persons with disabilities via the disabled persons’ complaint hotline110 as well
as the types of complaints filed to the FOI (as well as the complaint handling
results). The analyses are to be reported to the Insurance Bureau of FSC every
quarter as references for supervisory measures to be adopted. The NHRC
recommends that the abovementioned statistical data be released publicly on
a regular basis to allow others to review the effectiveness of supervision.
(6) In discussion meetings related to the ROC’s CRPD Report, disabled
persons’ organizations have repeatedly reported that Chunghwa Post frontline
counter staff frequently reject or are unwilling to accept simple life insurance
applications and savings insurance applications submitted by persons with
disabilities, or request that said persons submit their applications in the name
of their nondisabled family members, constituting discrimination.
Article 27: Work and employment
119. According to Points 68 b) and 69 b) of the Concluding Observations of the ROC's
Initial CRPD Report, the IRC recommended that the government mandate that
employers ensure reasonable accommodation in the workplace. The CRPD
Second Report failed to respond to this recommendation. However, the MOL
asserted that job redesign for persons with disabilities is a measure conceived to
regulate reasonable accommodation.111 The NHRC has noted that job redesign as
defined in Article 37 of the PDRPA is a non-mandatory statutory service
subsidized by the government that employers can apply for and that has nothing
to do with the reasonable accommodation obligation of employers characterized
in the CRPD. Additionally, this implies that the rejection of reasonable
accommodation constitutes discrimination. Regarding the inquiry by the NHRC
concerning the enforcement of reasonable accommodation, the MOL responded
110
111
Persons with disabilities can file complaints via complaint channels provided by the FSC, NLIA,
LIAROC, and insurance companies. On December 15, 2020, the FSC published a press release titled
“Complaint Channels for Persons with Disabilities to Report Unfair Treatment when Applying for
Insurance,” which directed persons with disabilities to file complaints via complaint channels
provided by the FSC, NLIA, LIAROC, and/or insurance companies if an insurance company rejects
their insurance application solely because of their disability. They can also file complaints if the
insurance salespeople refuse to accept their insurance application, assist them in submitting their
insurance application, and/or verbally encourage them to withdraw their insurance application during
the insurance solicitation stage.
Point 26 of the CRPD Second Report.
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