Attachment C of the Settlement Agreement between the United States and Carnival Corporation

Attachment C

CARNIVAL CORPORATION
Corporate Accessibility Standards

Introduction

Carnival Corporation (“Carnival”) is dedicated to offering a quality cruising experience to guests with disabilities. To assist in achieving this goal and in managing requests for accommodations and modifications, Carnival has adopted the following Corporate Accessibility Standards (the "Standards") which are set forth in detail below.

These Standards shall apply to Carnival Cruise Lines ("CCL"), Holland America Line ("HAL"), and Princess Cruise Lines ("PCL") (each individually a "Brand" or “Covered Brand”); collectively, "the Covered Brands") sailings that embark and disembark from United States’ waters or those of its territories (collectively, the "Covered Sailings"). The Standards establish a baseline that all Covered Sailings must meet. The Covered Brands are welcome to exceed the Standards.

There are several details about the Standards that are important to fully understand:

COORDINATION & MANAGEMENT OF ACCESSIBILITY ISSUES

Carnival has adopted a clear multi-level management structure to appropriately implement, manage, coordinate, and apply the Standards and respond to accessibility issues for the Covered Brands.

Carnival Corporation

Carnival Corporation will designate or hire an executive level ADA Compliance Officer (“ADACO”) who will be responsible for overseeing accessibility for individuals with disabilities including, more specifically, Carnival’s compliance with Title III of the ADA and implementing and administering its accessibility agreement with the United States.

The Covered Brands

Carnival Corporation will designate or hire an executive level ADA Responsibility Officer (“ADARO”) for both of CCL and Holland America Group who will serve as their respective brand’s ultimate contact on disability issues for the public and for the parties to Carnival’s accessibility agreement with the United States and have the authority to make decisions regarding accessibility issues for individuals with disabilities for their Covered Brand(s).

Each Covered Brand has shoreside staff who will administer the Standards on a day-to-day basis (including requests for accommodations and/or modifications) and assist in providing information regarding accessibility to guests for his/her respective Brand.

The Shoreside staffs will also be available to provide assistance to other shoreside departments (e.g., Reservations and Guest Services) as well as departments on board the Covered Sailings.

On Board Covered Sailings

Each Covered Sailing will designate or hire an ADA Shipboard Officer (“ADASO”) who will travel with the Covered Sailing and oversee the onboard department (e.g., Guest Services Department) or individual(s) responsible for responding to accessibility issues.  On each Covered Sailing, the Guest Services Department is available 24 hours a day, 7 days a week.  The ADASOs will have the authority to address most common accessibility issues during the Covered Sailings and the ability to rapidly escalate issues outside of his/her authority to the appropriate ADARO.

When responding to a complaint regarding a lack of accessibility, the appropriate personnel shall be directed to take whatever action is necessary to promptly comply with the Standards. If the complaint regarding a lack of accessibility raised by the guest has already occurred, that issue should be addressed and/or corrected as promptly as possible.  If an accessibility issue either requires escalation to a Manager or is submitted in writing (“ADA Complaint”), the guest must receive an initial substantive written response to his/her ADA Complaint within no more than 10 days. In the unlikely event that an ADA Complaint cannot be resolved prior to disembarkation, the ADA Complaint will be logged in the applicable Covered Brand’s system for complaints and available for review by the shoreside Guest Relations Department if needed.  If requested, a guest will be provided with the shoreside Guest Relations Department’s contact information to follow-up on his/her ADA Complaint as part of the post-cruise process.

In order to appropriately implement the Standards, the ADASOs and the Guest Services Departments have the authority to: (i) receive and investigate complaints; (ii) make reasonable adjustments, and/or modifications to policies, practices, and/or procedures; (iii) attempt to rectify complaints; or, if they cannot do so; (iv) contact other departments on board the ship (including, escalating the matter further up the ship's chain of command) and shoreside to obtain additional information and/or assistance.

Notwithstanding the above, on board, the Captain has ultimate authority, including over matters of accessibility.

ACCESSIBILITY REQUEST & COMPLAINT PROCEDURES

Carnival has adopted general complaint procedures to promptly and effectively respond to and resolve any guest (or potential guest) requests and complaints, no matter when/how they are raised. Requests and complaints regarding accessibility issues are handled through similar procedures as any other type of complaint raised by concerned guests, travel agents, or other interested parties and should be resolved at the earliest point of contact possible.

Each Covered Brand shall publish its contacts and procedures for raising a request and complaint on its website and in any appropriate brochures.

For 18 months each Covered Brand will maintain written reports documenting each ADA Complaint received and its resolution.

DISSEMINATION OF INFORMATION REGARDING ACCESSIBILITY

Carnival strives to empower its guests with sufficient information to make necessary decisions and preparations regarding all major aspects of the cruise experience. General information —including that specifically relating to accessibility – is made available to guests in a variety of formats.

Online Resources

Each Brand's website shall contain a separate section – accessible via a link on the main page – dedicated to providing information regarding accessibility on that Brand's Covered Sailings.

The accessibility section of the website shall also prominently provide links to other sections of each Brand's website that contain additional information relevant to accessibility issues.

Each Brand's website will be accessible to persons with disabilities.

Printed Materials

Each Brand shall also make accessibility information, simultaneously posted online, available in hard copy. Each Brand has the option to publish this material: (i) as a separate, stand alone, brochure regarding accessibility; (ii) as part of its general cruising brochures; and/or (iii) by providing a hard copy of the accessibility section of the Brand's website available upon request.

Onboard the Covered Sailings, each Brand shall include a section in the passenger information materials, in writing or electronically, (or supplemental insert or appendix to the existing passenger information material) contained in each cabin on the Covered Sailings identifying the ADASOs and their department or individual(s) responsible for responding to onboard accessibility issues and advising guests that the ADASO is responsible for handling disability-related claims onboard the Covered Sailings during the duration of the cruise and will report the nature and outcome of ADA Complaints (as defined elsewhere in these Standards) to the ADARO.

To the extent printed materials are made available regarding the following specific topics, each shall contain additional information relevant to accessibility issues: (i) excursions; and (ii) reservations.

Alternate Formats

Upon advanced request to the Shoreside ADA Representative's office, but no later than two weeks before the date of the requesting party's embarkation (or four weeks if the request is for Braille), Carnival will provide guests with any of its publicly disseminated brochures in an alternate format. If requests for alternate format materials are made less than two weeks prior to the requesting party's embarkation (or four weeks if requesting Braille), Carnival will fulfill the request to the extent it is feasible.

Updates

All reasonable efforts will be made to promptly update these materials as the Standards or Implementation Policies materially change and/or new information becomes relevant.

ACCESSIBILITY TRAINING

Carnival shall conduct an accessibility training program to provide shoreside and onboard staff/officers/crew with the knowledge necessary for their anticipated level of guest contact and their level of authority. This ongoing training, coordinated with the staff’s/officers’/crew’s traditional duties, will enhance current knowledge with proper responses to guest (or potential guest) inquiries and facilitate the resolution of guest complaints.

At a minimum each accessibility training will include: (i) general background on the ADA; (ii) an overview of the Company’s accessibility policies, practices and procedures (including examples of reasonable modifications of policies, practices and procedures); (iii) etiquette when interacting with individuals with disabilities; (iv) the process for responding to ADA requests and complaints (or where to direct guest requests and/or complaints, as appropriate); and (v) relevant accessibility features for the ships. Carnival may utilize multiple versions of the training materials (e.g., for use with different Covered Brands; management versus crew; shoreside versus onboard). 

As part of its accessibility training policies, practices, and procedures, Carnival will:

      1. Train the ADACO, the ADAROs, and other relevant members of senior management who will have a role in implementing these Corporate Standards and other aspects of compliance with Carnival’s accessibility agreement with the United States;
      2. Train all existing first-line supervisors and managers with regular anticipated guest contact (e.g., Guest Service Manager; Housekeeping Manager; Hotel Director; Restaurant Manager) who are in place as of the Effective Date of Carnival’s accessibility agreement with the United States.  Thereafter, the Company will train all new first-line supervisors and managers with regular guest contact within 45 days of the employee joining his/her first ship;
      3. Train all other existing crew/employees with regular anticipated guest contact who are in place as of the Effective Date of Carnival’s accessibility agreement with the United States. Thereafter, the Company will train all new hire employees with regular anticipated guest contact within 45 days of the employee joining his/her first ship; and
      4. Provide “refresher” training every 2 years to all individuals required to receive training under Carnival’s accessibility agreement with the United States. If there is a substantive change in a Company policy, the Company will provide interim training regarding the revised policy.

The accessibility training can be provided by live sessions, video recordings, and computer-based training.

ACCESSIBLE CABINS: RESERVATIONS, BOOKING & UPGRADES

Accessibility on board the Covered Sailings includes the existence of a variety of types of accessible cabins each with unique features meant to provide the appropriate levels of access for guests with different types of disabilities. 

The types of accessible cabins onboard each of the Covered Sailings include:

(collectively, the “Accessible Cabins”).  The Accessible Cabins will be dispersed within each Meta for each Covered Sailing at the Total Accessible Cabin (i.e., FAC + FAC-SSA + AAC) level. As with all Carnival reservations, Accessible Cabins are to be assigned on a first-come/first-serve basis to individuals with disabilities (whether booked by the individual with a disability or on his/her behalf by someone else in the party). However, within each meta, each Covered Brand shall take all reasonable steps so that, where Accessible Cabins exist, a FAC (and if an FAC is not available, then a FAC-SSA; and if an FAC-SSA is not available then an AAC if available) is the last cabin booked (unless such cabins are already booked by individuals with a disability).

If an individual with a disability requests an accessible cabin type in a Meta where no accessible cabin exists (i.e., never built as opposed to sold out) and the desired Meta still has non-accessible cabins available for booking at that time, the Company will upgrade the individual at no charge to the same type of accessible cabin or suite in the next immediately higher available Meta where that type of accessible cabin or suite is available.
Each Covered Brand provides current and detailed information regarding the locations and features of Accessible Cabins: (i) on each Brands' website (in the accessibility and reservations sections); (ii) in applicable printed brochures (e.g.,regarding accessibility and/or booking a cruise); (iii) in alternate formats when requested at least two weeks in advance of booking (or four weeks if requesting Braille); (iv) to travel agents; and/or (v) upon contacting the respective Brand's Shoreside ADA Representative.

ACCESSIBLE AIRPORT TRANSFERS

Carnival provides accessible transportation to and from the airports within the United States and its territories, at no additional cost, for guests who purchase airport transfers.

EMBARKATION & DISEMBARKATION

To accommodate guests with disabilities who require assistance during embarkation and disembarkation, Carnival has adopted several modifications to its general policies and procedures. These modifications balance the need for a safe and efficient embarkation and disembarkation with the desire for integration, inclusion, and equality of services for all guests.

In promoting these goals during the embarkation/disembarkation process:

SHORE EXCURSIONS

Carnival provides its guests with sufficient information regarding shore excursions to assist them in determining the appropriateness of a specific shore excursion. Moreover, Carnival makes appropriate staff available prior to Covered Sailings and while onboard to help answer any additional questions guests might have regarding shore excursions.

Where Carnival owns, operates, or leases transportation that is provided during shore excursions in the United States and/or its territories, Carnival provides accessible transportation to guests with disabilities, at no additional cost.

Notwithstanding any other policies and procedures, Carnival shall promptly provide a full refund to any guest who is unable to fully participate in an excursion because the excursion's level of accessibility was not accurately disclosed prior to and/or at the time of booking.

EFFECTIVE COMMUNICATION

Carnival’s ongoing commitment to providing all of its guests with disabilities with a fully and equally enjoyable cruising experience, includes a multi-faceted approach to assist all guests in achieving effective communication expressively, receptively, and contextually.

Carnival acknowledges that determining what constitutes effective communication is a contextual assessment that requires a review of a variety of factors both about the individuals involved (e.g., what is the disability at issue and the limitations it causes) and the situation (e.g., is it a one-on-one conversation, participation in a group event or scripted or unscripted live presentation). Therefore, in implementing this Standard, Carnival engages in individualized-inquiries as needed on a case-by-case basis.

Covered Sailings offer a wide range of auxiliary aids and services to provide guests with disabilities with effective communication.

Carnival understands that, depending upon the context and situation, and to the extent they do not create a fundamental alteration or an undue burden, appropriate auxiliary aids and services may include inter alia:

DINING

Carnival provides an enjoyable onboard dining experience for its guests with disabilities and/or dining restrictions.
For Covered Sailings, this includes:

MEDICAL & RELATED AUXILIARY SERVICES

The Covered Sailings contain onboard medical facilities staffed with qualified, licensed, physicians and nurses.

In addition, Covered Sailings provide guests with: (i) some auxiliary services related to medical care (e.g.,hazardous waste/sharp object containers; and cooling devices for the storage of medicine); and (ii) information necessary for guests to make informed decisions about traveling with other medical conditions and/or equipment (e.g.,oxygen).

Other Power-Driven Mobility Devices

The Covered Sailings shall make reasonable modifications to their policies, practices, and procedures to permit the transportation, storage, and/or use of other power-driven mobility devices by individuals with mobility disabilities on board, unless the Covered Sailings (or a specific ship) establish that the class of other power-driven mobility devices cannot be operated on the ship in accordance with legitimate safety requirements.

YOUTH PROGRAMS

To help provide guests of all ages with a positive cruising experience, Carnival has designed a series of programs and built facilities that are geared specifically towards its younger guests (the “Youth Programs”).

Carnival's Youth Programs shall operate with goals of integration and inclusion. Youth Program staff shall work with parents and/or legal guardians (e.g.,reviewing daily itineraries, medical information, etc.) to include all children with disabilities within the designated age-range in the available programs on a case-by-case basis. Each child's needs shall be assessed on a case-by-case basis to determine how s/he can be accommodated and integrated in the program (including, meals, games, trips, etc.) to have a fully and equally enjoyable experience as other participants.

EMERGENCY DRILLS

Carnival has adopted policies, practices, and procedures – compliant with the Safety Of Life At Sea (“SOLAS”) treaty – to prepare both crew and guests in the event of an emergency. Understanding that individuals with disabilities might face unique challenges during an emergency, Carnival has designed and implemented policies, practices, and procedures to provide individuals with disabilities with the information and assistance they need to successfully navigate emergency drills and actual emergencies.

Information regarding the delivery of emergency information shall be available as part of the accessibility section of each Brand's website or upon request in advance of, or during, booking.1

ENTERTAINMENT VENUES

Carnival recognizes that its live entertainment is often among the highlights of each evenings' activities onboard its ships. To assist guests with disabilities to fully enjoy their experience during these events, each Covered Sailing:

  1. will provide assistive listening devices for use at its main theaters and primary entertainment venues;
  2. includes accessible seating locations in its theaters and entertainment venues which are identified with the ISA (international symbol of accessibility); and
  3. shall implement a policy that provides individuals with mobility disabilities access to accessible seating locations up to 15 minutes prior to the start of a scheduled performance.

SERVICE ANIMALS

Service animals are permitted onboard the Covered Sailings and inside public and common-use spaces/facilities (e.g., dining, recreation, theaters, shops, cabins, gyms, casinos, etc.). Service animals are dogs that are individually-trained to do work or perform tasks for the benefit of an individual with a disability (e.g.,guide dogs, hearing-ear dogs, psychiatric service dogs) (“Service Animals”).

Emotional support animals, by their definition, are not service animals and, therefore, are not permitted onboard.

1 Alternative format copies of safety drill instructions are not available in advance of embarkation. However, guests who make the appropriate advanced request for such materials will be provided with the written materials in an alternative format on board.

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