Our aim is to deliver an outstanding service to every customer, making sure that everyone can use our services (as long as it’s safe to do so). That means providing an accessible transport network to all our customers, removing barriers to transport, providing reasonable adjustments, and supporting customers with accessibility and assistance needs.
The Equality Act 2010 (the “Act”) provides legal rights to people to protect them against discrimination in the workplace and in wider society. It provides legal rights in the areas of:
The Act sets out nine characteristics which are protected by the Act against discrimination (see 1.1 “Protected Characteristics” below for a list of the nine characteristics).
The Act also provides rights for people not to be directly discriminated against or harassed because they have an association with a protected characteristic. For example, this can apply to a carer or parent of a disabled person.
The definition of disability under the Equality Act 2010
Under the Act, a person has a disability if:
We shouldn’t question someone's impairment or disability. Instead, we should focus on what changes or reasonable adjustments we need to do to make sure disabled customers have equal access to our services. This is a legal requirement - please see section 1.2 for more information on Reasonable Adjustments to make for disabled customers.
Consequences if we fail to follow the Equality Act 2010
Protected characteristics, direct and indirect discrimination
There are nine protected characteristics. A protected characteristic means that it is against the law to discriminate against someone because of:
This is when a trader or service provider treats any person less favourably than someone else based on one of the above protected characteristics; for example, refusing travel to a customer belonging to a protected group.
This is ‘any provision, criterion or practice that applies to everyone but adversely affects people with a particular protected characteristic (eg. disability) more than others, and is not justified’. For example, requiring a wheelchair user to book in advance where a non-wheelchair user would be able to book on the day.
Harassment is a form of discrimination under the Equality Act 2010. Harassment is unwanted behaviour which has the purpose of violating someone’s dignity, offends or makes them feel intimidated or humiliated. It can happen on its own or alongside other forms of discrimination.
Treating someone badly because they have made a claim or complaint of discrimination (or if you believe that a person has done or is going to make a complaint).
Here are some examples of direct and indirect discrimination and how they might play out with some of the protected characteristics.
Religion or belief
In Sikhism, the five Ks are five items that Guru Gobind Singh commanded Khalsa Sikhs to wear at all times:
Example: 14-year-old S Singh won a High Court case against her school after it excluded her for breaking its "no jewellery" rule for wearing a Kara (steel bangle), a symbol of Sikh faith. The school was found guilty of indirect discrimination.
The Court found, which was upheld on appeal, that Thomas Cook had failed to make reasonable adjustments for Mrs Campbell. They should have supplied seating or asked other passengers to move ahead in the queue. She was awarded compensation against Thomas Cook. This is an example of indirect discrimination.
A club was found guilty of direct discrimination after refusing entry to a male attempting to enter the club. He was the only non-white person in his group and all but him were allowed entry.
In the Equality Act, race can mean your colour or your nationality (including your citizenship). It can also mean your ethnic or national origins which may not be the same as your current nationality. For example, you may have Chinese national origins and be living in Britain with a British passport.
In the case of Dziedziak v Future Electronics Ltd 2012, a Reading Employment Tribunal held that there was an act of direct discrimination on the grounds of nationality when a line manager told Ms Dziedziak, who was Polish, to not use "her own language" at work.
We must respect all customers and their rights to communicate in other languages.
A customer is breastfeeding her three-month-old baby on a coach. The driver asks her to breastfeed their baby in the toilets, as one of the customers has complained about it.
This is unlawful pregnancy and maternity discrimination. That means that under the Equality Act 2010, mothers are allowed to breastfeed an infant on board the coach.
The Equality Act recognises that bringing about equality for disabled people may mean changing the way in which services are delivered, providing extra equipment and/or the removal of barriers. This is our legal duty ‘to make reasonable adjustments’.
We are required to make reasonable adjustments to ensure that disabled customers can use our services as close as is reasonably possible to get to the standard usually offered to non-disabled people.
It is always best to ask customers if they have any reasonable adjustments or accessibility requirements. Examples of adjustments might include:
A customer has a severe nut allergy and contacts the Assisted Travel team. The team ask what assistance or adjustments the customer requires. The customer suggests we inform all customers on board of their nut allergy and request that no nuts are consumed on board. The Assisted Travel team sends the request to the driver via a driver’s note and informs the customer of the risks (such as non-English speaking customers not understanding). Having been informed of the risks and that we cannot guarantee the request is followed or understood by other customers, the customer is happy to go ahead with the journey based on the driver carrying out this reasonable adjustment.
Customers don’t have to pre-book assistance before travelling with us; although it is something we recommend. Accessible travel information should be provided both before and during the journey. Bus and coach operators legally have to organise mandatory disability awareness training for all drivers. There is also a right to compensation for damaged wheelchairs or other assistive equipment and information about passenger rights will become available in terminals and online.
If you have a customer who has booked their assistance in advance you must:
For customers transferring to a seat, having pre-booked assistance, our Assisted Travel team in the Contact Centre will have reserved a front seat for the customer, subject to availability and requirement. This is, however, a request and not a guarantee - that person could be asked to move to another seat if someone else boards (e.g. a wheelchair user) the coach further along the journey and is perceived to have a greater need (although this is rare).
Please note, if all four front seats are booked or taken, you can explain that seat allocation is done on a ‘first come, first served’ basis. You should offer alternative seats on the coach and the customer can travel if they are happy to sit elsewhere.
This does not apply to customers in wheelchairs who can only travel in the allocated seats on the coach (making sure they are safely secured for travel). If a seat is taken by a non-wheelchair user, you should politely ask them to move seats (if there is room) and accept the customer using a wheelchair for travel.
When customers connect from one National Express service to another, coach station staff will assist the customer from one coach to the next, subject to availability. In the case of London Victoria coach station (VCS), the staff (employed by Transport for London) will provide ‘connection assistance’. (Please inform your customer that if they accept luggage assistance from the self-employed porters in VCS, there is a charge for this service and is not part of our service provision).
When the inbound coach comes into the arrivals hall, drivers should ask a member of staff (based in the arrivals hall) to radio across to someone in the mobility lounge. That person will then come to assist the customer to either the departure gate of their next coach or to the mobility lounge if there is a long wait. The staff member will also assist the customer from the mobility lounge to their coach departure bay when it’s time for their next coach.
Wheelchair User Flowchart
If a customer in a wheelchair requests travel and they HAVE NOT booked assistance in advance, follow the guidelines in the flowchart:
Generally, whenever dealing with an assisted travel booking, please follow the guidelines below:
Offering assistance – supporting blind customers and customers with visual impairments
Offering assistance – supporting deaf customers or customers with hearing impairments
Offering assistance – speech impairments
Don’t finish the ends of a customer’s sentences, or pretend to understand them when you do not. Always politely ask them to repeat themselves, even if it takes several attempts.
Assistance - seating
Wheelchair users (including National Express-owned wheelchairs to transfer)
You can help provide a reliable coach service by being prepared for wheelchair users:
Wheelchair users - guidance
Turn-up and go on the day of travel – customers remaining in their wheelchair
Carry out the following steps before travel is booked for the customer. If in doubt at any stage of this process, call NCC for advice.
When speaking to NCC they will ask you for the wheelchair make and model (which you’ll get from the customer) so that the following information can be checked:
If these requirements are met, prepare the coach for travel by removing the Magic Seat (if it needs to be removed), from the wheelchair space to enable the customer to travel securely in their wheelchair. If you are in any doubt as to how to remove the Magic Seat speak to a member of staff or NCC at the time, and then arrange re-training for a later date. If any of the above requirements are not met go to the penultimate paragraph in this section.
If another customer (non-disabled or disabled) is already sitting in the Magic Seat, politely ask them to move to another available seat on the coach. However, if that customer is disabled then consider whether they may have mobility issues and whether asking them to move to another seat is practical or possible. If they don’t agree to move, please call NCC for further advice.
Deploy the wheelchair lift to board the customer and safely secure the wheelchair and the customer in the wheelchair space using the harness provided before embarking on the journey. Always ask the customer if they are happy for you to move them before manoeuvring their wheelchair.
When the customer has arrived at their destination, release the wheelchair from the wheelchair user space when the customer wishes to leave the coach. There may be occasions when the customer wants to get off the coach during the journey. If there isn’t a suitable planned break along the journey that meets the customer’s requirements, don’t refuse the customer’s request. This could amount to a failure to make reasonable adjustments for the customer. For example, all other customers can use the on-board toilet, but clearly this would not be possible for a wheelchair user. Please call NCC for advice on stopping at the nearest safe location.
If the compatibility requirements are not met, NCC will talk you through why it’s not possible to carry the customer on this occasion. You will need to relay this information accurately to the customer. If they have bought a ticket before travel, please direct them to a coach station member of staff who will organise a full refund of the ticket. Or, if at a non-staffed stop, advise the customer to get in touch with the customer service team by calling 03717 81 81 81 or go to the website for other ways of making contact with us.
If the compatibility requirements are met but you are unable to load the wheelchair or safely secure it on the coach, call NCC who will advise you on how to proceed.
Turn-up and go on the day of travel – transferring from a wheelchair to a coach seat
Follow the steps set out below to make sure the relevant compatibility checks (on wheelchairs and coach stop departure and arrival points) are carried out before travel is booked for the customer. If in doubt at any stage of this process, call NCC for advice.
Confirm that the customer wishes to stow their wheelchair in the luggage hold and transfer to a coach seat. If the customer wants to travel in their wheelchair, in the wheelchair space on the coach, you must follow the guidance provided in the section above.
If the customer wants to transfer to a coach seat and stow their wheelchair in the luggage hold, you will need to call NCC to check that the stops where they want to board and disembark are accessible stops where the wheelchair lift can be deployed. You will also need to confirm (by asking the customer for information about their wheelchair) that the wheelchair is safe for stowage.
Explain the following to the customer so that they understand what is happening whilst they wait to be boarded.
“I will just make a call to our Network Control Centre (NCC) who will carry out some checks to make sure that the stops you wish to use are wheelchair accessible stops where the wheelchair lift can be safely deployed. I will also need to ask you for certain information about your wheelchair to check that it can be safely stowed in the hold.”
Contact NCC to carry out these checks. If the stops are not accessible stops and/or there is no space on the coach go to the final paragraph in this section, below.
To check that the wheelchair is safe for stowage, ask the customer to confirm that the wheelchair:
If the wheelchair does not meet all of the above requirements go to the final paragraph in this section below.
If the stops which the wheelchair user wishes to use are wheelchair accessible (where the wheelchair lift can be safely deployed), there is space on the coach and the wheelchair meets the requirements listed above:
When the customer has arrived at their destination, provide reasonable assistance in unfolding the wheelchair (take advice from the customer on how to do this). There may be occasions when the customer wishes to disembark during the journey. If there is not a suitable planned break along the journey, which meets the customer’s requirements, don’t refuse the customer’s request. Call NCC for advice on stopping at the nearest safe location.
If the stops which the customer wants to use are not accessible stops, there is no space on the coach, or the wheelchair is not safe for stowage in the luggage hold, NCC will tell you how to proceed. If the customer has bought a ticket before travel direct them to a coach station member of staff who will organise a full refund of the ticket. Or, if at a non-staffed stop, advise the customer to get in touch with the customer service team by calling 03717 81 81 81 or go to the website for other ways of making contact with us.
Turn-up and go on the day of travel – using a National Express wheelchair
Follow the steps below to make sure the relevant compatibility checks, regarding coach stop departure and arrival points, are carried out before travel is booked for the customer. If in doubt at any stage of this process, call NCC for advice.
Explain the following to the customer so they understand what is happening while they wait to be boarded.
“I will just make a call to our Network Control Centre (NCC) who will carry out some checks to make sure that the stops you wish to use are wheelchair accessible stops where the wheelchair lift can be safely deployed.”
Follow the steps below to ensure the relevant compatibility checks, on wheelchairs and coach stop departure and arrival points, are carried out before travel is booked for the customer. If in doubt at any stage of this process, call NCC for advice.
We accept small mobility scooters and powered wheelchairs for stowage in the hold of the coach subject to the following:
Follow the steps below before travel is booked for the customer. If in doubt at any stage of this process - call NCC for advice.
We welcome trained assistance dogs on all our coaches.
We are unable to carry dogs or any other animals on our coaches.
Customers don’t have to pre-book an assistance dog onto the coach. However, we do recommend this to customers to ensure there will be space available on the service they require and to avoid disappointment. Drivers should not insist on a customer having first pre-booked assistance or prevent them from travelling if they have not.
Assistance dogs have to wear a safety harness when on board the coach which is then attached to the seatbelt of a spare seat. The customer has to provide the safety harness. If they don’t have one with them, do not refuse travel but contact NCC for further support. The safety harness keeps the customer’s assistance dog (as well as our driver and other customers onboard) safe if there’s an emergency stop. You may need to assist a customer and harness their assistance dog in safely. Please refer to the safe working practice for assistance dogs.
If a customer has not pre-booked you should ask the customer to confirm that their assistance dog is highly trained by producing evidence, for example, a certificate, correspondence from the training organisation, ID book, owner training logs or an email from the owner confirming what training has taken place. If you are unsure you should contact NCC for additional guidance.
Under the Equality Act 2010, there is a legal obligation to provide reasonable adjustments to enable disabled customers to access our services. You will be required to provide any reasonable adjustments and assistance when requested by the customer.
In any case, where a dog might display aggressive behaviour, drivers are able to refuse travel in line with Health and Safety. The failure to exercise this discretion reasonably and without good evidence may result in the driver being removed from the National Express network.
If you have a known allergy to dogs, medical evidence from a GP, of the diagnosed allergy, must be provided to your direct employer so that this can be recorded for future reference.
If you have an allergy and/or phobia to dogs to the extent that such allergy would prevent you from driving whilst transporting an assistance dog you must:
Provide evidence to your line manager/supervisor including by reference to a medical note from your GP of your allergy if you have not already done so; and
If the customer has booked in advance and notified National Express of their intention to travel with an assistance dog, you must notify the Assisted Travel Team 03717818181 and the relevant Operations Manager so that we can rotate you for a different driver (who does not have such allergy/phobia); or
Where the customer has not pre-booked, you should contact NCC who will arrange alternative transport for the customer.
Some customers can only travel on our services if they are accompanied by a carer (because of their disability), such Carer must travel). In this case, the carer travels free of charge. If the customer and the carer have not pre-booked and want to travel, you must contact NCC.
To avoid non-disabled people abusing the free carers’ scheme, NCC may ask you to ask the customer to provide evidence showing that they require a carer to travel, but if they do not have such evidence please contact NCC for further guidance. This evidence can take a variety of forms; for example, (this is a non-exhaustive list):
Invisible impairments, disabilities and mental health awareness
Not all disabilities/impairments are visible and it is important that you remember that not everyone’s requirements are the same. There are many different types of disabilities, impairments and long term health conditions. These could be physical or mental impairments and can include:
This list is not exhaustive and there are other groups who may require assistance in their journey such as older adults, those travelling with heavy or multiple luggage or customers who speak little or no English. Other groups can include people who have dyslexia, autism, ADHD, dyspraxia and other neurological conditions. These are 'spectrum' conditions, with a wide range of characteristics.
Just as all our customers are all different and individuals, the way they may communicate can be different. Some customers may have:
As with all aspects of your customer service role, you should be polite and helpful when dealing with our customers. Keep an eye out as you move through the station for potential, vulnerable customers who may need extra help, information or reassurance.
‘Implicit’ or ‘unconscious bias’ happens when our brains making incredibly quick judgments and assessments of people and situations without us realising. Our biases are influenced by our background, cultural environment and personal experiences.
We may not even be aware of these views and opinions or realise their full impact and implications.
Real examples of how bias can play out on our network
In all of these situations, your brain has made decisions and assumptions about how to treat these people differently. Therefore, prior to making a decision, please consider whether you would make that same decision for all customers.
Some customers who we come into contact with will be vulnerable in the context of how we interact with them, by virtue of their personal circumstances. We have a duty and obligation to ensure that all elements of our work are consistent with our values and that we make reasonable adjustments.
The type of vulnerability can vary widely; for example, a young person with autism living independently for the first time, or a single parent with dependent children who has recently become unemployed, or someone with a terminal illness. “Vulnerability” can be permanent, temporary or progressive.
Some examples of vulnerable customers might include:
If you have any concerns regarding customers please contact NCC. If you have immediate concerns regarding customers please call the police.
Communicating in a positive, effective way with customers can really add to their National Express experience.
If you’re communicating with customers who don't speak English as their first language:
Use positive language with all customers. When talking about impairments, requirements or needs of disabled customers, avoid phrases like ‘suffers from’ which suggests discomfort, constant pain and a sense of hopelessness. Wheelchair users may not view themselves as ‘confined to a wheelchair’– try thinking of it as a mobility aid instead.
People themselves are not necessarily disabled; it is society, services and the world around us all that can be disabling for some. The word ‘disabled’ is a description not a group of people. Use ‘disabled people’ not ‘the disabled’ as the collective term.
These are examples of words we should move away from using and what we can replace them with.
|Stop saying...||Replace with...|
|Wheelchair bound||Wheelchair user|
|Suffers from||Lives with|
|Person with disability||Disabled person|
|(the) handicapped, (the) disabled,
person with disabilities
|Afflicted by, suffers from, victim of||Has/lives with [name of condition or impairment]|
|Confined to a wheelchair||Wheelchair user|
|The blind||People with visual impairments; blind people;
blind and partially sighted people
|‘In this country /my country’||We receive many complaints about drivers saying
things such as ‘We have rules in this country’ etc.
If you say things like this, you are making an assumption
about the individual based on your perception of them.
This can be a way in which our unconscious biases play out.
Used in many contexts this term can be offensive
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