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FRATRES
Conduct & responsibility

Accessibility Statement

The accessibility standard this website targets, known limitations, and how to report an accessibility barrier.
Document reference
FGL-LEG-18
Version date
1 July 2026
Applies to
Fratres Limited

1.Interpretation and definitions

In this Accessibility Statement the following capitalised terms bear the meanings given to them below. Terms defined in the Web Content Accessibility Guidelines and not otherwise defined here bear the meanings given to them in that document.

Company
Fratres Limited, a private company limited by shares incorporated and registered in England and Wales, being the operator of the Website.
Website
The website published at fratresgroup.com, together with every subdomain, sub-directory and page operated by or on behalf of the Company under that domain.
Statement
This Accessibility Statement, as amended and republished from time to time in accordance with clause 16.
WCAG
The Web Content Accessibility Guidelines published by the World Wide Web Consortium. References in this Statement to WCAG are references to version 2.2 unless a different version is expressly identified.
Level AA
The intermediate of the three conformance levels defined by WCAG. Conformance at Level AA requires that every Level A and every Level AA success criterion is satisfied, or that a conforming alternative version is provided.
Success Criterion
An individual, testable requirement stated in WCAG, cited in this Statement by its numeric reference and title.
EN 301 549
The harmonised European standard setting accessibility requirements for information and communication technology products and services, which incorporates WCAG at Level AA as the requirement applicable to web content.
Assistive Technology
Hardware or software that a person uses to perceive, operate, understand or interact with the Website, including screen reading software, screen magnification software, speech recognition software, switch access devices, refreshable braille displays and alternative pointing and keyboard devices.
Accessibility Barrier
Any feature, omission or behaviour of the Website which prevents or makes unreasonably difficult the perception, operation or understanding of the Website by a person, whether or not that feature also constitutes a failure of a Success Criterion.
Alternative Format
A version of content published on the Website supplied by a different means or in a different form, including structured plain text, large print, or a document prepared for use with Assistive Technology.
Reasonable Adjustment
A step required to be taken under sections 20 and 29 of, and Schedule 2 to, the Equality Act 2010 to avoid a substantial disadvantage to a disabled person arising from a provision, criterion or practice, or from the absence of an auxiliary aid.
Enquiry Form
The enquiry form published at fratresgroup.com/contact, being the sole channel through which the Company receives enquiries and reports from the public.
Business Day
Any day other than a Saturday, Sunday or public holiday in England and Wales.
Visitor
Any person who accesses the Website, whether or not that person subsequently makes an enquiry or enters into any relationship with the Company. References in this Statement to “you” are references to the Visitor.
1.1
Headings are inserted for convenience only and shall not affect the construction of this Statement.
1.2
Words importing the singular include the plural and words importing one gender include every gender.
1.3
A reference to a statute or statutory provision is a reference to it as amended, extended or re-enacted from time to time, and includes subordinate legislation made under it.
1.4
A reference to WCAG, to EN 301 549 or to any other technical standard is a reference to the version identified in this Statement and, where no version is identified, to the version current at the version date stated at the head of this document.
1.5
Any phrase introduced by the words “including”, “in particular” or “for example” shall be construed as illustrative and shall not limit the generality of the words preceding it.

2.Purpose, scope and status

2.1
The purpose of this Statement is to record, in terms capable of being checked by the reader, four things: the accessibility standard the Website is built to meet; the specific measures taken to meet it; the respects in which the Website presently falls short of it; and the means by which a person may report an Accessibility Barrier and obtain the content by another route in the meantime.
2.2
This Statement applies to the Website in its entirety, including every page of the legal register of which this Statement forms part, the Enquiry Form, the site navigation overlay and the cookie preference mechanism.
2.3
This Statement does not apply to third-party websites to which the Website links. The Company does not control the accessibility of those destinations and makes no representation about them. Where the Company links to material that a Visitor is likely to need in order to deal with the Company, and that material is inaccessible, clause 14 applies and the Company shall supply the substance of it by another means.
2.4
The Company publishes no mobile application, no downloadable software and no document repository. Should any of these be published, this Statement shall be extended to cover them before they are made available, and the version date at the head of this document shall be revised accordingly.
2.5
This Statement is a public commitment by the Company and a statement of its present assessment. It does not form part of any contract, and it does not vary the Terms of Business for Client Engagements or the Terms & Conditions of Website Use. Nothing in it excludes or limits any right conferred on any person by the Equality Act 2010 or by any other enactment.
2.6
This Statement is to be read together with the Privacy Policy, the Cookie Policy and the Complaints Handling Procedure. Where this Statement and the Complaints Handling Procedure both address the escalation of an unresolved matter, the Complaints Handling Procedure prevails.

3.The standard targeted

3.1
The Company targets conformance with WCAG version 2.2 at Level AA across the whole of the Website. That standard is adopted for every page template without exception, including the pages of the legal register, which are frequently the pages a person most needs to be able to read.
3.2
WCAG organises its requirements under four principles: content must be perceivable, operable, understandable and robust. Within those principles it states individual Success Criteria at three levels of conformance, being Level A, Level AA and Level AAA. Level AA is the level ordinarily adopted as the benchmark for public-facing web content, and it subsumes every Level A criterion.
3.3
A claim of conformance under WCAG is subject to five conformance requirements, each of which the Company treats as binding on itself:
  • (a)the stated conformance level must be satisfied in full, no partial claim being permitted;
  • (b)conformance is claimed for full pages, and not for parts of pages;
  • (c)where a page forms one step in a process, every page in that process must conform, so that a person is not stranded partway through;
  • (d)only accessibility-supported ways of using technologies may be relied upon to satisfy a Success Criterion; and
  • (e)technologies which are not relied upon must not interfere with the ability to access the rest of the page.
3.4
Version 2.2 of WCAG added Success Criteria which did not appear in earlier versions. Those added at Level A are 3.2.6 Consistent Help and 3.3.7 Redundant Entry. Those added at Level AA are 2.4.11 Focus Not Obscured (Minimum), 2.5.7 Dragging Movements, 2.5.8 Target Size (Minimum) and 3.3.8 Accessible Authentication (Minimum). Version 2.2 also withdrew Success Criterion 4.1.1 Parsing, which is accordingly not addressed in this Statement. The Company assesses the Website against the added criteria as well as the criteria carried forward, and records in clause 11 the one respect in which an added criterion is not met.
3.5
Where a Level AAA criterion is satisfied, it is satisfied because the design produced that outcome and not because the Company has undertaken to meet Level AAA. No commitment to Level AAA is made or implied.
3.6
The Company treats WCAG as a floor and not a ceiling. A report that the Website is difficult to use will be investigated and, where the difficulty is real, addressed, whether or not the difficulty amounts to a failure of a Success Criterion.

5.Structure, semantics and navigation

5.1
The Website is built from semantic HTML. Structure is expressed in the markup itself rather than in visual styling, so that the meaning available to a sighted reader is also available programmatically to Assistive Technology.
5.2
The following structural measures are implemented across every page template:
  • The document language is declared as British English on the root element of every page, so that speech synthesis selects the correct pronunciation rules.
  • Each page carries exactly one first-level heading, and subordinate headings descend in order without levels being skipped. Headings are real heading elements; no text is made to look like a heading by styling alone.
  • Each page is divided into landmark regions — a banner, a single main region, a content-information footer and navigation regions — so that a person using Assistive Technology may move directly between the parts of the page.
  • Where more than one navigation region appears on a page, each carries a distinct accessible name. On the pages of the legal register the clause index is exposed as a navigation region named “Contents”.
  • Lists are marked up as lists, ordered where the order carries meaning and unordered where it does not. The clause index and the numbered process sequences are ordered lists; definition tables are description lists with paired terms and descriptions.
  • A “Skip to content” link is the first element to receive focus on every page. It is visually hidden until focused, becomes plainly visible on focus, and moves focus to the start of the main region.
  • Anchored links within a document account for the height of the fixed navigation bar, so that a clause heading reached from the contents index is not concealed beneath it.
  • Every page carries a unique and descriptive title, formed from the page name and the name of the Company, so that a page can be identified from a browser tab, a history entry or a list of open windows.
  • Purely presentational marks — the em rule that precedes each bulleted item, the arrow glyph on a link, the menu icon and the oversized vertical wordmark on photographic headers — are hidden from Assistive Technology so that they are not announced as content.
5.3
The reading order of the underlying document matches the visual reading order. The only place where the two diverge is an editorial layout in which an image and its accompanying text exchange sides at wide viewport widths; the sequence in which the two are read is unaffected and no meaning depends on which side the image occupies.
5.4
Instructions and descriptions do not rely on sensory characteristics. The Website does not direct a reader to “the box on the right” or to “the green button”; controls are identified by their visible text label.
5.5
Navigation is consistent. The same navigation mechanisms appear in the same relative order on every page, and components with the same function are identified by the same label wherever they appear. The route by which help may be obtained — the link to the Enquiry Form — appears in the same position in the footer of every page and in the same position within the navigation overlay, in satisfaction of Success Criterion 3.2.6 Consistent Help.
5.6
No change of context occurs automatically. Focusing a control does not navigate, submit or alter the page; changing the value of a control does not navigate or submit. Every navigation and every submission follows an explicit action by the Visitor.

6.Keyboard operability and focus

6.1
Every function of the Website is operable through a keyboard interface alone, without requiring specific timings for individual keystrokes. Interactive controls are native links and native buttons; no control is constructed from a non-interactive element with a click handler attached to it.
6.2
Focus order follows the order of the document. No positive tab index value is used anywhere on the Website, and the sequence in which controls receive focus therefore preserves meaning and operability.
6.3
A focus indicator is applied globally, as a two-pixel outline offset from the focused element by three pixels. It is never suppressed, and it is applied by way of the focus-visible mechanism so that it appears for keyboard and Assistive Technology users without appearing spuriously on pointer interaction. The limitation recorded at clause 11.4 applies to this indicator in one context.
6.4
The full-screen navigation overlay is implemented as a modal dialogue and behaves accordingly:
  • (a)the control which opens it is a button which reports whether the overlay is open and which identifies the element it controls;
  • (b)the overlay is exposed as a modal dialogue with an accessible name;
  • (c)focus is moved into the overlay when it opens;
  • (d)tabbing cycles within the overlay while it is open and does not escape into the page behind it;
  • (e)the Escape key closes the overlay from anywhere within it, and a visible close control is also provided;
  • (f)focus is returned to the control which opened the overlay when it closes; and
  • (g)the scroll position of the underlying page is preserved and restored.
6.5
When the navigation overlay is closed it is removed from the page entirely for the purposes of interaction: it is hidden by way of the visibility property rather than by opacity alone, so its links are removed from the tab order and from the accessibility tree and cannot be reached by a keyboard user or announced by a screen reader.
6.6
The cookie preference dialogue follows the same pattern. It is exposed as a modal dialogue named by its own heading and described by its explanatory text, it traps and restores focus, and it may be dismissed with the Escape key. Dismissal by that route is treated as a refusal to decide and records no consent. The controls to accept and to decline are given equal prominence and require equal effort.
6.7
There is no keyboard trap on the Website other than the two modal cycles described above, each of which may be left by pressing Escape or by activating a visible control.
6.8
The Website imposes no time limit of any kind. There is no session expiry, no countdown, no timed redirect and no content which updates, moves or refreshes itself. A person may take as long as they require on any page or on the Enquiry Form.
6.9
No function of the Website requires a dragging movement, a multipoint gesture or a path-based gesture, in satisfaction of Success Criterion 2.5.7 Dragging Movements. Every action is completed by a single activation of a control.
6.10
Buttons and links styled as buttons present a target substantially larger than the twenty-four by twenty-four pixel minimum required by Success Criterion 2.5.8 Target Size (Minimum). Radio buttons and checkboxes on the Enquiry Form are rendered at the size supplied by the browser, which may be smaller than that minimum; each is enclosed within a label whose full visible text is itself part of the target, and the controls are spaced so that the target of one does not intrude upon the target of another.
6.11
No part of the Website requires a person to authenticate. No cognitive function test — no puzzle, no transcription task and no CAPTCHA — is imposed on any person at any point, and Success Criterion 3.3.8 Accessible Authentication (Minimum) does not arise.

7.Colour, contrast and visual presentation

7.1
The Website uses a fixed and deliberately narrow palette. Contrast ratios for the combinations used to carry text have been measured against the page background and are stated below so that the reader may verify them.
  • Primary body text, headings and clause numbering are set in the dark bark tone on the cream page, measuring approximately 11.8 to 1. This substantially exceeds the 4.5 to 1 required by Success Criterion 1.4.3 Contrast (Minimum) and also exceeds the 7 to 1 required at Level AAA.
  • Secondary body text, used for definitions, descriptions and supporting paragraphs, is set in the mid earth tone, measuring approximately 4.7 to 1 and satisfying Success Criterion 1.4.3 for text at any size.
  • The single primary action on any view is white text on deep teal, measuring approximately 9.6 to 1. Outlined secondary actions are dark bark text on cream at approximately 11.8 to 1.
  • The focus indicator is deep teal, measuring approximately 9.1 to 1 against the cream page.
  • The skip link, when focused, is white text on deep teal at approximately 9.6 to 1.
  • The exception is the light grey tone used for captions, metadata and hint text, which is recorded as a non-conformance at clause 11.2.
7.2
No information is conveyed by colour alone. Where the Website uses a chromatic accent — the coloured hairline on a card, or the accent assigned to a sector — that accent is decorative. It distinguishes one card from another visually but carries no meaning which is not also stated in the text of the card itself.
7.3
Links within running prose carry a permanent underline in addition to a change of colour, so that they remain identifiable without reliance on colour perception. The behaviour of links presented in navigation lists is recorded at clause 11.6.
7.4
Validation errors on the Enquiry Form are never signalled by colour. Each is signalled by a written message beneath the field, by an entry in a summary at the head of the form, by a programmatic invalidity state and by a change in the weight of the field underline.
7.5
Text is real text throughout. No text is presented as an image; the wordmark itself is live text rather than a graphic, and Success Criterion 1.4.5 Images of Text is satisfied without exception.
7.6
The design carries no shadow, no gradient and no background fill behind running text. Separation is achieved with hairlines and with the contrast between the cream page and white surfaces. This is an editorial decision, but it also removes a common source of unpredictable contrast where text is laid over a graded background.
7.7
The layout is fluid. Multi-column arrangements collapse to a single column at narrow viewport widths, no container is set to a fixed pixel width, and no horizontal scrolling is required to read a block of content. The measure of long-form text is capped so that no line becomes uncomfortably long on a wide display.
7.8
Text spacing is not constrained by the stylesheet in a way which would prevent a person from overriding it. Line height, paragraph spacing, letter spacing and word spacing may be increased by a user stylesheet or browser extension to the values contemplated by Success Criterion 1.4.12 Text Spacing without content being clipped or lost, because containers are sized by their content rather than to fixed heights.
7.9
Nothing on the Website appears on hover which does not also appear on keyboard focus, and no content obscures other content when hovered. There are no tooltips, no hover cards and no menus which open on hover alone.
7.10
The Website does not restrict its display to a single orientation. Every page is legible and operable in both portrait and landscape.

8.Motion, animation and resilience

8.1
Motion on the Website is deliberately minimal. The only animation of content is a short fade and rise applied once to a block of content when it first enters the viewport. Beyond that there are brief colour and position transitions on hover, and the opening and closing of the navigation overlay.
8.2
A stated preference for reduced motion is honoured in two independent places, so that the preference is respected even if one mechanism fails:
  • (a)a global stylesheet rule reduces the duration of every animation and every transition to an imperceptible interval, disables smooth scrolling and renders revealed content immediately visible; and
  • (b)the script which observes content entering the viewport queries the same preference and, where it is set, marks all content visible at once without observing anything or running any animation.
8.3
Nothing on the Website moves, blinks, scrolls or updates automatically. There is no carousel, no marquee, no parallax effect, no automatically advancing content and no audio or video which begins to play without being started by the Visitor. Success Criteria 2.2.2 Pause, Stop, Hide and 1.4.2 Audio Control accordingly do not arise.
8.4
No content flashes. Nothing on the Website flashes more than three times in any one-second period, and Success Criterion 2.3.1 Three Flashes or Below Threshold is satisfied.
8.5
The reveal effect is applied only where scripting is available. Where scripting is unavailable, disabled or blocked, the rule which hides content prior to reveal is never applied and every page renders in full. A failsafe timer additionally reveals any block which the observer has not reached within four seconds. Content is therefore never left invisible by a failure of script.
8.6
The Website is delivered as server-rendered HTML. The substance of every page — including the whole of the legal register — is present in the markup delivered to the browser and does not depend on client-side script to appear.

9.Text alternatives and non-text content

9.1
Every image which carries content on the Website is rendered through a shared component which requires a text alternative as a mandatory parameter. The alternative cannot be omitted: a page which failed to supply one would not build. This is a structural control rather than a matter of editorial discipline, and it is the reason the Company is able to state without qualification that no content image on the Website lacks a text alternative.
9.2
Text alternatives describe the content and function of the image in the context in which it appears, rather than restating the adjacent heading.
9.3
Decorative and redundant graphics are hidden from Assistive Technology so that they are not announced. This applies to the arrow glyph which accompanies a link label, the two-rule menu icon, the oversized vertical wordmark set over photographic headers, and the brand mark wherever it appears beside the visible word “FRATRES”.
9.4
Where the brand mark stands alone as a link to the home page, the link carries an accessible name identifying both the Company and the destination, so that its purpose is clear when the link is encountered out of context in a list of links.
9.5
The Website publishes no audio, no video and no other time-based media. Success Criteria concerning captions, audio description and transcripts therefore do not presently arise. Should the Company publish time-based media in future, it shall be published with synchronised captions and a text transcript, and with audio description where the visual track carries information not present in the audio track.
9.6
The Website publishes no scanned document, no image of a page of text and no downloadable file. Should the Company publish a document for download in future, it shall be structured for accessibility, with a reading order, heading structure and document language properly declared, and an Alternative Format shall be available under clause 14.

10.Forms, labelling and error handling

10.1
The Enquiry Form is the principal interactive element on the Website and is the route by which a person makes contact with the Company. It has been built to the standard which that importance requires.
10.2
Every field carries a persistently visible label, associated with its field programmatically. No field relies on placeholder text to convey its label, and no label disappears when the field is completed. Field identifiers are generated uniquely, so that the association between a label and its field cannot be broken by the form appearing more than once in a page.
10.3
Related controls are grouped. The type of enquiry is presented as a group of radio buttons within a fieldset with a legend; the optional sectors of interest are presented as a group of checkboxes within a fieldset with a legend. The group name is therefore announced together with each option.
10.4
Instructional text is associated with the field it describes, so that it is announced when the field receives focus rather than being encountered only by a reader moving linearly through the page.
10.5
Fields which collect information about the person completing the form carry the standard autocomplete tokens for name, organisation, organisational role and country. A person may therefore use browser or Assistive Technology autofill rather than typing the same details again, in satisfaction of Success Criterion 1.3.5 Identify Input Purpose.
10.6
The form asks for no information twice. No value already supplied within the same submission is requested again, in satisfaction of Success Criterion 3.3.7 Redundant Entry.
10.7
Where a submission cannot be accepted, error handling operates as follows:
  • (a)each field in error is identified programmatically as invalid;
  • (b)a message in plain language is placed beneath the field, associated with it so that it is announced with the field, and the message states how to correct the problem rather than merely stating that a problem exists;
  • (c)a summary appears at the head of the form listing every field in error, each entry being a link which moves focus to the field concerned;
  • (d)focus is moved to the first field in error, so that a keyboard user is placed at the problem rather than having to hunt for it;
  • (e)the number of fields requiring attention, and the fact that nothing has been submitted, are announced through a polite live region which does not interrupt anything already being read; and
  • (f)once a submission has been attempted, validation runs again as values change, so that messages clear as problems are corrected rather than persisting until the next submission.
10.8
Native browser validation is suppressed in favour of the mechanism described above. This is deliberate: it allows the wording of every message to be written in plain language, placed in a predictable position and announced consistently, rather than being left to the browser.
10.9
Consent to the handling of the information supplied is collected through a separate, unticked checkbox with its own visible text, adjacent to a link to the Privacy Policy. Nothing is pre-selected and consent is never bundled with the act of submission.
10.10
The outcome of a submission, whether successful or not, is announced through a live region, so that a person not watching the screen is told what has happened.
10.11
No field is subject to a time limit, and the form does not clear itself.

11.Known limitations and non-conformances

11.1
The Company does not claim that the Website conforms fully with WCAG 2.2 at Level AA. The following are the respects in which the Website is known not to meet that standard, or in which its accessibility is otherwise limited. Each is stated with the Success Criterion affected so that the reader may judge the significance for themselves. This list is maintained as findings are made and is not represented as exhaustive.
11.2
Contrast of secondary text — Success Criterion 1.4.3 Contrast (Minimum), not met. A light grey tone is used for captions, metadata, note text, the hint text within the Enquiry Form and the corporate disclosure block in the page footer. Measured against the cream page background it yields approximately 2.8 to 1, below the 4.5 to 1 required. Some of the affected text is genuinely supplementary, but the hint text within the Enquiry Form is not, and the Company does not rely on that distinction: this is a failure. Replacement of the tone across the design system is the first item in the remediation programme.
11.3
Contrast of form field boundaries — Success Criterion 1.4.11 Non-text Contrast, not met. Text inputs are drawn as a single-pixel underline in a pale tone measuring approximately 2.1 to 1 against the background, below the 3 to 1 required for the visual boundary of a user interface component. The practical effect is mitigated by the persistently visible label above each field, and the underline thickens and turns deep teal on focus, but the boundary of the unfocused field is insufficiently distinct.
11.4
Focus indicator within the navigation overlay — Success Criterion 1.4.11 Non-text Contrast, not met. The deep teal focus indicator contrasts strongly against the cream page, at approximately 9.1 to 1, but the navigation overlay is set on the dark bark tone, against which the same indicator measures approximately 1.3 to 1 and is effectively invisible. A keyboard user opening the navigation overlay may be unable to see which link holds focus. The Company regards this as the most serious of the limitations recorded here and it is prioritised accordingly.
11.5
Focus obscured by the fixed navigation bar — Success Criterion 2.4.11 Focus Not Obscured (Minimum), partially met. The navigation bar is fixed to the top of the viewport at a height of fifty-six pixels. An element which receives focus immediately below the top edge of the viewport may be partly concealed behind it. Links followed from a contents index carry a scroll offset which clears the bar; the limitation arises during sequential keyboard navigation after the page has been scrolled.
11.6
Link identification in navigation lists — Success Criterion 1.4.1 Use of Colour, met with qualification. Links presented in navigation lists, in the footer columns and in the contents index reveal an underline on hover rather than carrying one at all times. They are distinguished from surrounding content by their position and container rather than by colour alone, and links within running prose are underlined permanently, so the criterion is not failed. The Company records the behaviour here because a reader may reasonably regard it as a limitation.
11.7
Absolute type sizes — Success Criterion 1.4.4 Resize Text, met with qualification. Type sizes are expressed in absolute pixel units. Text scales correctly under browser and operating system zoom to at least two hundred per cent, which is what the criterion requires, but it does not respond to a change in the browser’s default font size setting. A person who has configured a larger default font size in their browser, rather than using zoom, will not see the effect of that setting on this Website.
11.8
Language of parts — Success Criterion 3.1.2 Language of Parts, not met. Occasional words of Latin or Bengali origin appear in the editorial content without an attribute identifying the language of that passage. Speech synthesis will pronounce them according to English rules.
11.9
Target size of grouped controls — Success Criterion 2.5.8 Target Size (Minimum), met by exception. As recorded at clause 6.10, radio buttons and checkboxes render at the browser default size, which is below twenty-four by twenty-four pixels. The criterion is satisfied because each control is enclosed within a label whose visible text forms part of the same target and because the controls are adequately spaced, but a person using an imprecise pointing device may find the control itself small.
11.10
Alternative formats. The Website is published in English only. No British Sign Language interpretation, Easy Read version, large-print edition or translated version is presently published. This is not a failure of WCAG at Level AA, but it is a limitation on who can use the Website unaided, and clause 14 sets out what the Company will do about it on request.
11.11
Where a limitation recorded in this clause prevents a person from obtaining information or from making an enquiry, the Company shall supply that information or accept that enquiry by another means, at no cost and without undue delay, in accordance with clause 14. A person is not required to wait for remediation.
Remediation

The limitations at clauses 11.2, 11.3 and 11.4 are contrast defects in the design system rather than defects in individual pages. Each is corrected by changing the value of a single design token, and each correction applies across the whole Website at once. They are scheduled for the next revision of the design system and are treated as defects rather than as design decisions.

12.Assessment approach and basis of claim

12.1
This Statement records a self-assessment. It has not been verified by an independent accessibility auditor, no third-party audit report has been commissioned or published in respect of the Website, and this Statement must not be read as a certification. Where it records conformance, it records the considered assessment of the Company; where it records non-conformance, it does so because non-conformance has been found.
12.2
Accessibility of the Website is assessed by the following means:
  • traversal of every page template using a keyboard alone, without a pointing device, confirming that every function can be reached, operated and left, and that the focus position is discernible at each step;
  • operation of every page template with screen reading software, confirming that headings, landmarks, lists, labels, states and error messages are announced correctly and in a sensible order;
  • inspection of the accessibility tree rendered by the browser, to confirm that the structure exposed programmatically matches the structure presented visually;
  • measurement of the contrast ratio of every colour pairing used in the design system for text and for user interface boundaries, calculated against the relative luminance formula stated in WCAG rather than estimated by eye;
  • automated rule-based scanning, used to catch regressions of a mechanical kind and never relied upon as evidence of conformance, since automated tooling detects only a minority of accessibility defects;
  • rendering at increased zoom levels and at narrow viewport widths, confirming that content reflows without loss of information or function and without horizontal scrolling;
  • rendering with scripting unavailable, confirming that the substance of every page remains present and readable; and
  • rendering with a reduced-motion preference set, confirming that animation is suppressed.
12.3
Assessment is carried out against the Website as published, and the claim in this Statement is made in respect of the pages published under the domain identified in clause 1, in the versions live at the version date stated at the head of this document.
12.4
Assessment is repeated before any material change to a page template, to the design system or to the navigation is published, and in any event not less than once in each calendar year.
12.5
Accessibility is treated as a condition of release and not as a subsequent correction. A change which introduces a new failure of a Level A or Level AA Success Criterion shall not be published, and where such a failure is discovered after publication it shall be corrected in priority to feature work.
12.6
The Company shall commission an independent evaluation of the Website against WCAG 2.2 at Level AA, and shall record the fact and date of that evaluation in this Statement when it has been completed. Until that record appears in this clause, no independent evaluation has taken place.
12.7
Where a report made under clause 13 identifies a barrier which the Company’s own assessment did not detect, the assessment method is reviewed as well as the barrier, so that the same class of defect is caught in future.

13.Reporting an accessibility barrier

13.1
Any person may report an Accessibility Barrier. A report may be made by the person affected or by anyone acting on their behalf, and no person is required to identify themselves as disabled, to explain their reasons or to justify the request in order for it to be acted upon.
13.2
Reports under this Statement should be submitted through the Enquiry Form at fratresgroup.com/contact. In the field headed “Type of enquiry”, select “Other”, and begin the message with the word “Accessibility” so that the report is identified and routed immediately on receipt.
13.3
A report is more quickly resolved if it states, so far as the person is able:
  • the address of the page concerned, or a description sufficient to identify it;
  • what you were attempting to do;
  • what happened instead, and at what point the difficulty arose;
  • the browser, operating system and Assistive Technology in use, with version numbers if they are known; and
  • whether you were able to complete the task by some other route.
13.4
None of the above is a condition of making a report. A report which says only that a page is unusable shall be investigated on that basis.
13.5
The Company undertakes to acknowledge every report made under this clause within five Business Days of receipt.
13.6
The Company undertakes to provide a substantive response within twenty Business Days of receipt. That response shall state:
  • (a)whether the matter reported is accepted as an Accessibility Barrier and, if so, which Success Criterion is affected;
  • (b)what the Company intends to do about it and by when;
  • (c)where remediation is not to be undertaken, the reason; and
  • (d)what alternative means of obtaining the content or completing the task is available in the meantime.
13.7
Where a barrier prevents a person from making an enquiry, from reading a document in the legal register, or from obtaining information they require in order to deal with the Company, it shall be treated as urgent and remediated in priority to all other work on the Website.
13.8
Where remediation cannot reasonably be completed promptly, an Alternative Format or an alternative route shall be offered under clause 14 without waiting for the remediation to be carried out.
13.9
No charge is made for reporting a barrier, for any response to it, or for any adjustment made in consequence of it.
13.10
Personal data contained in a report is processed for the purpose of investigating and responding to it, on the basis of the legitimate interests of the Company in maintaining an accessible Website under Article 6(1)(f) of the UK GDPR, and is retained in accordance with the Data Retention & Records Management Policy. The Company does not require and does not invite information about a person’s health or disability. Where such information is volunteered it constitutes special category data within Article 9 of the UK GDPR, and it shall be used only to respond to the report and shall be deleted when it is no longer required for that purpose.
13.11
Every report is recorded in an accessibility register maintained by the Company, noting the date of receipt, the nature of the barrier, the Success Criterion affected, the decision taken, the date of remediation and the date the reporting person was informed. That register informs the review carried out under clause 16.

14.Alternative means of access

14.1
The obligations in this clause are undertaken in discharge of the anticipatory duty described at clause 4.3. They are available on request and are not conditional on a barrier first having been reported or accepted.
14.2
Any content published on the Website shall, on request, be supplied in an Alternative Format. This includes structured plain text suitable for use with Assistive Technology, large print, and a version prepared with simplified language and structure. Requests should be made through the Enquiry Form at fratresgroup.com/contact and shall be acknowledged within five Business Days.
14.3
The documents comprising the legal register, including this Statement, shall be supplied on request as accessible plain text or in such other format as the person requesting them reasonably requires.
14.4
A person who is unable to use the Enquiry Form shall not be prevented from contacting the Company on that account. A request may be submitted by a representative, an advocate, a colleague or a family member acting on that person’s behalf, and the Company shall thereafter make contact by whatever channel the person specifies, including by telephone, by electronic mail, by post or through an interpreter or intermediary. No person shall be required to use the Enquiry Form where using it is itself a barrier.
14.5
Where a person requires a particular means of communication for the duration of a dealing with the Company, that requirement shall be recorded and observed in every subsequent communication without the person having to repeat the request.
14.6
Where the Company convenes a meeting, briefing or site visit, whether in the United Kingdom or in Bangladesh, it shall on request make arrangements for accessible participation, including the accessibility of the venue, the provision of materials in advance in an Alternative Format, and interpretation or captioning. Where such arrangements cannot be made at a proposed venue, an alternative venue or an alternative means of participation shall be offered.
14.7
No charge shall be made for any Alternative Format, adjustment, interpretation or assistance provided under this clause, and no part of the cost of providing it shall be passed to the person requesting it, in accordance with section 20(7) of the Equality Act 2010.
14.8
The Company does not control the accessibility of third-party websites to which the Website links, nor of platforms operated by others. Where material relevant to a dealing with the Company is held on such a platform and is inaccessible, the Company shall supply the substance of that material directly.

15.Escalation and independent advice

15.1
A person who is dissatisfied with the Company’s response to a report or request made under clauses 13 or 14, or who receives no response within the periods stated, may escalate the matter under the Complaints Handling Procedure. Escalation is made through the Enquiry Form at fratresgroup.com/contact and should identify the original report and the respect in which the response is considered inadequate.
15.2
An escalated matter is reviewed by a person who was not responsible for the original response, and the outcome of that review is communicated in writing with reasons.
15.3
Nothing in this Statement, and no step taken under it, limits or replaces any right conferred by the Equality Act 2010. A person who considers that the Company has failed to comply with its duties under Part 3 of that Act in relation to the provision of services may bring proceedings in the county court in accordance with section 114 of that Act. The Company does not require any person to exhaust the process in this Statement before exercising that right.
15.4
Independent advice and information about rights under the Equality Act 2010 is available from the Equality Advisory and Support Service. The Equality and Human Rights Commission is the statutory body with responsibility for the enforcement of equality law in England, Scotland and Wales; in Northern Ireland that responsibility rests with the Equality Commission for Northern Ireland.
15.5
As recorded at clause 4.6, the Company is not a public sector body. The monitoring and enforcement arrangements established under the Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 do not extend to the Website, and this Statement is not made under those Regulations.
15.6
A complaint about the handling of personal data supplied in the course of a report or request may be made to the Information Commissioner’s Office, which is the supervisory authority for data protection in the United Kingdom. The Company asks to be given the opportunity to resolve the matter first, but a person is not required to do so.

16.Review, amendment and status

16.1
This Statement is reviewed not less than once in each calendar year, and in addition on each of the following events: a material change to the design system or to a page template; the publication of a new page type, a mobile application or downloadable material; the publication of a new version of WCAG or of EN 301 549; the completion of an independent evaluation; and the acceptance of a reported Accessibility Barrier which is not remediated immediately.
16.2
A review considers the accessibility register maintained under clause 13.11, the outcome of the assessments described in clause 12, and the status of each limitation recorded in clause 11. A limitation which has been remediated is removed; a limitation which has been discovered is added.
16.3
Amendments take effect on publication. The version date at the head of this document is the date of the version presently in force. Superseded versions are retained in accordance with the Data Retention & Records Management Policy and are available on request through the Enquiry Form at fratresgroup.com/contact.
16.4
Responsibility for this Statement, for the accessibility of the Website and for the remediation programme referred to in clause 11 rests with the director of the Company having responsibility for the Website. That responsibility is not delegated to any external supplier, and the engagement of a supplier to build or maintain the Website does not transfer it.
16.5
Suppliers engaged to design, build or maintain the Website are required by their terms of engagement to deliver work conforming with WCAG 2.2 at Level AA, and the Company assesses delivered work against that requirement before publication.
16.6
This Statement, and any dispute or claim arising out of or in connection with it or its subject matter, is governed by and construed in accordance with the laws of England and Wales. Nothing in this clause affects any right or protection conferred on a person by the law of another jurisdiction which cannot be excluded by agreement.
16.7
If any provision of this Statement is or becomes invalid, illegal or unenforceable, the remainder shall continue in force and the commitments it records remain binding on the Company.
Related policies
Conflicts of Interest PolicyFGL-LEG-13Whistleblowing & Speak-Up PolicyFGL-LEG-14Modern Slavery & Human Trafficking StatementFGL-LEG-15ESG & Responsible Business PolicyFGL-LEG-16
Full legal register