DISABILITY AND
REASONABLE
ADJUSTMENT POLICY

Brightbeam’s view on disability and inclusion

Disability discrimination and exclusion are not edge cases. They are structural failures — and ones that AI and technology companies have a particular responsibility to address. At Brightbeam, we work with organisations across insurance, pharma, manufacturing, and government. Many of the people we train, coach, and advise are navigating workplaces that still, often invisibly, disadvantage disabled colleagues. We have a duty not to replicate those patterns in our own practice.

The legal baseline — the Equality Act 2010, the Disability Discrimination Act 1995, and their equivalents — sets a floor, not a ceiling. Our aim is to exceed it. That means proactively asking about access needs before every programme, designing our online delivery to be usable by the widest possible range of participants from the outset, and treating reasonable adjustment not as a bureaucratic concession but as a normal part of how we work.

We also recognise that disability is frequently non-visible. Many of the people we work with will have conditions — neurodivergence, chronic illness, mental health conditions, visual or hearing impairment — that are not immediately apparent and that colleagues may not have chosen to disclose. Our starting assumption is not ‘no one in this room has additional needs.’ It is ‘some people in every programme will have needs we don’t know about yet, and our job is to make it easy for them to tell us.’

This policy is the formal expression of that commitment. It applies to everyone at Brightbeam — employees, associates, contractors — and to every learner who participates in a Brightbeam-delivered programme.

Publication and communication

This policy is published on the Brightbeam website at www.brightbeam.com.

It is distributed to all employees and associates at induction and made available to all learners at programme commencement.

All colleagues are asked to complete the internal colleague acknowledgement process for this policy.

This policy is reviewed at least annually by the CEO and Head of Operations.

1. Overview

Brightbeam AI Limited (“Brightbeam”) is an AI consultancy and training company operating across Ireland, the United Kingdom, and the United States. We are a remote-first company: our employees and associates work remotely, and all training and coaching programmes are delivered online. From time to time, workshops are held at client premises.

This policy sets out Brightbeam’s approach to disability discrimination, equality of access, and reasonable adjustment. It applies to:

• All employees and workers employed by or contracted to Brightbeam

• All associates, freelancers, and subcontractors delivering services on Brightbeam’s behalf

• All learners and delegates participating in Brightbeam-delivered programmes

• All candidates applying for roles at Brightbeam

This policy is mandatory. Compliance is not optional for any person covered by it.

2. Company statement

Brightbeam AI Limited is committed to ensuring that disabled people — whether employees, associates, or learners — are not treated less favourably and are not placed at a substantial disadvantage by our practices, policies, premises, or delivery model. We will make reasonable adjustments wherever required to remove or reduce barriers to participation.

We recognise that:

• Disability takes many forms, including physical impairments, sensory impairments, mental health conditions, learning differences (such as dyslexia, ADHD, and autism spectrum conditions), long-term health conditions, and progressive conditions

• Many disabled people do not use the word ‘disabled’ to describe themselves, and disclosure is a personal choice that must be respected

• Barriers are often created by environments and systems, not by the individual — and it is Brightbeam’s responsibility to remove those barriers

• Our remote-first, online delivery model presents both advantages (flexibility, reduced travel burden) and specific challenges (reliance on technology, screen-heavy content) that we must design around

This commitment is driven by legal obligation and by our values. Brightbeam believes that diverse and inclusive teams and learning cohorts produce better outcomes — and that access is a prerequisite for diversity.

3. Objectives

Brightbeam’s objectives under this policy are to:

• Ensure that no employee, associate, or learner is discriminated against on the grounds of disability

• Proactively identify and remove barriers to participation in Brightbeam’s programmes and workplace

• Make reasonable adjustments promptly, practically, and without making the individual feel that they are creating a burden

• Ensure that all employees and associates understand their responsibilities under this policy

• Create an environment in which disabled people feel safe to disclose access needs without fear of disadvantage

• Ensure that recruitment, onboarding, and programme enrolment processes are accessible from the outset

• Monitor and review our reasonable adjustment practices annually and improve them where gaps are identified

• Ensure compliance with the Equality Act 2010, the Disability Discrimination Act 1995 (as amended), the Employment Equality Acts 1998–2015 (Ireland), and all other applicable legislation

4. How this policy is upheld

4.1 Reasonable adjustment — the duty

The duty to make reasonable adjustments arises under the Equality Act 2010 (UK) and equivalent Irish legislation. It requires Brightbeam to take positive steps to ensure that disabled people are not at a substantial disadvantage compared to non-disabled people. This is an anticipatory duty — we must not wait to be asked.

Whether an adjustment is ‘reasonable’ depends on factors including: the nature and cost of the adjustment; the extent to which it would remove the disadvantage; the resources and size of Brightbeam; and the disruption caused. Brightbeam will always explore whether an adjustment is practicable before declining it.

4.2 Reasonable adjustment arrangements

The following sets out Brightbeam’s practical arrangements for making reasonable adjustments across our key areas of activity.

Programme delivery and learner access

Brightbeam will:

• Include an access needs question in all programme enrolment processes, allowing learners to disclose any requirements in advance

• Review disclosed access needs before programme commencement and confirm the adjustments that will be made

• Provide session materials in accessible formats on request (including large print, high-contrast versions, and screen-reader compatible documents)

• Ensure that all video conferencing sessions include live captioning where requested, or use platforms with built-in captioning capability

• Allow additional time for written tasks, assessments, or capstone submissions where this is a reasonable adjustment for the individual

• Record sessions where requested (subject to data protection and participant consent), to allow learners to review content at their own pace

• Ensure that facilitators and coaches are briefed on any disclosed access needs before a session begins

• Provide one-to-one support calls or alternative coaching formats where the standard group format creates a barrier

Employment and associate engagement

Brightbeam will:

• Ask candidates at the point of interview invitation whether any adjustments are needed for the interview process

• At onboarding, ask all new employees and associates whether they have any access needs or adjustments required for their role

• Review equipment, software, working pattern, and workload arrangements where an adjustment is needed

• Work with the individual to identify adjustments that are practical and effective, rather than applying a one-size approach

• Not use disability as a factor in any employment, promotion, or performance management decision

• Maintain confidentiality around disclosed disability or health information, sharing only with those who need to know in order to implement an adjustment

Content and materials

Brightbeam will:

• Follow all applicable accessibility guidelines as a baseline standard for all digital content produced for programmes

• Use plain language and clear formatting in all written materials

• Avoid relying solely on colour to convey meaning in slides, documents, and visual content

• Provide transcripts or summaries for audio and video content where requested

• Review our standard AI Embed curriculum and materials annually for accessibility barriers

In-person workshops at client sites

Where Brightbeam staff or learners attend client premises:

• The Brightbeam Project Lead will confirm with the client in advance that the venue is physically accessible

• Any disclosed access needs for attending delegates will be communicated to the client’s event lead (with the individual’s consent) so that appropriate arrangements can be made

• Where a venue cannot be made accessible, Brightbeam will work with the client and the individual to identify an alternative arrangement

4.3 Disclosure and confidentiality

Disclosure of a disability or health condition is entirely voluntary. Brightbeam will not pressure any individual to disclose, and will not make adverse assumptions if someone chooses not to. Where an individual does disclose:

• Information will be treated with strict confidentiality

• It will be used only for the purpose of implementing agreed adjustments

• It will be shared only with those who need to know in order to provide the adjustment

• It will be stored securely in accordance with Brightbeam’s data protection policy and GDPR obligations

Individuals may update or withdraw a disclosure at any time. Where someone discloses during a live programme or session, the facilitator will handle the disclosure sensitively and escalate to the Head of Operations if follow-up action is required.

4.4 Complaints and non-compliance

Any employee, associate, or learner who believes they have been discriminated against on the grounds of disability, or who believes a reasonable adjustment request has not been properly considered, should raise the matter under Brightbeam’s Learner Complaints Procedure (Doc 1.2) or, for employees, through Brightbeam’s internal grievance procedure.

Brightbeam takes all such complaints seriously and will investigate them fully. Victimisation of any person who raises a discrimination complaint is itself a breach of this policy and of the law.

5. Relevant legislation

This policy has been prepared with reference to the following legislation. Brightbeam will monitor changes to applicable law and update this policy accordingly.

Disability Discrimination Act 1995 (DDA 1995, as amended)

The foundational UK statute establishing the duty not to discriminate against disabled people. Largely superseded by the Equality Act 2010 in Great Britain but retains relevance in Northern Ireland.

Equality Act 2010 (UK)

The primary UK anti-discrimination legislation. Defines disability, establishes protected characteristics, sets out the duty to make reasonable adjustments, and prohibits direct discrimination, indirect discrimination, harassment, and victimisation on grounds of disability.

Employment Equality Acts 1998–2015 (Ireland)

Irish legislation prohibiting discrimination in employment on nine grounds, including disability. Imposes a duty on employers to provide reasonable accommodation.

Equal Status Acts 2000–2018 (Ireland)

Prohibits discrimination in access to goods, services, and education on grounds including disability. Relevant to Brightbeam’s programme delivery.

Equality Act 2010 (Disability) Regulations 2010

Supplementary regulations clarifying aspects of the disability definition and deemed disability provisions.

General Data Protection Regulation (GDPR) / Data Protection Act 2018

Health and disability information is special category data under GDPR. Brightbeam must handle disclosed disability information with heightened protection.

UN Convention on the Rights of Persons with Disabilities (CRPD)

International framework ratified by the UK and EU. Informs best practice in disability inclusion beyond minimum legal compliance.

6. Definitions

For the purposes of this policy:

Disability

Under the Equality Act 2010, a physical or mental impairment that has a substantial and long-term adverse effect on a person’s ability to carry out normal day-to-day activities. ‘Long-term’ means that it has lasted or is likely to last at least 12 months.

Reasonable adjustment

A step or change that Brightbeam takes to remove or reduce a substantial disadvantage faced by a disabled person. Whether an adjustment is ‘reasonable’ is assessed in context, having regard to cost, practicability, and effectiveness.

Direct discrimination

Treating a disabled person less favourably than a non-disabled person because of their disability.

Indirect discrimination

Applying a provision, criterion, or practice that puts disabled people at a particular disadvantage compared to non-disabled people, and which cannot be justified.

Harassment

Unwanted conduct related to disability that has the purpose or effect of violating a person’s dignity or creating an intimidating, hostile, degrading, humiliating, or offensive environment.

Victimisation

Treating someone badly because they have made or supported a complaint about disability discrimination.

7. Named responsibilities

CEO — Brian Hanly

Overall accountability for this policy. Signs and approves the policy. Ensures sufficient resource is allocated to implement reasonable adjustments. Reviews and re-signs the policy annually.

Head of Operations — Marli van Sittert

Day-to-day operational responsibility. Receives and logs all reasonable adjustment requests. Coordinates implementation of adjustments. Maintains records of disclosed needs (confidentially). Manages annual policy review. First point of contact for complaints under this policy.

COO — Paul Savage

Second-line oversight. Deputises for the CEO on policy matters. Ensures D&I principles are embedded in Brightbeam’s operational decisions.

Project Leads / Programme Managers

Ensure access needs questions are included in enrolment. Brief facilitators on disclosed needs before sessions. Co-ordinate with the Head of Operations on adjustments during active programmes. Handle in-session disclosures sensitively.

All employees and associates

• Treat all colleagues and learners with dignity and respect

• Complete the internal colleague acknowledgement process for this policy

• Co-operate with reasonable adjustment arrangements

• Report any disability discrimination concerns to the Head of Operations

Learners / delegates

Encouraged (but not required) to disclose access needs before programmes begin. Contact go@brightbeam.com at any time to request an adjustment. Treat fellow learners with respect and dignity.

8. Monitoring and review

The Head of Operations will:

• Maintain a confidential log of reasonable adjustment requests and outcomes

• Review the log annually to identify patterns, unmet needs, or areas for improvement

• Report to the CEO and COO annually on the operation of this policy, including any complaints received

• Ensure the policy is reviewed and re-approved by the CEO at least annually

This policy will also be reviewed following any of the following:

• A relevant change in UK, Irish, or other applicable equality legislation

• A complaint or incident that reveals a gap in the policy or its implementation

• A significant change in Brightbeam’s programme offering, workforce, or delivery model

Distribution confirmation

This policy is published on the Brightbeam website at www.brightbeam.com.

It is distributed to all employees and associates at induction.

It is made available to all programme learners at commencement and on request via go@brightbeam.com.

All colleagues complete the internal colleague acknowledgement process for this policy.

9. Colleague acknowledgement and declaration

All colleagues are asked to complete the internal colleague acknowledgement process. Through that process, each colleague confirms that they have read, understood, and agree to comply with Brightbeam’s Disability and Reasonable Adjustment Policy (DD-POL-001).

Colleagues confirm that they understand their responsibilities under this policy and their obligation to treat all employees, associates, and learners with dignity and respect, and to support the implementation of reasonable adjustments.

Completed declarations should be returned to the Head of Operations and will be retained on file.

10. Sign-off

This policy has been approved by the Chief Executive Officer of Brightbeam AI Limited. It will be reviewed at least annually.

Name: Brian Hanly

Title: Chief Executive Officer

Policy reference: DD-POL-001

Version: 1.0

Date last reviewed: June 2026

Next review due: June 2027