Foreword

Accréditation Sans Frontières was founded on a single premise: that geography and resource level should not determine whether a healthcare facility has access to internationally recognised quality standards. That founding premise is, at its core, an equality principle. This policy makes the structural commitments that principle demands explicit — in governance, in standard development, in consultation, in the conduct of surveys, and in the content of the standards themselves.

ASF operates across jurisdictions with different legal equality frameworks. This policy is grounded in the international instruments that apply regardless of jurisdiction: the ILO Discrimination (Employment and Occupation) Convention 1958 (No. 111); the UN Convention on the Elimination of All Forms of Discrimination Against Women (CEDAW, 1979); the UN Convention on the Rights of Persons with Disabilities (CRPD, 2006); the International Covenant on Civil and Political Rights (ICCPR, 1966); the UN Guiding Principles on Business and Human Rights (2011); and UN Sustainable Development Goal 10 (Reduced Inequalities) and SDG 3.8 (Universal Health Coverage). Where French law (as the law of ASF’s registered jurisdiction) requires a higher standard than these instruments, French law applies [1–8].

This policy is not aspirational language. Each commitment in it produces a specific, auditable obligation — documented in the How ASF Develops and Revises Standards methodology manual, the ASF Surveyor Training Standard, the Annual Activity Report, and the governance records of each Revision Panel. A commitment that cannot be audited against a document is not in this policy.

1. Scope

This policy applies to every function ASF performs and every person who performs it on ASF’s behalf:

• Governance: Council members, Revision Panel members, observers, and advisors
• Accreditation: Certified surveyors, review panel members, and the accreditation decision process
• Standard development: Evidence review, drafting, public consultation, and piloting
• Facilities: Accredited and applicant organisations and their staff and patients
• External parties: Training providers, local partners, and public consultation participants
• Standards content itself: whether the criteria ASF publishes embed or inadvertently perpetuate inequity

2. Protected Characteristics

ASF does not discriminate — directly or indirectly — on the basis of any of the following characteristics. This list is drawn from ILO Convention 111 and the additional grounds recognised in the CRPD, CEDAW, ICCPR, and French loi 2008-496 on equal treatment. It is illustrative, not exhaustive.

ILO Convention 111 draws an explicit distinction between direct and indirect discrimination. ASF applies both concepts. Direct discrimination occurs where a person is treated less favourably because of a protected characteristic. Indirect discrimination occurs where a requirement that appears neutral — a language requirement, a specific credential, a meeting format or time zone — has a disproportionate and unjustifiable effect on persons sharing a protected characteristic. Both are prohibited under this policy.

2.3 Intersectionality

The ISQua EEA Standards (6th edition, 2024) specifically reference intersectionality as a concept accreditation bodies must consider. Intersectionality recognises that a person’s experience of discrimination is shaped by the simultaneous interaction of multiple characteristics — a migrant woman with a disability faces qualitatively different barriers to healthcare access than a woman without a disability or a migrant man. No single-axis analysis captures this. ASF applies the intersectionality lens in the equity review checklist (Section 8, Question 8) and by specifically soliciting consultation submissions from organisations working with intersectionally marginalised populations: migrant women, disabled refugees, and older adults from ethnic minorities.

3. Gender Equality

Gender equality in governance and standard development is a substantive, not procedural, commitment. ASF’s obligations derive from CEDAW and its Optional Protocol, and from the Beijing Platform for Action (1995), which together require not merely the absence of discrimination but active measures to achieve equality of participation and outcome.

3.1 Council and Revision Panel composition

No gender shall constitute more than two-thirds of the seated Council membership. This is a hard ceiling, not a target. Where a vacancy arises that would cause this ceiling to be breached, the selection process for that vacancy is required to prioritise candidates of the underrepresented gender unless no qualified candidate of that gender is available after a genuine, documented search. The gender composition of the seated Council and each active Revision Panel is reported in the Annual Activity Report. Note: As of September 2026, the seated Council has a gender imbalance that does not yet meet this ceiling. Achieving the two-thirds ceiling is a commitment for the next appointment cycle.

3.2 Standards content

Every standard is reviewed against a gender equity checklist before publication. The checklist asks: Does this criterion apply differently to patients of different genders? Does this criterion address care contexts where gender-based violence is a background factor? Does this criterion use language that assumes a gender-neutral patient when evidence indicates otherwise? Findings from the gender equity review are documented in the revision file.

3.3 Survey conduct

Surveyors are required by the ASF Surveyor Training Standard (Domain E — Ethics and Conduct) to apply gender-sensitive interview and observation practices. Where the facility being surveyed provides services primarily to one gender (e.g. maternal health, men’s health), the survey team composition should include at least one surveyor with specific competence in that area.

4. Disability Inclusion

ASF’s disability inclusion commitments are grounded in the CRPD, and in particular Articles 9 (Accessibility), 19 (Living Independently), 21 (Freedom of Expression and Opinion), 25 (Health), and 27 (Work and Employment). France ratified the CRPD in 2010; loi 2023-442 additionally requires digital accessibility at WCAG 2.1 AA for public-facing digital content.

4.1 Governance participation

Where a Council member, Revision Panel member, or public consultation participant identifies a disability requiring accommodation — in meeting format, documentation format, communication mode, or physical access — ASF provides that accommodation in advance of the relevant activity, not as a reactive adjustment. The request and the accommodation provided are documented. No accommodation request shall be used as grounds to question a candidate’s suitability for a governance role.

4.2 Website and documents

The france-asf.fr website and all published standards documents are required to meet WCAG 2.1 Level AA. ASF’s Accessibility Plan documents current conformance level and the timeline for achieving full WCAG 2.1 AA conformance. Published standards PDFs are required to be screen-reader compatible.

4.3 Standards content

Every standard is reviewed for disability inclusion during the equity review step (see Section 8). The review asks: Does this criterion adequately address care for patients with physical, sensory, cognitive, or psychosocial disabilities? Does this criterion’s means of verification account for adapted patient communication? Does this criterion address staff training in disability-affirming care practices?

5. Race, Ethnicity and Indigenous Peoples

ASF’s obligations here derive from ILO Convention 111, the International Convention on the Elimination of All Forms of Racial Discrimination (ICERD, 1965), and, for standards affecting indigenous populations, ILO Convention 169 on Indigenous and Tribal Peoples (1989) and the UN Declaration on the Rights of Indigenous Peoples (UNDRIP, 2007).

ASF’s Health & Migration endorsement, present in every organisational standard, specifically addresses care for refugees, internally displaced persons, and migrant populations — a population that includes disproportionate representation of racial and ethnic minorities in most of ASF’s countries of operation. The endorsement criteria require culturally sensitive care practices, interpreter access, and non-discriminatory intake processes.

Where a standard applies in a context with a significant indigenous population, the Revision Panel must include, or formally consult, a representative with specific knowledge of that population’s health needs and cultural practices. This consultation is documented in the revision file and disclosed in the published standard.

6. Refugee, Migrant and Stateless Persons

ASF was built specifically to serve healthcare systems in transitional and fragile contexts, where refugee and migrant populations are disproportionately concentrated. The UNHCR’s health mandate, WHO’s Framework on Refugee and Migrant Health (2016), and the Global Compact for Refugees (2018) all recognise a gap between the health standards developed in stable, high-income settings and the realities of facilities serving displaced populations. ASF’s facility category system — and particularly the Crisis and Transitional categories — is ASF’s primary structural response to this gap.

Beyond category adjustment, this policy commits ASF to ensuring that no standard criterion creates a compliance barrier that effectively excludes facilities serving predominantly migrant or refugee populations from achieving accreditation, unless that barrier is directly necessary to protect patient safety and cannot be adjusted without compromising it. Where a criterion creates such a barrier, the Revision Panel must document the justification and consider whether a targeted adaptation is warranted.

7. Socioeconomic Equity and Universal Health Coverage

ASF’s four-facility-category system is the primary mechanism for addressing socioeconomic equity in standards content. The same criterion applied across four resource contexts ensures that a facility in a crisis setting is not assessed against a standard built on the assumption of unlimited resources, while simultaneously ensuring that the Universal Floor — the minimum patient safety requirements that apply regardless of category — is never waived on resource grounds alone.

Accreditation fees are set on a sliding scale by facility category. This is not charity — it is a structural recognition that the cost of accreditation cannot be a barrier to small or resource-limited facilities that serve populations with the least access to quality healthcare. The fee structure is published on the ASF pricing page and reviewed annually.

8. Equity Review in Standard Development

An equity review is embedded in the five-stage standard development process as a mandatory step between Stage 2 (Drafting) and Stage 3 (Public Consultation). No draft proceeds to consultation without a completed equity review.

The completed equity review checklist is filed with the revision file and is available on request as part of the standard’s development record. A summary of equity review findings and responses is published in the Annual Activity Report for the year in which the standard was published or revised.

9. Inclusive Consultation

Public consultation on draft standards is only meaningful if it is genuinely accessible to the populations the standard will affect. The following requirements apply to every consultation process.

• No registration barrier: Consultation submissions may be made without creating an account or providing any personal information other than the submitter’s name and contact (or a statement that the submission is anonymous). Anonymous submissions are accepted.
• Language accessibility: Consultation announcements are published in English and Georgian as a minimum. Where a standard has specific application in a country or region where another language is dominant, the announcement is also published in that language.
• Multiple submission channels: Submissions may be made by email, post, or through the website contact form. No submission channel may require technology that is not available in low-resource settings (i.e. a web form that requires a high-bandwidth connection is not acceptable as the only channel).
• Patient and community voice: For each public consultation, ASF specifically solicits input from patient organisations, consumer health groups, and community health workers in the countries where the standard applies. Evidence that this outreach occurred is documented in the revision file.
• Plain language summary: Every draft standard posted for public consultation is accompanied by a plain language summary of the changes proposed, designed for a reader with secondary school education, using WHO’s plain language health communication guidelines.

10. Patient/Community Voice — Mandatory Lay Seat

The mandatory patient/community representative seat on the International Standards Council, established in the Council composition rules, is the structural implementation of this policy’s principle that the people most directly affected by healthcare quality standards have a voice in writing them. This requirement is grounded in the WHO Framework on People-Centred Health Services (2016), Accreditation Canada’s patient advisor framework, and the ISQua EEA criterion on patient and public involvement in standard development [14, 17, 18].

The lay seat holder must have genuine lived experience of healthcare as a patient or carer — not as a professional advocate whose primary role is organisational. The selection process for the lay seat must include active outreach to patient advocacy organisations and community health groups, not only to professional networks. The selection is documented in the Annual Activity Report. The lay seat is currently vacant (September 2026). ASF commits to appointing a qualified lay representative by the end of the first quarter of 2027, following an open call to patient advocacy organisations and community health groups in ASF’s countries of operation.

11. Safe Participation — Zero Tolerance for Harassment

This section implements ILO Convention 190 on Violence and Harassment (2019), which entered into force in 2021 and covers all persons in the world of work — including volunteer panel members, survey participants, and public consultation contributors. France ratified ILO C190 in 2021.

ASF adopts a zero-tolerance policy for harassment, discrimination, intimidation, and violence in every activity it governs. This applies to:

• Council and Revision Panel meetings (in-person and remote)
• Public consultation processes
• On-site accreditation surveys
• Training activities under the Training & Education Standards
• Any other activity conducted on ASF’s behalf

Harassment includes, but is not limited to: offensive verbal or written conduct based on any protected characteristic; unwelcome sexual attention; intimidation or threats; exclusion or marginalisation on discriminatory grounds; and conduct that creates a hostile, degrading, or offensive environment for any participant.

Any person who experiences or witnesses harassment in an ASF-governed activity may report it under the ASF Internal Whistleblower Protection Policy (ASF-WHISTLE-001-v2), through the ASF Public Complaints & Feedback Policy (ASF-COMPLAINTS-001-v2), or directly to the Council Chair. Reports are handled confidentially, investigated independently, and the outcome communicated in writing to the reporting party. Retaliation against a person who makes a good-faith report is itself a violation of this policy and the Code of Conduct.

12. Monitoring, Reporting and Review

This policy is only as strong as its measurement. The following data are collected, analysed and reported annually.

This policy is reviewed on the same three-year cycle as the Methodology Manual. The review considers the monitoring data above, any complaints or incidents under Section 11, and changes in the international instruments to which this policy is anchored. The review outcome — reaffirm, revise, or retire — is documented in the Annual Activity Report for the year of review.

13. Relationship to Other ASF Documents

References

1. International Labour Organization. Discrimination (Employment and Occupation) Convention, 1958 (No. 111). Geneva: ILO; 1958.
2. United Nations. Convention on the Elimination of All Forms of Discrimination Against Women. New York: UN; 1979.
3. United Nations. Convention on the Rights of Persons with Disabilities. New York: UN; 2006.
4. United Nations. International Covenant on Civil and Political Rights. New York: UN; 1966.
5. United Nations. Guiding Principles on Business and Human Rights. New York: UN; 2011.
6. United Nations. International Convention on the Elimination of All Forms of Racial Discrimination. New York: UN; 1965.
7. International Labour Organization. Convention Concerning Indigenous and Tribal Peoples in Independent Countries (No. 169). Geneva: ILO; 1989.
8. United Nations. Declaration on the Rights of Indigenous Peoples. New York: UN; 2007.
9. International Labour Organization. Violence and Harassment Convention, 2019 (No. 190). Geneva: ILO; 2019.
10. France. Loi n° 2008-496 du 27 mai 2008 portant diverses dispositions d’adaptation au droit communautaire dans le domaine de la lutte contre les discriminations. Paris: République française; 2008.
11. France. Loi n° 2023-442 du 6 juin 2023 visant à améliorer l’accessibilité du service aux personnes handicapées. Paris: République française; 2023.
12. World Health Organization. Framework on Refugee and Migrant Health. Geneva: WHO; 2016.
13. United Nations High Commissioner for Refugees. Global Compact on Refugees. New York: UNHCR; 2018.
14. World Health Organization. Framework on People-Centred Health Services. Geneva: WHO; 2016.
15. United Nations. 2030 Agenda for Sustainable Development. New York: UN; 2015. Goals 3 and 10.
16. United Nations. Beijing Platform for Action. New York: UN; 1995.
17. Accreditation Canada. Patient Advisor Framework. Ottawa: Accreditation Canada; 2024.
18. ISQua External Evaluation Association. ISQua EEA Standards, 6th edition. Dublin: ISQua; 2024. Criteria 3.1–3.4 (Patient and Public Involvement).
19. World Health Organization. Plain Language Health Communication Guidelines. Geneva: WHO; 2022.
20. World Wide Web Consortium. Web Content Accessibility Guidelines (WCAG) 2.1. Cambridge (MA): W3C; 2018.