Policy paper

Equality and Human Rights Commission Strategic Plan, 2019 to 2022

Published 12 June 2019

This was published under the 2016 to 2019 May Conservative government

Our vision

The Equality and Human Rights Commission exists to protect and promote equality and human rights in Britain.

We stand up for freedom, compassion and justice in changing times. Our work is driven by a simple belief: if everyone gets a fair chance in life, we all thrive.

As we face a future of ever faster and deeper change, we believe that human rights and equality are more important than ever. They are principles with deep roots, built on values we can all recognise, like open-mindedness, respect for human dignity and being fair and decent to one another.

It’s our job to put these important principles into effect, so that everyone in the country can make the most of their rights, everyone can be treated fairly, with dignity and respect, and everyone has the chance to lead a fulfilling life.

We use a range of different tools and techniques to tackle discrimination, disadvantage and human rights abuses. We can shine a light on issues and their causes through inquiries and research. We can support employers and service providers to improve how they work. We can use our unique enforcement powers to require an employer or service provider to act. And we can equip individuals to seek redress, by ensuring they can access good quality legal advice and by supporting legal cases.

Our work reaches every part of England, Scotland and Wales. But we know we can’t do everything and we know we can’t do it alone. That’s why we have to be smart and creative. We have to work in partnership with others. And we have to make tough decisions on where, how and when to spend our time and energy.

Our strategy seeks to ensure that equality and human rights work effectively in Britain to help people live well together, making life safer, happier and more prosperous for all of us.

Our context

We are launching this strategic plan during a period of significant legal, economic, and social change, which will affect equality and human rights in Britain for many years to come. Our plan sets out how we will respond to these challenges over the next 3 years.

As the UK leaves the European Union (EU) and the devolution of power to Scotland and Wales continues, the way in which equality and human rights are protected in our laws will change. Leaving the EU will remove our links to European anti-discrimination legislation and the Charter of Fundamental Rights, and we are likely to see ongoing questions about how best to keep pace with developments and protect international human rights standards in domestic laws. In Wales, there are important debates about strengthening and aligning equality and human rights duties on public bodies and a commitment from the Welsh Government to implement the socio-economic duty. In Scotland, implementation of the socio-economic duty is already underway and there are proposals to significantly enhance the domestic protection of human rights and to reform the Public Sector Equality Duty. These laws are fundamental to our mandate and our role in advising on them will be crucial.

As our population ages, the challenges and disadvantages facing older people and disabled people will become increasingly prevalent. We will work to strengthen the laws protecting them, by seeking further incorporation of relevant human rights, such as the right to independent living. We will tackle discriminatory and abusive treatment in health and social care settings and we will focus on exposing discrimination in recruitment and promoting more inclusive workplaces. We will use our powers to make transport more accessible, to ensure older people and disabled people can participate fully in all aspects of life.

Post Brexit, there will be continued debate about the role immigration plays in our society and economy. Our role in protecting those at most risk of human rights abuses is important in this context, and we will scrutinise the rules regulating immigration detention and the treatment of those who are held in this way.

We are seeing growing divisions in our society reflected in spikes in racial and religious hate crime. The need to foster good relations between communities is increasingly important in this context. We will push for more to be done in the education system to develop shared values and guard against prejudiced attitudes developing. We will work to ensure that schools are truly inclusive places where diverse children mix, children receive their education without discrimination and education instils an understanding of and respect for difference, to create engaged citizens who value equality and human rights. This will be particularly important for people who continue to experience high levels of prejudice, such as lesbian, gay, bisexual and trans people, disabled people, people with specific religions or beliefs and people from ethnic minorities, including Gypsy, Roma and Traveller people.

During 2018, our ‘Is Britain Fairer?’ reports highlighted the significant problems facing our justice system and how access to justice, in relation to equality and human rights issues, has been seriously undermined. But without a realistic prospect of challenge, those with responsibility for complying with the law may feel they can ignore it at will. This is why we have focused our strategic plan on where and how our enforcement powers will have most impact and on tackling the barriers to individuals seeking redress.

Underpinning the goals and priority aims in our plan is an overall deterioration in living standards throughout Britain. Reforms to welfare and tax continue to have a disproportionate impact on the poorest in society, dragging more people into poverty. This creates a cross-generational cycle of disadvantage with the most affected being disabled people, people from some ethnic groups and women. The impact of these changes has not been evenly distributed across Britain. For example, a greater proportion of people in Wales are reliant on welfare than in England and Scotland. And, despite rising employment levels, being in work increasingly does not guarantee an adequate standard of living.

This is why we have set out to focus on the issues affecting the most disadvantaged in society. While we cannot control spending decisions, we will use our litigation and enforcement powers to tackle discriminatory decision-making in the social security system, to ensure people receive the support they are entitled to. We will tackle discrimination in the workplace and promote fair treatment at work, focusing on the lowest-paid sectors of society. We will also work to strengthen the Public Sector Equality Duty and call for the socio-economic duty to be implemented across Britain as these can be critical tools to tackle barriers people face, including  health and housing inequalities.

Finally, our plan looks to the future. Technology plays an increasingly important role in all our lives, affecting many equality and human rights concerns. We will look at the implications of new technology for our justice system, for the accessibility of transport and for decisions made in the workplace. As the nature of the labour market, the workplace and the overall workforce changes, we will lead the thinking on how best to protect against discrimination at work.

How we work across England, Scotland and Wales

Our work both reflects and respects devolution. Evolving local power structures across England present a positive opportunity for us. We know that the issues we work on differ in different locations, particularly in relation to education, work and transport. We will work with local partners to develop our understanding, identifying where we can best use our powers to affect change. We will engage with local decision makers with influence over these issues.

We identify opportunities to advance equality and human rights in the specific political, economic and social contexts of Wales and Scotland. Our Wales Committee and Scotland Committee help us identify and make the most of those opportunities. During the life of this plan, we will advise the Welsh Government on plans to strengthen the equality and human rights legal framework in Wales, including the implementation of the socio-economic duty, and seek to ensure that the curriculum in Wales promotes good relations and respect for equality and human rights. We will also seek to increase the legal advice available in Wales to those whose rights have been breached. We will align our work to tackle inequality with that of other Welsh Commissioners and regulators to ensure maximum impact, including the Office of the Future Generations Commission, whose remit and goal of ‘A more equal Wales’ aligns closely with our own.

In Scotland, we will seek to improve access to justice by tackling barriers to accessing legal aid for discrimination claims and building on our Transfer of Expertise programme with advice roadshows and clinics. We will also seek to influence a number of important legislative opportunities, including on disabled children’s access to mainstream education, and will work to improve aspects of the criminal justice system for women who have experienced sexual abuse.

Our human rights remit in Scotland covers issues which relate to reserved matters only. The Scottish Human Rights Commission (SHRC) has a remit to promote human rights and encourage best practice in relation to human rights in devolved areas. Where the strategic goals, priority aims and planned activities set out in this document relate to human rights they will be advanced in reserved policy areas only, or where appropriate, with the agreement of SHRC in Scotland. We will collaborate and work closely with SHRC where we have a shared interest in advancing human rights on specific issues.

The way we work

We use a number of different tools and techniques to achieve our vision.

From using our policy expertise to influence the development of stronger laws and policies protecting rights; by employing our unique enforcement powers to defend people from unfair or unequal treatment; by creating the conditions for change through our specialist research and evidence base; to our investment in behavioural science and communications to change practice on the ground.

We have thought long and hard about how we can best use these tools to create the most impact in each country to achieve our vision of a Britain where everyone gets a fair chance.

Firstly, it is important we have a broad understanding of the state of equality and human rights across Britain. Our ‘Is Britain Fairer?’ reports and our regular human rights reports reveal the most pressing issues, while our stakeholders help us to understand what is happening in different communities.

We use this information as an evidence base to identify the issues we should prioritise in our strategic plan. We have set out our priority aims for 2019 to 2022 on pages 21 to 27 of this document.

We may conduct an inquiry, carry out research, or speak to those affected to better understand the issues covered by our aims. Once we have a good understanding of the nature and extent of a particular issue and the factors contributing to it, we identify solutions to achieve lasting change. Our solutions are based on the following approach:

1. We ensure that those who make decisions about the laws, policies and practices that affect our everyday lives fully respect and promote equality and human rights laws and principles. We do this by supplying them with evidence, advice, guidance and support. We also use our enforcement powers to require them to take action.

2. We equip and support individuals to gain access to justice when they experience discrimination, or a breach of their human rights. We supply clear information to help them understand and assert their rights, as well as offering direct support to bring legal cases. We also build capacity among those who provide legal advice to individuals, ensuring they are equipped with the necessary knowledge to help people. We will go to communities across Britain to hear about their experiences and seek out cases to support, in order to ensure that those who breach the rights of others understand that they will not get away with flouting the law.

3. We join forces with those who are responsible for overseeing a particular sector, such as regulators, inspectorates or ombudsmen. We encourage them to incorporate equality and human rights in the standards that they set, in how they assess compliance and tackle problems in a particular sector. We know they have an important role to play because of their access to and influence in various sectors, including their ability to advise decision-makers about the laws and policies that govern those sectors.

We have put impact at the heart of our planning process and will specify at the outset of each project the impact we aim to have. We will take the devolved context into consideration when deciding on the most appropriate interventions to achieve this impact.

In developing our plan, we have had due regard to the need to eliminate discrimination, advance equality of opportunity and foster good relations for different groups – women, men, trans people, disabled people, different age groups, people from different ethnic backgrounds, people with different sexual orientations, and people with different religions and beliefs or none. We know that certain characteristics, when combined in an individual, lead to specific forms of discrimination or compound the disadvantage people experience, although there is a need for more data on this. For example, in developing solutions to the issues prioritised in this plan, we will aim to identify the more specific responses that are needed by those facing multiple discrimination and disadvantage.

The importance of prioritising

Equality and human rights touch almost every aspect of life. A person might experience discrimination or a human rights abuse anywhere, from their workplace to their local shop, from their child’s school to their GP’s surgery. The list of issues we could work on is long and prioritising these has not been easy, but it is essential. We have been consistently told by employers, civil society organisations, parliamentarians and public bodies that they want us to concentrate on a smaller number of issues over the longer term. This will allow us to take a deeper look at each issue and devote more resources to addressing a particular problem.

We have been forced to make some difficult decisions about our focus, in order to achieve lasting change. We have selected priority aims that can best be addressed through use of our unique enforcement and litigation powers, placing them at the forefront of our work. For there to be an effective deterrent, it is important that potential perpetrators face a realistic prospect of challenge. With this in mind, we have identified those areas of life where individuals face such serious barriers in accessing justice that our role in standing up for them and in challenging perpetrators is particularly important.

Much of our work is about tackling entrenched inequalities, or long-standing attitudes. We know that fixing these problems will not be quick. While we will review our strategic plan after 3 years, we do not envisage significant changes to our strategic goals or many of our priority aims.

Our core aim

Strong equality and human rights laws protect people, and data shows what is happening to people in practice.

The Commission has a unique role to play in upholding and strengthening the system which protects equality and human rights. At the heart of this strategic plan is our overarching aim: Strong equality and human rights laws protect people and data shows what is happening to people in practice. In working towards this aim, we will concentrate on 3 major areas. Firstly, we will focus on the legal framework which supports equality and human rights in Britain. The loss of the EU Charter of Fundamental Rights is the first big constitutional change emerging from Brexit, and there are crucial questions about how equality and human rights will be best protected in the months and years to come. We will guard against any regression of existing rights and seek to strengthen the legal framework across Great Britain. The Public Sector Equality Duty has not resulted in meaningful progress on some of the inequalities facing some groups, for example in housing and health outcomes. We will focus on ensuring that this duty  is strengthened to require action to  tackle the big issues of the day, that the socio-economic duty is implemented and that the law provides stronger protection  of human rights.

Secondly, we will seek to close any gaps in data which show whether people are experiencing discrimination, inequality or a breach of their rights.

Finally, we will use our unique powers to uphold the system of equality and human rights protections. We will increase our litigation and enforcement work to ensure that the law is working in practice to support equality and human rights.

What we will do

• Influence the development of equality and human rights laws in England, Scotland,Wales and at GB and international level.

• Strategic litigation to strengthen the interpretation of the law.

• Communications activities to build public support for human rights standards.

• Influence bodies responsible for the collection of data.

• Research and partnership working to reduce data gaps.

• Hold the State to account for compliance with international human rights standards,and influence others to do so.

• Send a clear message about the need to comply with equality and human rights law by challenging flagrant breaches.

• Tackle the systemic barriers people face through legal challenges to widespread failures to comply with equality and human rights law.

• Defend the rights of people in the most vulnerable positions experiencing serious breaches of their fundamental rights.

How we will know we have achieved our aim

• Equality and human rights laws are maintained or strengthened.

• Gaps in current data are reduced and data can be broken down by protected characteristics

• Accountability mechanisms for compliance with international human rights standards are strengthened

• Flagrant, systemic and serious breaches are successfully challenged.

Our strategic goals and priority aims

We have identified 3 strategic goals which are key to ensuring everyone in Britain gets a fair chance.

Strategic goal 1: To ensure that people’s life chances aren’t held back by barriers in their way

We believe that if everyone gets a fair chance, we all thrive. Our research makes it clear that across many areas of life, there are still too many people who are losing out, and some groups facing multiple disadvantages who feel forgotten or left behind. We want to help transform life chances, by removing barriers to opportunity.

Strategic goal 2: To make sure we have strong foundations on which to build a more equal and rights-respecting society.

We want the principles of freedom, compassion and justice to be a reality across Great Britain. We can only realise this vision with the right foundations in place – strong legal protections, the ability to enforce those protections, an understanding of where people’s rights are being breached, and a reduction in the prejudice that leads to people being treated unfairly.

Strategic goal 3: To protect the rights of people in the most vulnerable situations

People in the most vulnerable situations are particularly at risk of discrimination and human rights abuses. They may find it difficult to assert their rights in the legal system and lack power in political processes. We will focus on ensuring that the laws, policies and practices protecting their rights are strong and effective.

There is still significant inequality in the workplace. Disabled people and women are more likely to be in low-pay occupations than others, many ethnic minority and older people still face barriers in accessing the workplace, and there is evidence that sexual harassment and bullying at work remain widespread. Insecure employment, with its adverse impact on job quality and living standards, has increased and is particularly likely to affect some groups, including disabled people and specific ethnic groups. In many workplaces, religious believers feel they need to leave their faith at home rather than being able to bring their whole self to work. Many of the implications of new technology on the workplace are only just emerging. Our work will help public and private sector employers of all sizes provide fair opportunities to all and protect workers’ rights.

We will focus our work on 5 priority aims in support of the 3 goals.

Strategic goal 1: To ensure that people’s life chances aren’t held back by barriers in their way

Priority aim 1: People in Britain have equal access to the labour market and are treated fairly at work

What we will do:

• Investigations into discriminatory recruitment practices and breaches of equal pay law
• Support individuals to bring cases to challenge discrimination at work
• Research or inquiries to expose the nature of discrimination and bias in recruitment
• Support employers to address pay gaps and improve recruitment practice
• Strategic litigation to ensure that theEquality Act 2010 offers appropriate protection in new types of employment relationships and the use of new technologies
• Examine the impact of technological developments on individuals’ workplace rights
• Push for greater transparency in employers’ equality outcomes
• Influence Government and Parliament to strengthen the legal and policy framework protecting fairness at work.

How we will know we have achieved our aim:

• Breaches of the law are effectively challenged in order to improve employment practice
• Recruitment companies and job portals change practice
• Pay gaps are exposed and employers implement specific, evidence-led and measurable action plans to address barriers in recruitment, retention and progression
• Governments implement measures to tackle factors driving pay gaps, both in the workplace and at a societal level
• Laws preventing and responding to sexual harassment in the workplace arestrengthened
• Equality and employment law is changed to provide more robust employee rights,protections and means of redress in response to the changing nature of work.

Priority aim 2: Public transport supports the economic and social inclusion of disabled people and older people

When public transport is accessible and appropriate, it allows people to participate fully in all aspects of life – going to work, accessing education or health services and visiting family and friends. However, efforts in this area, particularly to improve public transport for disabled people, are inconsistent.

What we will do:

• Enforcement against transport companies that we suspect are breaching the EqualityAct 2010

• Support passengers to bring cases to challenge discrimination

• Hold advice clinics and provide grants and legal advice for organisations providing support to passengers who have experienced discrimination

• Work with regulators, inspectorates and ombudsman to set standards and tackle poor practice

• Convene industry bodies to identify and tackle access issues

• Support industry bodies to comply with the law

• Influence governments and parliaments to ensure services are designed with regard to the needs of disabled people and older people, and to fill gaps in protection.

How we will know we have achieved our aim:

• Breaches of the law are challenged effectively

• Industry bodies’ policies and practice in relation to the provision of reasonable adjustments are changed to better meet users’ needs

• Gaps in legal protections are reduced

• Equality considerations are central to public transport service design.

Strategic goal 2: To make sure we have strong foundations on which to build a more equal and rights-respecting society

Priority aim 3: People can access redress when they are wronged and have a fair trial in the criminal justice system

Legal rights are of little value unless we are able to seek justice when they are breached, but our 2018 ‘Is Britain Fairer?’ report concludes that it has been increasingly difficult to access representation and redress in British courts.

What we will do

• Inquiries to expose barriers to justice in the civil and criminal justice systems

• Compliance, litigation and enforcement activity to improve policies and practice, in particular tackling decision-making in social security and challenging barriers to justice for women and girls who have survived violence

• Influence parliaments and governments to strengthen the legal and policy framework

• Work with relevant regulators, inspectorates and ombudsmen to influence practice

• Support those advising on equality and human rights disputes, through an adviceline for advisors, advice clinics for advisors and grant schemes.

How we will know we have achieved our aim

• Rules governing access to legal aid for discrimination cases are amended in line with our recommendations

• Mechanisms for seeking redress for breaches of the Equality Act 2010 andHuman Rights Act 1998 are made more accessible and effective

• Practice and procedures in the criminal justice system are improved to ensure a fair trial for disabled people

• Barriers to justice for women and girls who have survived violence are exposed and reduced

• Discriminatory barriers to justice in relation to decision-making in the social security system are reduced

• More people are able to access high quality advice in relation to discrimination and human rights

Priority aim 4

The education system promotes good relations with others and respect for equality and human rights.

Schools and nurseries play an important part in shaping children’s attitudes. We will increase our understanding of the best ways to prevent and change prejudiced attitudes. We will work to ensure that schools are truly inclusive places where diverse children with different beliefs and backgrounds mix, children receive their education without discrimination and education instils understanding of and respect for difference, to create engaged citizens who value equality and human rights and each other. This will be particularly important for people who continue to experience prejudice, and even hate crime, such as lesbian, gay, bisexual and trans people, people with particular religions or beliefs and people from ethnic minorities, in particular Gypsy, Roma and Traveller people.

What we will do

• Support children and parents to bring case to challenge discrimination in the education system
• Hold advice clinics and provide grants and legal advice for organisations which support parents and children
• Litigation and enforcement activity to improve policies and practice
• Support education bodies to improve policies and practice
• Work with relevant regulators, inspectorates and ombudsmen to influence practice
• Inquiry to expose and tackle failures to make reasonable adjustments
• Research to understand what works to tackle prejudice
• Influence governments and parliaments to change laws and policies governing education, such as in relation to the content of curricula

How we will know we have achieved our aim

• Breaches of the law are effectively challenged
• Policy and decisions about the establishment of new schools and admissions are changed to explicitly reference the need to promote equality and good relations following our advice
• Oversight mechanisms are changed to better tackle discriminatory exclusions
• Curriculum subjects are amended to reflect the need to promote equality, good relations and human rights
• Schools’ practice in relation to reasonable adjustments is subject to increased scrutiny
• Universities introduce better mechanisms to tackle racial harassment experienced by staff and students as a result of our inquiry recommendations.

Strategic goal 3: To protect the rights of people in the most vulnerable situations

Priority aim 5

Rules and practice governing entry into, exit from and treatment in institutions respect equality and human rights standards.

Our research has shown that conditions in detention settings in England and Wales, including adult prisons and immigration detention, have deteriorated. There is a lack of data in relation to the use of force on people living in institutions. The UK has no time limit for detaining immigrants and, across England, Scotland and Wales, there are concerns that mental health and mental capacity legislation allows people to be detained or deprived of their liberty without adequate safeguards.

What we will do

• Inquiries to expose the reasons for disproportionality in the detention of people with mental health conditions,the treatment of people in institutions(including use of force and isolation) and the role of private sector operators in immigration settings

• Compliance, enforcement and litigation to improve policy and practice

• Work with oversight mechanisms to tackle discriminatory detention, institutionalisation and/or treatment (including use of force and isolation)

• Support individuals who have experienced discriminatory treatment (including use of force and isolation) in institutions to bring legal challenges

• Influence laws and policies governing detention, institutionalisation and/or treatment (including use of force and isolation).

How we will know we have achieved our aim

• Breaches of the law are effectively challenged

• Legal and policy safeguards are strengthened to prevent people sharing certain protected characteristics from being disproportionately detained,institutionalised or deprived of their liberty

• Legal and policy frameworks are strengthened to ensure that people sharing certain protected characteristics are not subjected to unlawful or improper treatment (including use of force and isolation) in institutions

• Reduction in practice of discriminatory decision-making on detention,institutionalisation and/or deprivation of liberty

• Reduction in practice of unlawful or improper treatment (including use of force and isolation) which violates human rights and equality of people sharing certain protected characteristics in institutions

We have indicated above the high level impact we will seek. Each year in our business plan we will set more specific success measures.

In the first year of implementation of our strategic plan, we will be most active in relation to aims 1, 3 and 5. During this period, we will build our evidence-base and knowledge in relation to aims 2 and 4. We will become more active in relation to aims 2 and 4 during the second and third years of our plan. Our work on the core aim will be a priority throughout the life of the plan.

Our equality objectives

The Public Sector Equality Duty is a ground-breaking legislative tool. It requires public bodies to proactively identify and tackle discrimination, inequalities and promote good relations.

As well as regulating compliance with the duty, we must, of course, also comply with it. We aim to be exemplary in doing so. As part of this, we are required to set equality objectives.

We have prioritised 3 types of equality objectives. These are:

• Objectives in relation to the delivery of our mandate
• Objectives in relation to our people
• Objectives in relation to our intelligence gathering

In relation to each of these, we have described the process we followed and information on which we relied in setting our objectives.

Objectives in relation to the delivery of our mandate

Our mandate, or primary purpose, is set out in section 3 of the Equality Act 2006. Unlike many other public authorities, our core business is to advance the aims of the Public Sector Equality Duty. Therefore, the equality objectives we have set in relation to the delivery of that mandate are the same as the aims we have in this strategic plan:

Core aim: Strong equality and human rights laws to protect people, and data to demonstrate what happens in practice.

Priority aim 1: People in Britain have equal access to the labour market and are treated fairly at work.

Priority aim 2: Public transport better supports the economic and social inclusion of disabled and older people.

Priority aim 3: People can access redress when they are wronged and have a fair trial in the criminal justice system.

Priority aim 4: The education system promotes good relations with others and respect for equality and human rights.

Priority aim 5: Rules and practices governing entry into, exit from and treatment in institutions respect equality and human rights standards.

In setting these objectives, we referred to our evidence base in ‘Is Britain Fairer?’ and talked to stakeholders to identify the key types of discrimination, inequalities and any need to foster good relations. We consulted on our proposals, and analysed the consultation responses to identify patterns in the responses from people and organisations representing particular protected characteristics. In deciding which issues should be prioritised, we looked at the likely impact of our proposals for different groups sharing particular protected characteristics. You can find out more about this analysis in our response to the consultation.

Objectives in relation to our people

As an employer, we will seek to:

• provide an accessible and inclusive working environment and culture where all our staff are treated fairly, are able to perform to the best of their abilities and get support in developing and growing their careers
• increase the diversity of our workforce to reflect the society within which each of our offices are based

In setting these objectives, we have examined our equality information, including workforce diversity data, data identifying discrepancies in pay, appraisal outcomes and training opportunities, and discrepancies in engagement and satisfaction levels expressed in staff surveys. We have also convened a staff group to develop an equality and diversity strategy.

Objectives in relation to our intelligence gathering

Our contact with stakeholders is key to the success of our work. It is only if we hear directly from them about the inequalities and discrimination they experience, that our work will be fully informed. Therefore, we will review the effectiveness of our stakeholder engagement mechanisms with a view to ensuring that they are accessible. We will ensure we are regularly in contact with a representative group of stakeholders in England, Scotland and Wales and that the intelligence we gain is embedded into appropriate decision-making processes.

We have undergone significant change over the last few years, in terms of our structure, people and processes. Given this, we conducted a review of the relevance and impact of each of our functions on the aims of the duty. We used this information to set our equality objectives in relation to our intelligence gathering.

Contacts

This publication and related equality and human rights resources are available from our website.

For information on accessing one of our publications in an alternative format, please contact: [email protected].

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