Employment status
This response is submitted on behalf of the Fellowship of Independent Evangelical Churches, an association founded in 1922, with a current membership of 465 independent churches in the UK.
While other forms of atypical employment are undoubtedly important, our knowledge and experience is entirely connected with the situation of ministers of religion, and our submission is therefore devoted solely to addressing their employment status.
We have considerable knowledge of the way in which the ministers of independent churches relate to the churches which they serve, not only because the FIEC has been in being for 80 years, but also because 334 of our churches have ministers and we are in close and regular contact with them.
In our submission we wish to advocate most strongly that no change is made to the present employment status of ministers of religion, for the following reasons:
[1] The church officers, members and its minister are “on the same side.” They have the same view about the importance and nature of the work, and there is no suggestion that the present arrangement is beneficial to the church or the minister to the detriment of the other.
[2] Additional employment obligations as employers, whether financial or supervisory, would not be welcomed by the churches, as they would not necessarily have the financial or human resources to meet these requirements.
Conversely, ministers would not welcome the loss of status which becoming an “employee” would imply, and the potential threat to their own personal freedom to organise their working lives in the way that suits them best, and which most effectively meets the needs of the churches they serve.
[3] By the nature of the work the actual workload and daily priorities and work activities of the minister are unpredictable. In these circumstances the provisions of the Working Time Regulations would be a positive hindrance to the minister, either making it necessary for him to make himself unavailable in time of need, or saddling him with bureaucratic calculations to ensure he is not exceeding hours limits. A minister does not think in terms of hours of work.
[4] It is essential for the minister to be able to plan and determine his own work commitments. This is the only way in which he will be able to respond to immediate needs. In these circumstances a minister does not fit the employee model, but rather sees himself as being accountable to God. In an independent church there is no “employer” structure either, most of the officers and members who appointed him being busy earnings their own livings outside the church.
[5] The present relationship between independent churches and their ministers has existed for many years and is a tried and tested system which has not been found wanting. Problems which have arisen have not been the fault of the system and would not be solved by any change to it.
[6] We have no evidence that the current lack of extended employment rights has deterred anyone from serving as a minister of a church, but the increased commitment involved if employment rights were extended would not be welcomed by the churches and might deter a few of them from appointing a paid minister.
[7] Bringing ministers of religion under the mainstream employment legislation would involve the Tribunals from time to time in having to make judgements about issues of a biblical and theological nature - issues which they may well not possess the knowledge to handle. This is not a criticism of the Tribunal system, but indicates the specialist nature of this area of employment.
[8] Above all, there is no reason for change, and nothing at all to be gained by implementing it.
Rev Basil A Howlett, Secretary, FIEC Pastors’Association
Rod Badams, FIEC Administrator
