Maternity Benefits and other Workplace Amenities across the World
Perspectives on maternity benefits vary across different regions. The benefit of paid leave without having to worry about losing your job may seem like a must-have right in a particular country, while in another, the same could be seen as a privilege. What one person may take for granted, another may look at as a distant dream that is years of lobbying away. What one company may see as their duty towards their employee as a part of their human needs, another may look at as simply a loss of resources that could be avoided.
While there are umpteen possible explanations for the same, it is paramount that one has a fundamental understanding of the status quo and understand the degree to which the provision of maternity benefits varies across the globe.
Maternity Benefits in the United States of America (or the lack thereof)– The nation synonymous with freedom. The land of opportunities. The place where dreams come true. The best place to live your life without worries. While this has remained our broad idea of the country, we have missed out the small text at the bottom “no guarantees for pregnant women and new mothers”. For although the last line is not mentioned much by the country, it does seem to be the policy that is adopted by companies, considering that the country does not guarantee paid maternity leave. Alongside Papua New Guinea, the United States is the only other country which does not guarantee paid leave for new mothers[1].
Granted, there does exist the Family Medical Leave Act, passed in 1993 (while it is shocking that there hasn’t been a more recent development, this is not the most frustrating characteristic of the Act), under which 12 weeks of unpaid leave are provided. This is, however, subject to multiple conditions, such as the place of work having at least 50 employees or the person working in a public agency or a private elementary or secondary school. And if these conditions aren’t restrictive enough, the employee is also required to have worked for the employer for a period of at least a year, in addition to clocking 1,250 hours.
As expected, this has resulted in more than 40% of the workers in the country unable to meet the requirements, and even if they are, they are unable to afford the luxury of unpaid leave. While a minority of the workers in the private sector are able to avail of paid maternity leave, the rest are forced to resort to other sources of money, some even resorting to crowdfunding websites. That is when one can be sure that the maternity benefits offered by the country are woefully short of those required.
France– The French do not take the issue of a mother’s postpartum leave to be an unimportant matter, unlike certain other countries (read: USA). The mother is guaranteed fully paid leave of six weeks before the birth of the child, and 10 weeks of the same after delivery. In addition, in families that have two children, the woman can take two and a half years of job protected leave, while the other parent is entitled to six months. Families which have two or more children, also receive family benefits, receiving a monthly cash payment from the French government.
Finland– Expecting mothers are entitled to paid maternity leave that starts as early as 50 days prior to the expected due date, which extends to four months following the birth of the child. However, there is still no compulsion for the mother to return to work and she would be entitled to 70% of her salary as parental allowance which could be collected until the baby reached the age of nine months. The Parental Allowance system also permits men to take time off work as well.
Australia– There is no maternity leave in particular in Australia. However, they do have parental leave which is government paid leave, which can be availed by either parent for a period of 18 weeks. This leave can also be shared by the parents. In Australia, a person’s job is also protected for a year following the birth of the child.
Sweden– In Sweden new parents can avail of 480 days of leave, for which they would receive 80% of their normal pay. Out of this duration, the mother can avail of a guaranteed period of 18 weeks. Following this period, the remaining portion of their leave can be split between the two parents in the manner of their choosing.
Iceland– The Icelandic policy is extremely favourable to new parents. They receive nine months of leave where they are paid 80% of their salary. Further, each parent gets a minimum of three months out of the total period, in order for the kid to be able to spend time with either parent. The remaining period of three months can be split between the two parents in any manner they feel is appropriate.
Denmark– New mothers in Denmark are entitled to 18 weeks of maternity leave in total, out of which four weeks are before the birth of the baby, with the remaining 14 weeks after the delivery. The entire duration of leave is at full pay. During the 14-week period, the father is also entitled to take leave for two consecutive weeks. Following this, parents can also split 32 additional weeks of leave in any way they like. This can also be extended for a period of 14 weeks, in case the child or a parent gets sick. The government, by law, covers 52 weeks of paid leave, although not always at the full salary.
Belgium– Mothers can avail of 15 weeks of maternity leave, where the first month of their leave after the birth of the child is covered at 80% of their salary, with the remaining period being covered at 75%. Fathers are also given 10 days, of which three are at full pay while the remaining are paid at 82% if used within the baby’s first four months. Mothers are also given the option to take eight months of part time leave in place of fifteen months of full leave.
Serbia– New mothers in Serbia are entitled to 20 weeks of fully paid leave following the birth of the child. Following this, they also receive an additional year of leave, however the amount with which they are compensated also diminished over time. The first 26 weeks are at full pay, the next 13 weeks are at 60% while the last 13 weeks are at 30% of pay. Fathers receive one week of full paid leave.
Norway– The maternity benefits system in Norway is one that is flexible and offers the new mother with a choice. She can opt for 35 weeks of leave which would be at full pay or she could choose 45 weeks, for which she would receive 80% of her pay. Fathers, on the other hand, can take leave from 0-10 weeks, which is dependent on their wives’ income. In total, the parents can receive 45 weeks at full pay or 55 at 80% of their income.
Hungary– In Hungary, mothers receive 24 weeks of paid leave, during which period, they receive 70% of their salary. The period of leave commences from four weeks prior to the expected date of delivery. Following the 24 weeks, parents can also take an additional 156 weeks of leave, of which the first 104 weeks are paid at 70% of their salary, while the remaining duration is paid at a flat rate.
Estonia– Mothers are entitled to 140 days of fully paid leave for pregnancy as well as maternity. The period begins from 30-70 weeks preceding the expected due date for the delivery. Fathers are also given two weeks of paid leave, in order for them to bond with their child. They are also given time off during the final two months before their expected delivery date. At the ending of the maternity leave, parents also receive an additional period of 435 days off which can be shared, and is payable at the average of the amount earned by both of them.
Lithuania– Mothers receive 18 weeks of leave which is fully paid, while fathers get four weeks of the same. Following this, there is also an additional period of 156 weeks which could be shared between them. The shared portion could be paid at 100% for the first year or at 70% for the first two years. The remaining period in either case is unpaid leave.
Germany– The length of maternity leave in Germany is for a period of 14 weeks, of which the woman is entitled to be paid at a rate of 65% of her normal allowance. Apart from this, they also have assistance from a midwife in certain cases which is provided soon after the birth of the child.
United Kingdom– In the UK, the eligible employees can avail of up to 52 weeks of maternity leave. Out of this period, they can receive compensation for 39 weeks. Of these, the first six weeks are payable at 90% of their average earnings, while the remaining period is paid at either 141 pounds or 90% of their average weekly earnings, depending on the amount which is lower.
India– In India, mothers get a period of 26 weeks of maternity leave, of which not more than eight weeks are to precede the date of delivery, while the entire period is payable at the average rate which is payable to her. In order to claim the benefits, the mother should have been working for a period of at least eighty days in the past year for her employer. She cannot be made to perform arduous work during the month preceding the six weeks before her date of delivery. In addition to this, following the end of the statutory period of maternity benefits, she also has the option to choose to work from home, provided that the nature of her work permits her to do so and on terms agreed upon by her employer and her.
Countries with the Worst Maternity Benefit Policies
Papua New Guinea– The length of maternity leave provided is 6 weeks, in which the parent is not entitled to any compensation during the same.
United States of America– The length of maternity leave is 12 weeks; however, the entire period is unpaid and the woman receives no compensation.
Swaziland– Similar to the United States Swaziland also provides for 12 weeks of maternity leave, which are unpaid.
Lesotho– Again, similar to the above two, Lesotho provides for 12 weeks of maternity leave for new mothers, which are not paid.
Tunisia– The length of maternity leave is much shorter in this case, being a period of 4 weeks, which is paid at 50% for women who are in agriculture, 67% for those who are covered by the labour code, while civil servants are covered for the same at full compensation.
Conclusion
It is clear that the economic status of a country does not have a direct relation to the maternity benefits offered by the them. While the United States of America can certainly afford the payment and the leave which is to be granted to the expecting mothers, there is also a problem in the manner in which the employees are viewed by their employers. While the dominant view in the case of the USA is that the maternity leave and compensation is seen as a loss to the employer, the situation in a majority of the European countries is the opposite where they view the same amount as a benefit to the employee, rather than a cost to the employer. All said and done, maternity benefits are a basic right which should be available to the employees as a human right, and the failure to provide them with the same is a very clear indicator of the care and concern which their employers have for them. This brings out the severity of the difference in perspectives of people in different regions with varying policy. An American mother could only look at the conditions of a similar person in Sweden with nothing but longing and envy, while the mother in Sweden would view the plight of the American mother as a nightmare that she could never even imagine undergoing.
[1] Data from the International Labour Organisation, which has been quoted in the article linked below. (https://www.forbes.com/sites/ritarubin/2016/04/06/united-states-lags-behind-all-other-developed-countries-when-it-comes-to-paid-maternity-leave/#75d046e18f15)
[2] The data has been obtained from the UN data on maternity leave and Save the State of the World’s Mothers 2012- Save the Children.
Author: This post has been submitted by Rohit Iyengar, as part of his assignment with Ungender Insights. Rohit Iyengar is currently a student of NALSAR University of Law, Hyderabad.
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