In a stance rejecting discrimination, a 2009 study for the Department of Labour by the CONSAD Research Corporation concluded, "it is not possible now, and doubtless will never be possible, to determine reliably whether any portion of the observed gender wage gap is not attributable to factors that compensate women and men differently on socially acceptable bases, and hence can confidently be attributed to overt discrimination against women." and continued "In addition, at a practical level, the complex combination of factors that collectively determine the wages paid to different individuals makes the formulation of policy that will reliably redress any overt discrimination that does exist a task that is, at least, daunting and, more likely, unachievable." The conclusion was based largely on a study by Eric Solberg & Teresa Laughlin (1995), who found that "occupational selection is the primary determinant of the gender wage gap" (as opposed to discrimination) because "any measure of earnings that excludes fringe benefits may produce misleading results as to the existence magnitude, consequence, and source of market discrimination." They found that the average wage rate of females was only 87.4% of the average wage rate of males; whereas, when earnings were measured by their index of total compensation (including fringe benefits), the average value of the index for females was 96.4% of the average value for males.