Disability inclusion

This toolkit is a resource to assist CME businesses to develop Accessibility and Inclusion Action Plans (previously known as Disability Action Plans). These plans may be used to support employers to increase the number of people with disabilities they engage; to provide the necessary workplace adjustments and initiatives that enable people with disabilities to work effectively; and to ensure that businesses are getting the greatest benefit from a more diverse and inclusive workshop.

Early in 2018, the BCCM engaged Per Capita to extend its investment in promoting diversity across the CME sector by considering how it can create a more inclusive workplace environment for people with disabilities.

Per Capita worked with the BCCM over a 12 month period on a collaborative project to explore ways in which businesses in the CME sector in Australia can position themselves as ‘employers of choice’ for people with disabilities, and meaningfully increase their engagement and support of employees who live with disabilities.

The resulting report educates leaders in the CME sector about the opportunities, challenges and benefits of employing people with disabilities. It was informed by both qualitative and quantitative research, including an online survey of workers in the CME sector nation-wide, and two co-designed social innovation workshops with representatives of the CME sector and disability advocates.

The survey and workshops revealed a high level of empathy and understanding of the needs of people with disabilities, and a positive attitude to including them in the workplace. Compared to big business, CME organisations are well-placed to build on their values of mutuality and cooperation by creating truly inclusive workplaces.

The challenge now is to embed this cultural advantage in a sector-wide commitment to increasing the employment of people with disabilities, which is underpinned by appropriate programs of support for businesses within the sector, under the leadership of the BCCM.

This toolkit is a resource to assist in meeting that challenge. It is intended to enable individual businesses in the sector to develop Accessibility and Inclusion Action Plans (previously known as Disability Action Plans).

These plans may be used to support employers to increase the number of people with disabilities they engage; to provide the necessary workplace adjustments and initiatives that enable people with disabilities to work effectively; and to ensure that businesses are getting the greatest benefit from a more diverse and inclusive workshop.

It is important to note that this toolkit is intended to assist businesses in the CME sector to remove barriers to the inclusion of people with disabilities as employees, rather than to create an Action Plan to remove discrimination against customers with disabilities. For assistance with customer-facing practices, please refer to the Disability Action Plan information on the AHRC website.

According to the Australian Network on Disability more than 4.4 million people in Australia have some form of disability, or one in five people.

There are 2.1 million Australians of working age with disability. Of these, just under half are employed (47.8 per cent), compared with 80.3 per cent of people without disability. In addition, almost one in five (18.9%) people with disability aged 15-24 years experienced discrimination. In almost half of those instances, the source of discrimination is an employer.

Legal requirements

There are specific obligations under Australian law in relation to the employment of people with disabilities.

The following explanation is taken from the Australian Human Rights Commission (AHRC):

The Disability Discrimination Act 1992 (DDA) makes it unlawful to discriminate against a person, in many areas of public life, including: employment, education, getting or using services, renting or buying a house or unit, and accessing public places, because of their disability.

The DDA covers people who have temporary and permanent disabilities; physical, intellectual, sensory, neurological, learning and psychosocial disabilities, diseases or illnesses, physical disfigurement, medical conditions, and work-related injuries.

It extends to disabilities that people have had in the past and potential future disabilities, as well as disabilities that people are assumed to have.

In addition, the DDA protects people with disabilities who may be discriminated against because they are accompanied by an assistant, interpreter or reader; they are accompanied by a trained animal, such as a guide, hearing or assistance dog; or they use equipment or an aid, such as a wheelchair or a hearing aid.

The DDA also makes it against the law to discriminate against someone because of their association with a person with a disability.²

In relation to the employment of people with disabilities, the DDA makes it unlawful to discriminate against people with disabilities in employment, including:

• the recruitment process, such as advertising, interviewing, and other selection processes
• decisions on who will get the job
• terms and conditions of employment, such as pay rates, work hours and leave
• promotion, transfer, training or other benefits associated with employment
• dismissal or any other detriment, such as demotion or retrenchment.³

Such discrimination at work can be either direct – when a person with a disability is consciously treated less favourably in their workplace directly due to their disability; or indirect – when an employer puts in place conditions, requirements or work practices that appear to treat all employees equally but in practice put people with disabilities at a disadvantage.⁴

Most employers are aware of their obligations under the DDA and direct discrimination against job applicants or employees with disabilities is relatively rare.

Indirect discrimination is more common but can be difficult to definitively prove. It is often unintentional and stems from a lack of awareness or understanding on the part of the employer, but the impact on the worker with a disability is still significant.

Both direct and indirect discrimination against people with disabilities is unlawful under the DDA. More information about legal requirements can be found on the AHRC website.

The business case for employing people with disabilities

Above and beyond the requirements under the DDA and related legislation, there are compelling reasons to employ people with disabilities, and to improve the way your business engages with and supports them.

Employing people with disabilities can enhance your business’s public reputation and image in the community.

Including people with disability in your workforce ensures that your business is representative of the community and your customer base. With one in five Australians living with a disability, your business likely engages with customers who have a disability regularly.

People with disabilities tend to build strong connections with customers, often displaying high levels of empathy and understanding, and can provide a viewpoint due to their experience of living with a disability that can enrich your organisation’s understanding of customer and community needs.

Evidence has also shown that a more diverse workforce improves productivity and creates a more welcoming and inclusive culture. People with disabilities, like all workers, bring a range of skills and talents to the workplace, and can boost staff morale and create or improve a sense of teamwork.

When workers with disabilities are employed in suitable positions, with the necessary workplace adjustments and support, they perform as well as any other worker in terms of productivity.

What’s more, due to the demonstrated commitment of workers with disabilities, there are real cost savings in employing people with disabilities through reduced staff turnover and lower recruitment and retraining costs.

There is strong evidence that people with disabilities take fewer sick and other leave days and stay in the same job longer than other workers. As a result, employment costs for people with disabilities can be as low as 13 per cent of the standard employment costs.

Moreover, workers’ compensation costs for people with disabilities are as low as four percent – this is because people with disabilities have fewer workplace accidents. (Graffam, J, Shinkfield, A, Smith, K, and Polzin, U 2002, ‘Employer benefits and costs of employing a person with a disability’, Journal of Vocational Rehabilitation, vol. 17.)

Given the many benefits of employing people with disabilities, it makes good business sense to think about how you can increase the number of employees with disabilities and support them to do their best work in your organisation.

This means going beyond the legal requirements not to discriminate, towards creating a culture of inclusion where all employees, including those with diverse abilities, can thrive.

An Accessibility and Inclusion Action Plan can help you identify any practices in your business that might result in the exclusion of employees with disabilities. You can then use the findings of your action plan to reduce and eliminate exclusion and discrimination.

To inform our understanding of the current attitudes, understanding and practices in relation to the employment of people with disabilities across the CME sector in Australia, Per Capita undertook an online survey of BCCM members. The survey was open for six weeks and we received more than 100 considered responses, providing us with a ‘sector snapshot’ of disability inclusion in CMEs across Australia.

The sector snapshot contained a lot of positive results.

Most employees in the CME sector already believe their workplace is inclusive of people with disabilities, and overwhelmingly they agree on the importance of disability inclusion.

Employees with disabilities in the sector want managers with the knowledge and understanding to support them.

Managers want this too:

• 66% wanted information and advice on how to employ a person with a disability;
• 59% wanted training and support to understanding the associated legal requirements; and
• 49% wanted information from similar CME businesses with experience employing people with disabilities.

While managers have a tendency to focus on laws and regulations, and on providing accessible physical and operational environments, the survey revealed these issues, while important, to be of less concern to employees with disabilities in the CME sector.

Rather, people with disabilities told us that what makes an inclusive workplace is a diverse and welcoming organisational culture, the availability of flexible working conditions, including working from home and flexibility in office hours, and the presence of understanding colleagues and managers, who provide one-on-one support.

What makes an inclusive workplace?

Although the sector performed strongly on most measures of disability awareness and inclusion, there is clear room for improvement in this key issue of understanding and support for employees with disabilities in the CME sector.

Following the completion of the survey and analysis of its findings, we conducted two workshops to further explore the understanding and awareness of disability inclusion in the CME sector, and to develop an approach to increasing the inclusion of people with disabilities as employees.

The workshops involved leaders from the CME sector nationally, including CEOs, heads of HR and other managers with responsibility for recruitment, personnel and organisational culture.

All participants recognised that the inherent values of cooperatives could be extended to consider the needs of people with disabilities. There is a natural alignment between the values of the cooperative sector and the practice of inclusion, more so than is often found in large organisations.

Some of the ideas from CME leaders that emerged from the workshops are listed below. The ideas are focussed on two key themes: recruitment of people with disabilities, and support and inclusion of employees with disabilities in the workplace.

Recruitment

Recruitment

• Form partnerships with disability employment service (DES) providers
• Advertise that “we support applications from people with a disability”
• Ensure recruiters briefs include an inclusion statement
• Create outcome-based, rather than task-oriented, position descriptions
• Position descriptions and job docs should be in accessible formats, for example, HTML

Vison and narrative

• Rather than recruiting people to fit a job, how we might create the job to fit the person?
• Share experience across organisations about successful disability inclusion programs
• Provide links to videos of how the organisation supports employees with disability
• Share and celebrate failures and successes
• Be clear on the organisational policy of inclusion

Policy and procedure

• Create all positions to suit all abilities (unless not possible due to physical limitations)
• Position descriptions need to be reviewed for inclusion
• Policies, processes, targets – create action plans around each
• Create a job redesign kit for managers
• When designing a role, consider: could it be part-time? Flexible hours? Flexible duties?

Culture and development

• Managers must be open to hiring people with disability
• Be open about what additional supports you can offer
• Identify support people and tools that already exist or could easily be implemented
• Provide support, coaching and training on unconscious bias to HR and other recruiters
• HR must “walk the talk”, for example, by hiring people with disability within their own teams

Tracking and measuring

• Disclose statistics on how many people with disabilities work at your organisation
• Disclose statistics on adjustments made to support employees with disabilities
• Implement bonus rewards for Enterprise Resource Planning
• Understand and evaluate a recruiter’s level of experience with disability recruitment
• Set clear disability inclusion targets and hold staff accountable to meeting them

Support and Inclusion

Physical environment in the workplace

• Create and maintain physically accessible workplaces
• Implement suitable health and safety processes and undertake regular OH&S assessments
• Provide workplace signage in braille
• Provide Auslan interpretation at company events and meetings where requested
• Involve people with disabilities in the design and modification of the workplace

Technological support

• Ensure technological devices are enabling irrespective of disability
• Provide telephones with adjustable volume for those with hearing impairment
• Provide screen readers for computer monitors for employees with vision impairment
• Offer audio description programs for those with a vision impairment
• Internally and externally, advertise the adaptive technology the organisation offers

Management and Human Resources support

• Provide specialist training on disability inclusion to management and HR
• Managers should proactively ask what can be done to support employees with disabilities
• Appoint a workplace mentor to assist with induction and provide ongoing support
• Provide mental health support for all employees, including access to a counsellor
• Make provision for carer support in the workplace, if needed

Flexible working

• Embed KPIs that are focused on outcomes over time, rather than rigid daily achievements
• Provide the option to work from home where possible
• Create flexible schedules to accommodate appointments, travel outside peak hour, etc.
• Create a culture of flexibility by extending flexible work policies to all employees
• Management should model flexible working by using flex hours and working from home

Key steps

Although this toolkit is about helping employers hire and support employees with disabilities (rather than ensuring accessibility for customers) the steps involved in creating your Action Plan will be broadly similar to those used for a standard Disability Action Plan as suggested in the DDA, and outlined in the AHRC’s Guide for Business⁶.

Those key steps are:

1. Review your business practices in relation to employees
2. Devise policies and programs to increase accessibility and inclusion
3. Set goals and targets for their implementation
4. Allocate responsibility for each policy or program, and for evaluation
5. Devise and implement an evaluation process

To assist you in framing an Action Plan tailored to creating an accessible and inclusive workplace for people with disabilities, this toolkit will set out the specific areas of practice in which your business can implement measures to achieve that outcome.

When undertaking the development of policies and actions under each area of practice, you will follow the six key steps set out above.

Areas of practice

Based on the sector-specific information gained through Per Capita’s research for the BCCM in 2018, there two broad categories within which CME sector businesses can take action to embed accessibility and inclusion in their workplaces.

Those categories are:

1. Recruitment (hiring more people with disabilities)
2. Support and Inclusion (providing support to people with disabilities in the workplace)

Within each of these categories, there are specific areas of practice, as set out below.

Recruitment

1. Setting a vision
2. Encouraging applications from people with disabilities
3. Implementing procedures to increase the number of people with disabilities recruited to new roles

Support and inclusion

1. Creating an inclusive culture
2. Providing an appropriate and safe physical environment
3. Providing appropriate technical support
4. Ensuring adequate management and Human Resources support
5. Providing flexible work conditions

Toolkit

The toolkit that follows will set out the approach to take under each of these areas of practice, and provide some concrete examples, drawn from the experiences of other leaders in the CME sector, of specific actions you can implement to develop your Action Plan.

Setting a vision

Step One: Review your business practices

At management level, including the CEO, division heads and Human Resources, consider what your vision is for becoming an accessible and inclusive workplace, and an employer of choice for people with disabilities.

Review your mission statement and HR policies to ensure these reflect your vision and establish the new narrative around accessibility and inclusion.

Step Two: Implement policies and programs

Some policies and processes suggested by other business and HR leaders in the CME sector to develop your accessibility and inclusion vision and narrative include:

• Rather than recruiting people to fit a job, can you look at how you might create the job to fit the person?
• Create video or audio content that illustrates how the organisation supports employees with disability
• Explicitly state your accessibility and inclusion policies when promoting and talking about your company
• Be clear with all staff on the organisational policy of inclusion
• Talk to other leaders in the CME sector and comparable businesses about successful accessibility and inclusion programs they have implemented
• Engage with People With Disabilities Australia and other peak bodies to ensure you are implementing best practice

Step Three: Set goals and targets

This might include:

• Redrafting your mission statement to explicitly mention your commitment to accessibility and inclusion of employees with disabilities
• Redrafting your strategic plan to include specific policies to promote accessibility and inclusion
• Nominating your business for industry awards that recognise accessibility and inclusion of people with disabilities in the workplace

Step Four: Allocate responsibility

Responsibility for vision and narrative would typically sit with the CEO and Board of the company.
Step Five: Devise and implement an evaluation process

This might include:

• Regularly reviewing and updating your mission statement and business plan
• Undertaking regular staff surveys to assess whether your policies and procedures are working as intended to reflect your vision
• Ensuring you share your failures, and lessons learned and celebrate your successes, with your team

Encouraging applications from people with disabilities

Step One: Review your business practices

Start by reviewing your current practices for advertising or otherwise promoting opportunities to work for your company.

For example, some questions you might ask include:

• How do you currently advertise positions?
• Which, if any, recruitment agencies do you use?
• What specifications are included in the briefs you give recruitment agencies, if used?

Step Two: Devise policies and programs

Some policies and processes suggested by other business and HR leaders in the CME sector to encourage applications from people with disabilities include:

• Explicitly state in your advertisements that “We encourage applications from people with a disability”
• Ensure that any briefs sent to recruitment agencies include your accessibility and inclusion statement
• Understand and seek out employment service providers who help facilitate and find roles for people with disability
• Advertise on disability job boards and through disability networks

Implementing procedures to increase the number of people with disabilities recruited to new roles

Step One: Review your business practices

Undertake a thorough review of recruitment practices in your company. Some practices you may need to consider include:

• How can you make roles in your company more suitable for people with disabilities?
• What format and details do you expect on job applications?
• What options do you give applicants for submitting applications and contacting you to discuss opportunities?
• How accessible is your premises for people with disabilities coming for an interview?
• Are position descriptions and other recruitment documents available in accessible formats?
• Do your HR and other recruitment staff have a sufficient understanding of the importance of accessible recruitment practices and of the company’s commitment to the inclusion of people with disabilities as employees?

Step Two: Devise policies and programs

Some policies and processes suggested by other business and HR leaders in the CME sector to support recruiters and make recruitment processes more inclusive included:

• Focus on the necessary outcomes of the job rather than the tasks that are conventionally performed in the role – what can be adapted to adapt the role so it can be performed by people with disabilities and still deliver the same outcome?
• Create outcome-based, rather than task-oriented, position descriptions

• Create all positions to suit all abilities (unless this is not possible due to physical limitations)

• To facilitate this, create a job redesign kit for managers

• Invest in the necessary technology to provide accessible recruitment services to applicants
• Provide recruitment staff with specialised training in accessibility and inclusion, including unconscious bias awareness. and ensure they have the necessary skills and understanding

Step Three: Set goals and targets

These might include:

• Redrafting position descriptions to be outcome-based rather than task-oriented
• Giving individual recruitment staff targets for reaching people with disabilities with job advertisements, and for the number of people with disabilities who apply for roles proportionate to the number of roles advertised
• Engaging new recruitment agencies that specialise in recruiting people with disabilities

Step Four: Allocate responsibility

Responsibility for this practice area would typically sit within the HR department or, if your company does not have a dedicated department, with the person responsible for drafting and placing job advertisements.

Step Five: Devise an evaluation process

This might include:

• Including adherence to inclusive recruitment processes in HR and other recruitment staff’s Key Performance Indicators
• Regularly tracking the number of applications for new roles from people with disabilities

Implementing procedures to increase the number of people with disabilities recruited to new roles

Step One: Review your business practices

Undertake a thorough review of recruitment practices in your company. Some practices you may need to consider include:

• How can you make roles in your company more suitable for people with disabilities?
• What format and details do you expect on job applications?
• What options do you give applicants for submitting applications and contacting you to discuss opportunities?
• How accessible is your premises for people with disabilities coming for an interview?
• Are position descriptions and other recruitment documents available in accessible formats?
• Do your HR and other recruitment staff have a sufficient understanding of the importance of accessible recruitment practices and of the company’s commitment to the inclusion of people with disabilities as employees?

Step Two: Devise policies and programs

Some policies and processes suggested by other business and HR leaders in the CME sector to support recruiters and make recruitment processes more inclusive included:

• Focus on the necessary outcomes of the job rather than the tasks that are conventionally performed in the role – what can be adapted to adapt the role so it can be performed by people with disabilities and still deliver the same outcome?
• Create outcome-based, rather than task-oriented, position descriptions
• Create all positions to suit all abilities (unless this is not possible due to physical limitations)
• To facilitate this, create a job redesign kit for managers
• Invest in the necessary technology to provide accessible recruitment services to applicants
• Provide recruitment staff with specialised training in accessibility and inclusion, including unconscious bias awareness. and ensure they have the necessary skills and understanding

Step Three: Set goals and targets

These might include:

• Setting a date by which all recruitment staff have undergone accessibility and inclusion training
• Setting a target for the proportion of your staff who identify as living with a disability, and a date to achieve it, for example, “within two years, 5% of our workforce will be people with disabilities”
• Establishing clear time frames for reviewing all positions with a view to adapting them to include workers with disabilities
• Establishing clear time frames under which recruitment documentation will be made available in accessible formats

Step Four: Allocate responsibility

Responsibility for this practice area would typically sit within the HR department or, if your company does not have a dedicated department, with the person responsible for managing the recruitment of new staff. However, it is important that support and oversight is provided at the senior management level.

Step Five: Devise an evaluation process

This might include:

• Regularly measuring the proportion of your workforce who identify as living with a disability and benchmarking it against national averages and/or similar businesses.
• Including a statement measuring performance against your recruitment targets and goals in the company’s annual report
• Disclosing statistics on how many people with disabilities work at your organisation and how many reasonable adjustments have been made to support them

Creating an inclusive culture

Step One: Review your business practices

Objectively analyse your organisational culture through the lens of accessibility and inclusion. Some questions you might consider include:

• Do people in leadership positions at your company understand the benefits of having a diverse workforce, including people with disabilities?
• Does your leadership team and senior staff understand their legal obligations towards people with disabilities?
• Are all members of your management team open to hiring people with disabilities?

Step Two: Devise policies and programs

Some policies and processes suggested by other business and HR leaders in the CME sector to create an inclusive culture include:

• Consider engaging an external consultant to undertake an accessibility audit of your workplace and company policies
• Provide your leadership team with training in accessibility and inclusion awareness
• Develop a suite of key statements about the company’s commitment to inclusion and post them in prominent places throughout your workplace
• Require people in management roles to sign a company pledge to support the inclusion of people with disabilities in their teams
• Ensuring that familiarity with your company’s Accessibility and Inclusion Action Plan is part of staff induction and development courses

Step Three: Set goals and targets

These might include:

• A time frame for the completion of an accessibility audit
• Having all managers undertake accessibility awareness training within six months of the audit / three months of commencing a management position
• A deadline by which all staff have taken your company’s inclusion pledge

Step Four: Allocate responsibility

Responsibility for creating an inclusive culture ideally rests with the CEO and Board of an organisation.

Step Five: Devise an evaluation process

This might include:

• Including a statement measuring performance against your Accessibility and Inclusion Action Plan in the company’s annual report
• Monitoring the number of employees who have undertaken accessibility and inclusion awareness training
• Repeating the accessibility audit process at regular intervals, for example, every three years – to obtain independent assessments of your progress

Providing an appropriate and safe physical environment

Step One: Review your business practices

This is one practice area in which an objective and independent assessment of your workplace can be invaluable. That assessment might include:

• Hiring expert consultants to assess the physical environment of your workplace to identify barriers to the participation of people with disabilities. This is usually done as part of an accessibility audit.
• If unable to resource an independent accessibility audit, you can utilise online resources to help you identify any barriers in the physical environment of your workplace that would prevent people with disabilities from working there, or make it more difficult and/or unsafe for them to do so

Step Two: Devise policies and programs

Some policies and processes suggested by other business and HR leaders in the CME sector to ensure your workplace is an appropriate and safe physical environment for employees with disabilities include:

• Creating and maintaining physically accessible workplaces, through the removal of physical obstacles that could restrict movement for those with impaired movement or vision
• Implementing suitable health and safety processes, for example, around evacuation, removing workplace hazards
• Undertaking regular OH&S assessments of potential triggers for conditions such as epilepsy or other sensory disabilities, for example, lighting
• Providing double-glazed windows to reduce ambient noise for people with hearing impairment
• Providing workplace signage in braille for toilets, meeting rooms, etc.
• Providing Auslan interpreters at important company events and significant meetings on request
• Involving people with disabilities in the design and modification of the workplace

Step Three: Set goals and targets

These might include:

• Including all key accessibility measures in your company’s OH&S policy
• A commitment to remove all physical obstacles that could restrict movement for those with impaired movement or vision within three months of identification
• A clear time frame to implement other measures identified in your audit of your workplace’s physical environment as necessary to ensure the inclusion of employees with disabilities

Step Four: Allocate responsibility

Responsibility for ensuring an appropriate and safe physical environment in the workplace is typically the responsibility of the HR department.

Step Five: Devise an evaluation process

This might include:

• Regular reviews or audits of the workplace to ensure new barriers to inclusion don’t inadvertently arise
• Reporting annually on the accessibility of your workplace in line with your OH&S policies

Providing appropriate technical support

Step One: Review your business practices

Again, this is a practice area in which an objective and independent assessment of your workplace can be invaluable. That assessment might include:

• Hiring expert consultants to assess the accessibility of the technology used in your workplace, including computers, telephones, videoconferencing, websites, apps, kitchen equipment and any technologies specific to your business and required by employees to do their jobs. This is usually done as part of an accessibility audit.
• If unable to resource an independent accessibility audit, you can utilise online resources, such as the Web Content Accessibility Guidelines, to help you identify whether your technology assets provide full accessibility for your staff

Step Two: Devise policies and programs

Some policies and processes suggested by other business and HR leaders in the CME sector to ensure you provide appropriate technical support to employees with disabilities included:

• Ensuring technological devices are enabling irrespective of disability
• Providing telephones with adjustable volume for those with hearing impairment
• Providing screen readers for computer monitors for employees with vision impairment
• Eliminating the use of CAPTCHAs and other inaccessible forms of security on IT systems
• Providing desks with adjustable heights
• Providing supportive desktop aids such as cushioned wrist rests for computer use
• Offering audio description programs for those with a vision impairment
• Internally and externally, advertising the adaptive technology the organisation offers

Step Three: Set goals and targets

These might include:

• Creating and publishing an accessible technology policy
• Developing accessible procurement guidelines for staff responsible for purchasing and maintaining technology assets
• A clear time frame to implement other measures identified in your audit of your workplace’s technology assets as necessary to ensure that all technologies are accessible for employees with disabilities

Step Four: Allocate responsibility

Responsibility for ensuring an appropriate and safe physical environment in the workplace is typically the responsibility of the IT department. If your company does not have an IT department or manager, responsibility should be given to the person responsible for purchasing and maintaining technology assets.

Step Five: Devise an evaluation process

This might include:

• Regular reviews or audits of your company’s technology assets to ensure they are complying with the latest accessibility standards
• Reporting annually on the accessibility of your technology assets to ensure they comply with your accessible technology policy and/or accessible procurement guidelines

Ensuring adequate management and Human Resources support

Step One: Review your business practices

This practice area is closely linked to creating an inclusive culture. Research consistently shows that having support from management is critical to ensuring people with disabilities are included and feel valued in the workplace. Some questions you might consider include:

• Do managers of individual business units and teams understand the benefits of having a diverse workforce, including people with disabilities?
• Are those people directly responsible for staff management and development sufficiently informed about their legal obligations and duty of care for employees with disabilities?

Step Two: Devise policies and programs

Some policies and processes suggested by other business and HR leaders in the CME sector to ensure your company provides adequate management and HR support for employees with disabilities included:

• Providing specialist training to managers, including awareness of the benefits of having people with disabilities in the team
• Providing a dedicated HR contact if an employee with a disability has any questions or needs help
• Ensuring that managers proactively ask if there’s anything that can be done to support employees with disabilities
• Appointing a workplace mentor who can assist with induction and provide ongoing one-on-one support
• Providing a safe space and opportunity for an employee with disabilities to explain their condition to co-workers, if requested
• Appointing a disability advocate within the organisation
• Ensuring that staff training accommodates different levels of ability
• Ensuring that a key manager or colleague has knowledge of any required medication or emergency procedures that may be needed
• Providing first aid training for all employees
• Providing mental health support for all employees, including access to a counsellor
• Embedding the right to take regular breaks into workplace agreements
• Providing free hearing and vision tests for all employees
• Making provision for carer support in the workplace, if needed

Step Three: Set goals and targets

These might include:

• Scheduling regular catch-ups between manager / HR representatives and employees with disabilities
• Setting a time frame for implementing training and induction processes to improve inclusion
• Ensuring all staff have had first aid training within 6 months of making it available

Step Four: Allocate responsibility

All managers of staff, along with senior management and HR staff, should take responsibility for providing support to employees with disabilities and for ensuring that all staff contribute to an inclusive workplace culture.

Step Five: Devise an evaluation process

This might include:

• Making support of employees with disabilities and fostering an inclusive work place culture a Key Performance Indicator for anyone with responsibility for staff management
• Including accessibility and inclusion awareness in all staff assessments
• Scheduling regular HR meetings to review instances of complaints or accessibility problems arising in the workplace

Providing flexible work conditions

>Step One: Review your business practices

Implementing flexible work where possible is one of the most effective ways of making work accessibly for people with disabilities. It is worth reviewing your business practices to see where flexible work could be implemented effectively. Some questions you might consider include:

• Are there some roles in your organisation that don’t require people to physically be in the office all the time?
• Do managers in your company rely on measuring the number of hours people are at their desks or work stations to judge performance, rather than assessing the productivity or output of their staff?
• What are the core hours in which your business needs to have staff on premises?

Step Two: Devise policies and programs

Some policies and processes suggested by other business and HR leaders in the CME sector to ensure your company provides adequate management and HR support for employees with disabilities included:

• Embedding Key Performance Indicators (KPIs) that are focused on outcomes over time, rather than rigid daily achievements
• Providing the option to work from home where the role allows it
• Creating flexible schedules to accommodate medical appointments, travel outside peak hour, picking up children from school, etc.
• Providing flexible hours to enable days off when needed to be made up at other times
• Creating a culture of flexibility by extending flexible work to all employees in all roles
• Ensuring management models flexible working by working from home when possible, and utilising flexible hours when needed
• Implement equipment that allow team meetings and collaboration to occur over internet-enabled technologies
• Staggering start and finish times across your team so the workplace is always attended during core hours but individual staff can meet outside commitments

Step Three: Set goals and targets

These might include:

• Creating a roster of work-at-home days for teams and ensuring it is adhered to
• Setting a deadline by which you have adopted an “all roles flex” policy

Step Four: Allocate responsibility

The decision as to whether to allow a role to be worked flexibly is ultimately one for the CEO, but ensuring it is implemented effectively and that productivity does not decline depends on oversight from individual team managers and HR staff.

Step Five: Devise an evaluation process

This might include:

• Regular in-person team meetings to ensure staff working flexibly have the opportunity to collaborate and share work face-to-face
• New methods of assessing performance that measure output and productivity rather than hours
• Tracking who is working flexibly and when, to ensure workloads are evenly distributed

Once you have completed the steps set out in this toolkit, you should have a working draft of your organisation’s Accessibility and Inclusion Action Plan.

The next step to share the draft Action Plan with management and HR to ensure that the measures included are able to be implemented, and to refine any goals and measurement systems.

After you have reached agreement with your company’s leadership team on the contents of your Action Plan, you should publish it and share it with all staff in your company.

You might do this by printing and distributing the document, or publishing it on your company’s intranet.

It is important to invite feedback from staff on the Action Plan, so you can identify any concerns and address any misunderstandings or confusion about the purpose of the Action Plan.

You should also identify a manager or HR representative who can assist staff to understand and, where necessary, alter work practices to comply with the Action Plan.

The Action Plan will only be effective if everyone in your organisation understands their obligations under the Action Plan, and knows where they can go to get assistance to fulfil those obligations.

If you have any further questions about this process, the BCCM can assist you.