CBM Policy on Accessibility

Approved by ILT on 15th November 2018 II CBM Policy on Accessibility

ACRONYMS CRPD Convention on the Rights of Persons with Disabilities DID Disability-Inclusive Development DPO Disabled People Organisation HR Human Resources LCDF Legally Contracted Designated Funding ILT International Leadership Team

DEFINITIONS The following definitions are based onCRPD Article 2, except for definition on ‘Accessibility’ which is based on CRPD Article 9.

Accessibility means taking appropriate measures to ensure access to persons with disabilities, on an equal basis with others, to the physical environment, to transportation, to information and communications, including information and communications technologies and systems, and to other facilities and services open or provided to the public, both in urban and in rural areas. These measures, which shall include the identification and elimination of obstacles and barriers to accessibility, shall apply to, inter alia: a) Buildings, roads, transportation and other indoor and outdoor facilities, including schools, housing, medical facilities and workplaces; b) Information, communications and other services, including electronic services and emergency services.

Communication includes languages, display of text, Braille, tactile communication, large print, accessible multimedia as well as written, audio, plain-language, human-reader and augmentative and alternative modes, means and formats of communication, including accessible information and communication technology.

Reasonable accommodation means necessary and appropriate modification and adjustments not imposing a disproportionate or undue burden, where needed in a particular case, to ensure to persons with disabilities the enjoyment or exercise on an equal basis with others of all human rights and fundamental freedoms.

Universal design means the design of products, environments, programmes and services to be usable by all people, to the greatest extent possible, without the need for adaptation or specialized design. ‘Universal design’ shall not exclude assistive devices for particular groups of persons with disabilities where this is needed. CBM Policy on Accessibility 1

Contents

Foreword 3

1. Rationale 4

2. Purpose 7

3. Scope 7

4. CBM’s accessibility statement and commitments 8 CBM’s accessibility statement CBM’s seven accessibility commitments

5. Contextualising accessibility standards 10 Taking into account context realities Working to improve national accessibility standards Promotion of international accessibility standards

6. Governance and accountability for the CBM accessibility policy 12 Adoption Policy implementation Support available for policy implementation Review and monitoring policy Evaluating the policy Complaints mechanism

Annex 1: The Principles of Universal Design 15

2 CBM Policy on Accessibility CBM Policy on Accessibility 3

Foreword

‘Accessibility is everyone’s responsibility and benefits us all. We all have a key role to play in breaking down unnecessary barriers and exclusions in a manner that benefits all including people with physical, sensory, psychosocial and intellectual disabilities.’

Accessibility is a fundamental human disabilities. CBM embraces this updated right and fundamental for people with accessibility policy as a means to disabilities. It is a precondition to ensuring demonstrate our accountability to people the inclusion and participation of women, with disabilities and to reaffirm CBM’s men, girls and boys with disabilities in responsibility to ensure and promote society on an equal basis with others. accessibility based on the principles of It is also an essential condition to universal design in all spheres of our work, realising humanitarian and development in line with the CRPD. frameworks including the Agenda 2030 The updated policy has evolved from a Sustainable Development Goals (SDGs), period of internal reflection about how CBM the Sendai Framework for Disaster can ensure we are meeting the standards Risk Reduction 2015-2030 and the set down by the CRPD on accessibility New Urban Agenda under the core and how we are ensuring accountability commitment and clear mandate of leaving to people with disabilities. The policy has no one behind. been widely consulted upon, drawing in 2018 marks the 10th year of the feedback from all parts of the federation. Convention on the Rights of Persons As CBM, we want this policy to positively with Disabilities (CRPD) entry into inspire change and to give confidence and international law – heralding the vision clarity to our staff and partners in how to of an inclusive world for all people with deliver high quality work. This policy also disabilities. To mark this occasion, I might inspire our alliance and mainstream am delighted to share CBM’s updated partners to join us in promoting the full and accessibility policy which is a Federation- effective participation of all people with wide policy. As an international disabilities to actively contribute to every development organisation with over aspect of the social, cultural, economic and 100 years’ experience supporting political life of their communities. and promoting the rights of people with disabilities, CBM is committed to Dr. William Rowland ensuring equal access and participation Chairperson Supervisory Assembly of all women, men, girls and boys with CBM International CBM Policy on Accessibility 4

1 Rationale

It has been ten years since CBM issued its first accessibility policy along with guidelines for promoting access to the built environment and guidelines for accessible communication and information.

This updated policy demonstrates This policy is also working alongside CBM’s our continued commitment to model Inclusive Employment Framework, accessibility across all functions and levels adopted in February 2017, to ensure of the organisation and to promote it participation of our own staff with amongst our partners. It will help CBM and disabilities and promote inclusion across all our partners to further develop the quality our human resource practices: recruitment, of our work to succeed in modelling good retention and professional development of practice in line with the CRPD. all staff.

With the CRPD, there is a clear expectation The impetus for this policy is that over from international development agencies the past ten years, since the adoption of leading in Disability-Inclusive Development the CRPD, much has changed within the to promote the rights of persons with development and humanitarian sectors. disabilities and model accessibility in line As an organisation, CBM operates in a with CRPD article 9. As a non-state actor legal and policy framework which and in receipt of funding from government recognises that accessibility is a agencies, CBM is expected to comply prerequisite for addressing the full and with CRPD Article 32 on international effective participation of women, men, cooperation, stipulating that international girls and boys with disabilities to exercise cooperation has to be inclusive of and their social, cultural, economic and political accessible to persons with disabilities. This rights on an equal basis with others. also applies to the field of humanitarian The adoption of Agenda 2030, with action where CBM needs to address the strap line of ‘leaving no one behind’ accessibility and inclusion of persons with demands that women, men, girls and disabilities in line with CRPD Article 11 boys with disabilities must equally be on situations of risk and humanitarian able to access and enjoy the full range of emergencies, including the promotion of development opportunities alongside peers. Disability Inclusive Disaster Risk Reduction Equally, the launch of the Charter on (DIDRR) to ensure resilient and inclusive Inclusion of Persons with Disabilities communities. in Humanitarian Action at the first CBM Policy on Accessibility 5

World Humanitarian Summit (Istanbul Longer term, the policy aims to address 2016), and the Sendai Framework for more systemically the need for the Disaster Risk Reduction recognise that effective promotion of Universal Design. humanitarian action must be accessible Addressing Universal Design will effectively for all persons with disabilities, engaged place CBM in a position to influence as critical stakeholders to the success of and contribute to more systemic long emergency response and disaster risk term change and achieving the vision of reduction management programmes accessible and inclusive environments, in every community. Furthermore, the services, programmes, technologies and New Urban Agenda calls for actions to products that are equitable and non- ensure that cities, towns and villages are discriminatory, healthy and safe, resilient inclusive of and accessible to persons with and sustainable, and autonomously usable disabilities. by all within communities, to the widest extent possible. This will ultimately create Building on this, CBM has consulted the most cost-effective and inclusive staff and partners, including Disabled planning for sustainable environments for People’s Organisations, to review our all, in line with Agenda 2030. practices in line with the CRPD. This has resulted in the development of this policy based on our joint learning, especially on identification of gaps that need to be addressed to provide accessibility standards and clearer accountability mechanisms for improved compliance of CBM’s work in line with CRPD Article 9 As an organisation, CBM on accessibility and its further guidance in operates in a legal and policy the CRPD general comment number 2 framework which recognises on accessibility (2014). that accessibility is a prerequisite for addressing the Building on learnings from the previous full and effective participation policy, CBM wants to succeed within the of women, men, girls and boys next five to ten years to ensure that our core systems, practices and programmes with disabilities to exercise are consistently demonstrating good their social, cultural, economic accessibility practice and addressing the and political rights on an equal different access requirements, needs and basis with others. preferences of persons with disabilities. 6 CBM Policy on Accessibility CBM Policy on Accessibility 7

2 3 Purpose Scope

This accessibility policy aims at providing CBM’s accessibility policy is a Federation a framework for CBM with a governance wide policy. The policy is applicable to and accountability mechanism to the entire remit of CBM International’s monitor and improve our practice on work covering: accessibility across all areas of our work: 1. All roles and functions in CBM from internal systems and practices International including staff across to support of partners in delivery of finance and operations, programmes, accessible development and humanitarian communications, initiatives, regional programmes. This policy guides the hubs and country offices; delivery of CBM’s programme standard on accessibility and universal design, 2. CBM partners, consultants, contractors detailed in CBM’s Programme Quality and any other third party providing Framework (PQF). products, goods, services, systems or facilities on behalf of CBM International This accessibility policy aims to ensure that or as part of programmes funded via CBM promotes accessibility in line with the CBM International. CRPD and that we have credibility as an international development agency working The policy is applicable to CBM Member towards Disability-Inclusive Development. Associations. However, it is understood some Member Associations may need to adapt this policy to meet higher national standards which may be legally binding.

CBM International and Member Associations are jointly expected to promote the policy and support implementation with partner organisations.

This accessibility policy aims at providing a framework for CBM with a governance and accountability mechanism to monitor and improve our practice on accessibility across all areas of our work. CBM Policy on Accessibility 8

4 CBM’s accessibility statement and commitments

CBM’s accessibility statement

CBM is committed to promoting equal access and participation of all women, men, girls and boys with disabilities in the countries in which we work. It is CBM’s responsibility, in line with the Convention on the Rights of Persons with Disabilities, to ensure and promote accessibility based on the Principles of Universal Design in all spheres of our work. We will do this by meeting seven core commitments. CBM Policy on Accessibility 9

CBM’s seven accessibility commitments

Our international, regional and country offices and premises are accessible to all 1 persons with disabilities.

Our information and communications, including systems and technologies are 2 accessible to all persons with disabilities.

Our procurement of goods, services and facilities include consideration of accessibility 3 criteria and standards.

Our staff, partners, consultants, contractors and volunteers are aware of CBM’s accessibility policy and receive appropriate support and trainings on 4 accessibility where relevant.

Our programmes and services are non-discriminatory and accessible to all persons with disabilities in their communities regardless of age, gender, faith, 5 ethnicity or any other identity characteristic.

Our meetings and events are accessible 6 to all persons with disabilities.

Our workplaces promote an inclusive and accessible environment that supports all staff to thrive with provision of reasonable accommodation 7 for employees with disabilities, where needed. CBM Policy on Accessibility 10

5 Contextualising accessibility standards

TAKING INTO ACCOUNT as ‘progressive realisation’ in line with the CONTEXT REALITIES CRPD. However, it is important to note that CBM undertakes to meet accessibility where accessibility is not possible, CBM as an standards in recognition of the following employer, has a responsibility to ensure an context realities: accessible work environment for all staff with disabilities through provision of reasonable 1. Accessibilit y is local-environment specific accommodation in response to an individual and may not be transferable from one request. Please see CBM’s staff handbook. area, region or country to another. However, regardless of context and WORKING TO IMPROVE NATIONAL the varying resources available, the ACCESSIBILITY STANDARDS Principles of Universal Design should be applied (See Annex 1). It is understood that the different contexts within which CBM operates have different 2. Ther e are very different contexts within national regulations and standards which which CBM works. In each, the highest CBM has to comply with as a registered standards of accessibility should be NGO. CBM commits to comply with minimum sought within locally available resources, national accessibility requirements and supporting local economies and exceed these where possible in order to meet enhancing environmentally sustainable CBM’s seven commitments in this policy. development approaches. National accessibility standards should be CBM recognises that improving practices measured against the CRPD Article 9 and and achieving quality standards on CRPD General Comment number 2 which accessibility cannot be achieved overnight should be used as the main reference where and will be incremental. This will be based no adequate national standards are in place. on findings of assessments undertaken, working to key priorities according to Where national accessibility standards do not availability of funding. This is understood exist, are poor and not in compliance with CBM Policy on Accessibility 11

CRPD, in the core countries in which CBM PROMOTION OF INTERNATIONAL works, CBM commits to working with DPOs ACCESSIBILITY STANDARDS to advocate change including development Where possible CBM will promote and adoption of national accessibility adherence with the international standards and policies. accessibility standards listed below: In situations of risk and humanitarian For the built environment: emergency minimum accessibility ISO 21542 Building construction – standards should be met in line with the Accessibility and usability of the built Charter on Inclusion of Persons with environment. Disabilities in Humanitarian Action. This is in line with CRPD Article 11 For digital accessibility: on situations of risk and humanitarian ISO/IEC 40500 (Web Content emergencies. Accessibility Guidelines (WCAG) 2.0) and European standard EN301 549. CBM Policy on Accessibility 12

6 Governance and accountability for the CBM accessibility policy

ADOPTION POLICY IMPLEMENTATION

• This policy is valid from the date of Three-step process of policy approval by the International Leadership implementation Team and remains valid until such time Delivery of the accessibility policy requires as an updated policy is approved to offices to follow a three-step process: replace it.

• On approval of the policy, the 1. Accessibilit y assessment of CBM offices International Leadership Team (ILT) will and practices. mandate the International Management 2. D evelopment of a three-year accessibility Team (IMT) to establish an Accessibility action plan setting realistic targets Policy Committee (APC) to oversee with budget requests and an agreed delivery of the policy and to support responsible focal point person. the development and review of the 3. R egular monitoring, learning and review accessibility action plans. of action plans.

Three-step process of policy Accessibility implementation assessment of CBM offices 1 and practices 2 Development of a three-year 3 accessibility Regular monitoring, action plan learning and review of action plans CBM Policy on Accessibility 13

The accessibility action plans will address SUPPORT AVAILABLE FOR each of the seven commitments defined POLICY IMPLEMENTATION in CBM’s accessibility statement (see Technical support section 4) and will be supported with The DID initiative will provide technical technical guidance from DID advisors and oversight to support the delivery of this a companion guide, which helps to clarify policy. Global, regional and, where available, how to implement the three-step process local DID advisors will give technical support and what each of the seven commitments to offices in development, costing and review requires. of their accessibility action plans. Roll out of policy In the absence of a CBM DID advisor in a The roll out of the policy across CBM given location, the CBM Technical Advisor International will be undertaken in two for Accessibility or other DID initiative team phases overseen by the Accessibility Policy members will provide technical support, or Committee: provide links to competent practitioners or • An initial phase from 2018-2019 will partners that can provide this support. consist of working with a select number In addition, a companion guide to this of country and regional hub offices policy will be available to provide guidance, to undertake the three-step process. practical steps and tools to support This will allow troubleshooting of any implementation. implementation issues and provide opportunities to learn, build capacity of CBM International’s IT team are the advisory support team and refine the available to support, troubleshoot and companion guide to this policy. monitor issues that need to be resolved • A second phase from 2020 onwards regarding digital accessibility. They can will see roll out in remaining country, be contacted at CBM’s IT help desk: regional and other offices under CBM [email protected]. International. Member Associations can also call upon the Member Associations will be expected DID Initiative for referrals and advice on to take on the review of their offices and DPOs and technical partners that can support practice against the seven commitments, with the implementation of the accessibility but working to their own time frames and policy if needed. processes. Given that Member Associations Resourcing the accessibility policy do not sit within the CBM International Each office will be responsible for costing up budget system, it is expected that they will their three-year accessibility action plan and use their own annual planning and review submitting a budget to the annual budget systems to take implementation forward. cycle. However, it is expected that they will share learning and progress with the APC on an The Accessibility Policy Committee (APC) annual basis. will be ready to support CBM International CBM Policy on Accessibility 14

management and offices on how to Each office should send to the Accessibility prioritise actions when budget availability Policy Committee an annual progress report is reduced. The APC will also advise on how on implementation of their accessibility best to schedule implementation action plan, including challenges and of the policy in line with availability of DID lessons learned related technical resources. to the agreed accessibility action plan and any changes in delegation of work, Finance and Operations are responsible to including of focal point person. Templates verify and ensure that every CBM office has for this will be available in the accessibility an accessibility budget allocation. This will companion guide. vary considerably and not be uniform given its dependence on the specific action plan EVALUATING THE POLICY and context realities. The Accessibility Policy Committee It is understood that CBM will need to is responsible for commissioning an prioritise interventions based on: evaluation of this policy within five years the availability of funding, technical of adoption. resources and findings of the assessments undertaken. Findings, recommendations and learning from this evaluation will inform subsequent REVIEW AND MONITORING POLICY policy revisions that will in turn be submitted to the ILT for approval. The Accessibility Policy Committee will be in charge of the overall monitoring of the COMPLAINTS MECHANISM implementation of the CBM Accessibility Policy, including baselining and overall CBM regular mechanisms for feedback progress of achievements toward the and complaints should be used by staff or seven commitments. partners for any concerns. These are:

The Committee will report the progress • For serious complaints by staff, or for on an annual basis to the International systemic non-compliance, the HR dispute Management Team and will advise resolution process should be used. when amendments may be required to • F or regular staff concerns these should the policy based on learning and latest be communicated through the line developments. management system. Each office is responsible for reporting • F or complaints by partners/ external and lodging their three-year accessibility agencies regarding CBM’s accessibility, action plan with the Accessibility Policy CBM’s main complaints mechanisms Committee who will review them prior to should be used. These are detailed on annual budget approval and support with CBM’s website under the accountability prioritisation of actions as needed. and reporting page.

ANNEX

The Principles of Universal Design

Version 2.0 - 4/1/97 Compiled by advocates of universal design, listed in alphabetical order:

Bettye Rose Connell, Mike Jones, Ron Mace, Jim Mueller, Abir Mullick, Elaine Ostroff, Jon Sanford, Ed Steinfeld, Molly Story, and Gregg Vanderheiden

Major funding provided by: The National Institute on Disability and Rehabilitation Research, U.S. Department of Education CBM Policy on Accessibility 16

Universal Design

The design of products and environments to be usable by all people, to the greatest extent possible, without the need for adaptation or specialized design.

The authors, a working group of of the key elements that should be present architects, product designers, engineers in a design which adheres to the principle. and environmental design researchers, (Note: all guidelines may not be relevant to collaborated to establish the following all designs.) Principles of Universal Design to guide Principles of Universal Design are available a wide range of design disciplines, in other languages as provided on other including environments, products, and websites, including: Dutch, Italian, French, communications. These seven principles German, Japanese, Portuguese, Spanish, may be applied to evaluate existing Swedish. designs, guide the design process and educate both designers and consumers The Center for Universal Design had no about the characteristics of more usable involvement in the translation of the products and environments. Principles of Universal Design© into other languages. These links are solely provided The Principles of Universal Design are as a service. If you are aware that the presented here, in the following format: Principles of Universal Design© are available name of the principle, intended to be a in other languages on the internet, or in the concise and easily remembered statement existence of a more ‘definitive’ version than of the key concept embodied in the the one listed, please contact the Center at principle; definition of the principle, a [email protected]. brief description of the principle’s primary directive for design; and guidelines, a list

These seven principles may be applied to evaluate existing designs, guide the design process and educate both designers and consumers about the characteristics of more usable products and environments.

PRINCIPLE PRINCIPLE 1 2

Equitable Use Flexibility in Use

The design is useful and marketable The design accommodates a wide to people with diverse abilities. range of individual preferences and abilities. Guidelines: • Pro vide the same means of use Guidelines: for all users: identical whenever • Pro vide choice in methods of use. possible; equivalent when not. • Accommodate right- or left-handed • A void segregating or stigmatizing access and use. any users. • F acilitate the user’s accuracy • Pro visions for privacy, security, and and precision. safety should be equally available to • Pro vide adaptability to the all users. user’s pace. • Ma ke the design appealing to all users.

PRINCIPLE PRINCIPLE 3 4

Simple and Perceptible Intuitive Use Information

Use of the design is easy to The design communicates understand, regardless of the necessary information effectively user’s experience, knowledge, to the user, regardless of ambient language skills, or current conditions or the user’s sensory concentration level. abilities.

Guidelines: Guidelines: • Eliminate unnecessary complexity. • Use different modes (pictorial, verbal, tactile) for redundant presentation • Be consistent with user of essential information. expectations and intuition. • Provide adequate contrast between • Accommodate a wide range of literacy essential information and its and language skills. surroundings. • Arrange information consistent • Maximize ‘legibility’ of essential with its importance. information. • Provide effective prompting and • Differentiate elements in ways that feedback during and after task can be described (i.e., make it easy to completion. give instructions or directions). • Provide compatibility with a variety of techniques or devices used by people with sensory limitations.

PRINCIPLE PRINCIPLE 5 6

Tolerance Low Physical for Error Effort

The design minimizes hazards The design can be used efficiently and the adverse consequences of and comfortably and with a accidental or unintended actions. minimum of fatigue.

Guidelines: Guidelines: • Arrange elements to minimize • Allow user to maintain a neutral hazards and errors: most used body position. elements, most accessible; hazardous • Use reasonable operating forces. elements eliminated, isolated, or shielded. • Minimize repetitive actions. • Provide warnings of hazards • Minimize sustained physical effort. and errors. • Provide fail-safe features. • Discourage unconscious action in tasks that require vigilance.

PRINCIPLE 7

Size and Space for Please note that the Approach and Use Principles of Universal Design address only universally usable design, while the practice of Appropriate size and space is design involves more than provided for approach, reach, manipulation, and use regardless consideration for usability. of user’s body size, posture, Designers must also incorporate or mobility. other considerations such as economic, engineering, cultural, Guidelines: gender, and environmental • Provide a clear line of sight to concerns in their design important elements for any seated processes. These Principles offer or standing user. designers guidance to better • Make reach to all components integrate features that meet comfortable for any seated or the needs of as many users standing user. as possible. • Accommodate variations in hand and grip size. • Provide adequate space for the use of assistive devices or personal assistance.

© 1997 NC State University, The Center for Universal Design Photography credits Page 2 © CBM Page 6 © CDD (CBM Database) Page 8 © CBM/Alba Gonzales/Benjamin Dard Page 11 © CBM/Thomas Lohnes Page 15 ©CBM/Benjamin Dard