pharmacists, information technology professionals, managers, transport industry professionals and translators and interpreters throughout Australia. APESMA is the only industrial association to represent exclusively the industrial and professional interests of these professionals. This submission is made on behalf of the members of our Translators and Interpreters Group. Submission Translating and Interpreting Industry APESMA considers assisting with the protection of member entitlements a fundamental part of our role. We are in the process of establishing APESMA as an industry presence for a group of Victorianbased Translator and Interpreter members. Monitoring and enforcement can be particularly difficult in the case of entitlements for low-income and/or casual employees. Recent APESMA research 1 shows that the Translating and Interpreting industry is marked by: high levels of casual employment; hourly rates of pay which have failed to keep pace with inflation; potentially high rates of misclassification of employees as contractors; multiple job holding; and low levels of retirement income. Each of these factors make it critical that Translators and Interpreters are able to effectively monitor whether or not they are being paid their correct superannuation entitlements. Proposed changes The Draft Bill requires superannuation funds and Retirement Savings Account (RSA) providers to report contributions to active members within 42 days after the end of a quarter or a six-month period effective the financial year beginning 1 July 2013. The proposed change to the Superannuation Industry (Supervision) Act 1993 will enable the Australian Prudential Regulation Authority (APRA) to take action if funds or RSAs do not comply with the new requirements. 1 Lost in Translation: Barriers to building a sustainable Australian translating and interpreting industry (2012), Association of Professional Engineers, Scientists and Managers, Australia. Available at http://issuu.com/barriers/docs/lost_in_translation?mode=window&pagenumber=1 4
APESMA's view It is the view of APESMA's Translators and Interpreters Group that the notice requirements set out in the proposed Superannuation Fund Notification Bill will help protect the superannuation entitlements of our Translator and Interpreter members by providing a mechanism by which members can note discrepancies between their entitlements and employer payments into their accounts sooner. The process will allow for more timely and effective monitoring. We also strongly support the proposed amendment to the Superannuation Industry (Supervision) Act 1993 as an incentive for compliance with the proposed notification legislation. Conclusion APESMA strongly supports the proposed changes to the Corporations Act 2001 and the Superannuation Industry (Supervision) Act 1993. It is our view that such reform will provide greater protection of the entitlements of all professionals, but particularly for more vulnerable workers including Translating and Interpreting professionals. Submission preparation Dr. Kim Rickard, Executive Officer, APESMA Managers and Professionals Division e: krickard@apesma.com.au APESMA GPO Box 1272, Melbourne, Vic. 3001 e: info@apesma.com.au w: www.apesma.com.au/groups/translators-and-interpreters t: 1300 APESMA I 1300 273 762 5