The Community had always strived to promote equality between the sexes. Article 119 of the Treaty of Rome enshrined the principle of equal pay for men and women in doing the same job. The concept of equal pay had gradually established itself and a coherent set of legal provisions aimed at guaranteeing equal rights in respect of employment, professional training and, to a large degree, social security had now been adopted on this basis at Community level. In addition to its legislative activities (adoption of six directives), the Community had been helping promote equality in a practical way since the 1980s by means of specific action programmes. The latter had provided funding for positive actions and pilot projects aimed at helping women combine family life with a professional career, promoting the role of women in decision making and their participation in economic life and in the labour market, etc. Issues relating to gender equality had been part of the Community’s policy on cooperation and development for a number of years. Furthermore, the Community had played a key role in the UN conferences in Rio de Janeiro , Vienna , Cairo , Copenhagen and Peking , the latter having been held in September 1995. Many of the conclusions reached at these meetings were designed to promote the role of women and give them greater scope for action and greater independence. The European Councils of Essen, Cannes and Madrid had underlined the fact that promoting equality of opportunity between men and women, along with efforts to reduce unemployment, constituted a priority task for the Union and its Member States . In December 1995 the Council of Ministers had adopted a draft decision from the Commission on the setting-up of a new Community action programme on equal opportunities (1996-2000). This was intended to achieve legislative progress and to make real headway in the area of ‘integration’, as well as to help support and implement specific actions aimed at promoting equal opportunities for men and women. The following actions were either under way or planned: - communication from the Commission to the Council and the European Parliament on the interpretation of the ECJ’s ruling of 17 October 1995 on the Kalanke case (reference C-450/93, casebook 1995, page I-3051); - a proposal for a directive from the Council amending Directive 76/207/EEC on equal treatment for men and women, which sought to clarify the article relating to positive action; - a proposal for a directive from the Council relating to the burden of proof in cases involving equal pay and equal treatment (the second phase of the consultation between the social partners commenced on 7 February 1996); - a proposal for a directive on the framework agreement on parental leave concluded by UNICE, the CEEP and the ECS (and adopted by the Commission on 31 January 1996); - a code of good practice for equality of pay for the same job, following the memorandum on equal pay that was adopted by the Commission on 23 June 1994; - a report on the implementation of the Commission’s recommendation of 1991 for the protection of the dignity of male and female workers.