Nomensa Report Accessibility of FTSE 100 Company Web Sites - Update

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 Nomensa Research
 Accessibility of FTSE 100 Web Sites – Update                               www.nomensa.com

                                  Nomensa Report
                     Accessibility of FTSE 100
                   Company Web Sites – Update

                             Author Léonie Watson
                        Contributors Simon Norris, Alastair Campbell, Alex Metcalf, Marc Deglos
                                     and Jonathan Shipley
                                Date 17th May 2004
                        Distribution Public distribution
                             Version 1.0

Document Summary
This document contains an update to the Nomensa FTSE 100 Accessibility Report that was
published in January 2004.
This research survey has been undertaken solely by Nomensa without any external influence or
commercial sponsorship. The research methodology ensured that no prejudicial or beneficial
preference was applied to any of the sites tested.

For any further information about any points made in this document please do not hesitate in
contacting Nomensa:
Léonie Watson
Accessibility Consultant
Email: lw@nomensa.com
Phone: +44 (0)117 344 5012

Nomensa Ltd.                t: +44 (0)117 344 5012                                   Page 1 of 27
1 Friary, Temple Quay       f: +44 (0)117 344 5257                                      17/5/04
Bristol, BS1 6EA
Foreword
Welcome to the second Nomensa report focusing on the accessibility of the FTSE 100. The first
report was received with great success with hundreds of people requesting a copy of the report
and many people providing fantastic feedback. We have listened to what people have said and
responded by simplifying our scoring procedure. However, our focus and commitment as an
organisation has not changed. We are dedicated to making the web a more accessible, usable
and enjoyable experience for all people, regardless of ability.

Overview of results
As can be seen from the table below, the overall levels of accessibility and usability are
improving. This is an indication that the implementation of accessibility is playing an increasingly
important role in the formulation of Corporate Social Responsibility (CSR) strategy, a move
applauded by Nomensa.
                                         Alternate Text
                           Conformance

                                                          Code Validity

                                                                                                                                             Link Quality
                                                                                        Access Keys

                                                                                                                                                            Page Titles
                                                                                                                               Alt Quality
                                                                          Scalability

                                                                                                      Skip Links

                                                                                                                   Structure

                                                                                                                                                                          Total
Year

2003                          11%           21%                    1%        23%                1%        N/A        10%          44%           46%            49%        23%
2004                          37%           41%                    1%        38%                2%        3%          7%          56%           34%            76%        30%
Table 1: Results comparison between 2003 and 2004

Maintaining accessibility
Re-engineering a web site to be both accessible and usable has legal, commercial and social
ramifications. However, once you have designed an accessible web site the problem does not go
away – the real problems begin:

    How do you sustain the level of accessibility that you have achieved without
    compromising quality?

Typically, a web site may be developed or re-designed to be accessible; however, over time the
quality of the web site begins to degrade and, ultimately, your users suffer.
If you cannot sustain the expected level of quality you run the risk of having to complete the
exercise again. This puts additional drain on company resources and means that your initial
investments are short lived. Therefore, when you get your web site or intranet redesigned to be
accessible, make sure that procedures have been included to sustain the level of accessibility
achieved.
Using this report
I do hope you enjoy reading our second FTSE 100 report. Please read it, use it and distribute it to
your colleagues. Remember that web site accessibility will benefit your organisation by both
reinforcing existing Corporate Social Responsibility programmes and commitments and more
importantly by achieving legal compliance.
Simon Norris
Managing Director
11th May 2004
Contents
About Nomensa....................................................................................................................................................................5
Introduction............................................................................................................................................................................6
   Accessibility Overview..................................................................................................................................................6
   How Accessibility and Usability Are Related.......................................................................................................6
   Making the Case for Accessibility ............................................................................................................................6
Legislation and Guidelines...............................................................................................................................................8
   Disability Discrimination Act (1995) .......................................................................................................................8
   Web Content Accessibility Guidelines (1999) ....................................................................................................8
Process and Method ........................................................................................................................................................ 10
   Research Scope ............................................................................................................................................................ 10
   Testing Categories....................................................................................................................................................... 10
   Testing Focus................................................................................................................................................................. 10
   Test Descriptions.......................................................................................................................................................... 11
Research Results ................................................................................................................................................................ 14
   Results and Comparisons......................................................................................................................................... 14
Results Table........................................................................................................................................................................ 18
   Result Analysis............................................................................................................................................................... 20
Conclusions.......................................................................................................................................................................... 22
Glossary ................................................................................................................................................................................. 23
Appendices.......................................................................................................................................................................... 26
   Appendix A: Company web site addresses ...................................................................................................... 26
About Nomensa
Nomensa, a digital design company, is dedicated to improving online effectiveness by
humanising technology. We are experts at understanding online behaviour and use our
knowledge to improve business performance.
Our approach fuses usability, accessibility, design, technology and market research to provide
more inclusive and supportive Internet technologies. By understanding the key elements that
make up a winning online strategy Nomensa are ideally positioned to offer practical advice that
will make a real difference to both your customers and your brand.

      “Our working relationship with Nomensa has been excellent. They delivered
      in a timely manner and exceeded service expectations. Their dedication and
      originality in finding solutions to our problems has been a real help to AA
      eCommerce designers and developers. We would have no hesitation
      recommending them to another company.”
                                        Dominic Duckworth, Content Manager, theAA.com

Nomensa has completed projects for key brands such as BAE Systems, BT, British Gas and The AA.
The commercial benefits that result from our work include:
        ƒ   Projecting a high level of corporate social responsibility (CSR)
        ƒ   Achieving legal compliance with UK and international disability legislation
        ƒ   Providing technology that is both enjoyable and user friendly
        ƒ   Generating positive user experiences
        ƒ   Increased competitiveness
        ƒ   Achieving a high level of ROI
        ƒ   Improved measurement strategies
        ƒ   Increased profitability.
For more information please visit our web site, www.nomensa.com, to discover how we can
bring a measurable difference to your online strategy.
Introduction
In this report we provide the results from our most recent cycle of research into the accessibility
of web sites belonging to FTSE 100 companies. The accessibility of companies’ web sites should
be a fundamental success factor for Corporate Social Responsibility (CSR) programmes.
We investigate the current state of accessibility by providing a comparative analysis between
Nomensa’s research conducted last year for the original FTSE 100 Accessibility Report and this
current round of tests.
Always believers in the importance of effective communication, we have refined the testing
process and scoring system in response to feedback from the previous report. We hope that
these adjustments will make the information easier to read and simplify the task of
understanding how we have measured accessibility and usability.

Accessibility Overview
Accessibility is the availability of information and services to all users, regardless of ability,
technology or situation. Many people are aware of the importance of accessibility for user groups
such as people with vision impairments. However, accessibility also addresses the needs of many
other users, such as people with dyslexia and people who are hard of hearing. In a wider context,
the changes to make a site accessible also have a highly beneficial effect for all users, as the
fundamentals of accessibility stem from well structured information presented on web pages
written with standards-compliant code.
Usage of the Internet is rapidly increasing for user groups more noticeably affected by poor
accessibility. Elderly and retired people form a growing percentage of the market, along with
disabled people who may have visual, hearing, cognitive or physical restrictions. These (and all)
user groups have spending power and influence that impacts on corporate reputation and,
ultimately, share value and profitability.
In addition, with the range of devices used to access the Internet expanding to include
televisions, mobile phones and PDAs1, the importance of ensuring that web sites are accessible is
greater than ever.

How Accessibility and Usability Are Related
If the ideal of accessibility is availability to all, usability is the ease of that availability and the
usefulness of what is available. While accessibility is often considered to be a black and white
measure – for example, either information on a web site page is ‘accessible’ or it is not – the
distinction between accessibility and usability is continuing to narrow. Nomensa advocates the
consideration of accessibility as part of a wider consideration of the user experience of a web site
– we call this approach humanisation.

Making the Case for Accessibility
Accessibility has evident moral importance. However, by endeavouring to make your web site
accessible to all you are also fulfilling several important obligations. Not only can there be a legal
requirement to do so, in line with the Disability Discrimination Act (DDA), but there is also the

1
    Personal Digital Assistants
economic obligation to shareholders – a site with poor accessibility is simply a barrier that limits
the number of customers your company can address.
Last, but by no means least, an accessible site should be appreciated for its importance in a
company’s CSR programme. At a time when corporate competition is as active as ever, those
organisations who are able to demonstrate that they are responsible and humanitarian will be
suitably rewarded in the public eye.
Legislation and Guidelines
Disability Discrimination Act (1995)
The Disability Discrimination Act (DDA) was enacted into UK law in 1995. It is intended to protect
people with disabilities from being unfairly treated or discriminated against.
The DDA places an obligation on public and private sector organisations to ensure that their
products, services business practices and premises present no obstructions or difficulties to
persons with disabilities.
Web site accessibility resides under the remit of ensuring that information and services are
available to users with disabilities. A web site is considered to be a service presented to the
public, and as such an organisation is responsible for making every reasonable effort to make
those services available. It should also be noted that the DDA not only covers web sites but also
company intranets, where, from Nomensa’s experience, the need to improve accessibility can be
even greater.

Web Content Accessibility Guidelines (1999)
The Web Content Accessibility Guidelines (WCAG) are compiled by the Web Accessibility
Initiative (WAI), a working group of the World Wide Web Consortium (W3C).
Version 1.0 of the WCAG was formalised in 1999 and is comprised of a series of checkpoints
based around fourteen design principles. In order to clearly define acceptable levels of
accessibility, these checkpoints are divided into three distinct categories.
        ƒ   Priority One – Compliance with all Priority One checkpoints achieves Level A
            accessibility.
        ƒ   Priority Two – Compliance with all Priority Two checkpoints achieves Level AA
            accessibility.
        ƒ   Priority Three – Compliance with all Priority Three checkpoints achieves Level AAA
            accessibility.
The guidelines form the basis for accessibility and usability implementation, but are not the only
means by which these concepts are either applied or measured. Instead, as their title suggests,
they form a guide from which accessibility and usability can be incorporated into web
development. They provide a solid starting block from which a developer can progress onwards
to more complex techniques for web accessibility implementation.

Moreover the guidelines also provide targets around which an accessibility strategy can be
formulated. In the UK, the Government recommend Level AA compliance as the standard of
accessibility at which to aim.
At Nomensa we would always encourage working towards the highest degree of accessibility
possible, but we do appreciate that as an initial goal this may not always be practical. In light of
this we would recommend implementing a strategy of achieving Level AA conformance, whilst
promoting an awareness of further steps that can be taken in the future to further raise the
accessibility of a site.
Process and Method
Research Scope
The companies whose sites were evaluated were taken from a FTSE 100 listing for Q1 2004,
provided by www.ftse.com.
The web site addresses used were taken from a spreadsheet available on the London Stock
Exchange web site. Where the spreadsheet did not list a web address for a company, the most
prominent (based on a Google search) UK-based web address was used. Identifying the various
web sites that belong to a company can be a complex process at best; Nomensa believe that
many companies should further develop their strategies for managing their portfolio of sites and
how those sites are portrayed to the public. Confusion over which site a person should access
could be a fundamental stumbling block for people attempting to work with a company;
credibility of the company can consequently be severely undermined. People need to trust a
company and the information it provides.
The 100 web sites were evaluated over a two week period beginning on the 8th March, with the
report compiled over the following month.

Testing Categories
In the time since the research for the original report was completed we have developed the
testing process by extending the criteria we measure and by simplifying the scoring system.
We expanded the range of categories that we tested in order to provide a more comprehensive
picture of accessibility and usability within the context of commercial web design.
The extended criteria list is given below, along with a brief explanation of its purpose:
        ƒ   Conformance – Conformance level achieved under the WCAG.
        ƒ   Alt Text – Do all images have alt attributes set?
        ƒ   Code Validity – Has valid code been implemented?
        ƒ   Scalability – Has relative sizing been implemented?
        ƒ   Access Keys – Have keyboard shortcuts been correctly implemented?
        ƒ   Skip Links – Have shortcut links been implemented?
        ƒ   Structure – Have headings been correctly implemented?
        ƒ   Alt Quality – Have the alt attributes been set appropriately?
        ƒ   Link Quality – Has link text been set appropriately?
        ƒ   Page Titles – Do pages carry unique and helpful titles?

The scoring system itself was refined in order to remove the multi-layer points structure used in
the original report. Each of the above categories, with the exception of Conformance, now carries
a simple pass or fail. The Conformance category is necessarily awarded a maximum of 3 points in
accordance with the different levels of compliance achievable under the Web Content
Accessibility Guidelines (WCAG).

Testing Focus
For each of the 100 sites tested, the home page was the primary focus. The only category to
move beyond the home page was Page Titles, where two further pages were chosen at random
from commonly found links such as Media Centre, Contact Us, Investor Information, Site Map and
About Us.

Test Descriptions
To further help appreciate the requirements of each testing category, a fuller description is given
below. The number shown is the score awarded for achieving the appropriate pass or level in the
test – other than for the Conformance test this is simply no points or one point.

Conformance
        ƒ   0 = Failure to achieve basic compliance under the Web Content Accessibility
            Guidelines (WCAG)
        ƒ   1 = Achievement of Level A compliance under the WCAG
        ƒ   2 = Achievement of Level AA compliance under the WCAG
        ƒ   3 = Achievement of Level AAA compliance under the WCAG.
As previously outlined, the WCAG are the benchmark by which basic accessibility is gauged. The
degree to which a web site succeeds when measured against the guidelines using an automated
checker is the basis for this score.

Alt Text
        ƒ   0 = Alt attributes have not been set for all images
        ƒ   1 = Alt attributes have been set for all images.
All images, including graphics, buttons, spacers and image maps should carry an alternate
description, known as an alt text.
The alt text should also be appropriate to the image; this is covered by the Alt Quality test
described later.

Code Validity
        ƒ   0 = Code does not validate to formal published specification
        ƒ   1 = Code validates to formal published specification.
There are a variety of different languages that may be used to write a web page, each with a
formal specification.
The language in which a page is written should be declared at the top of each web page within a
site and the code therein must conform to the rules of that language.

Scalability
        ƒ   0 = The site does not implement relative sizing
        ƒ   1 = The site implements relative sizing.
The text on a web site should be capable of being resized by using the browser’s own
functionality. For example, a Windows Internet Explorer user should be able to resize the text by
selecting one of the ‘Text size’ options in the ‘View’ menu.
Access Keys
        ƒ    0 = Keyboard shortcut keys are absent or incorrectly implemented
        ƒ    1 = Keyboard shortcut keys are correctly implemented.
Access keys should be used sparingly and consistently across a site, to provide keyboard
shortcuts to specific page elements.
Each access key should lead to an actual entity on a page, such as a particular link or a search
facility. They should not be assigned to entities that have no purpose, such as redundant internal
page anchor links.
Most importantly, they should not override existing browser functions. For example Alt+a is the
browser shortcut to access the ‘Favourites’ menu, yet is often used as the access key to locate an
accessibility statement.
It is also important that, where necessary, information about access keys is provided clearly and
accurately and that access keys are clearly and accessibly defined so that their purpose is
apparent.

Skip Links
        ƒ    0 = Skip links are not implemented
        ƒ    1 = Skip links are implemented
Internal page anchor links, known as Skip Links, should be implemented to provide a means for
non-mouse users to skip over portions of a web page in order to easily reach the relevant page
element. For example, when a screen reader user reads a page, all structural formatting is lost
and the content is presented in linear format not unlike a shopping list. The presence of a skip
link enables a screen reader user to bypass a portion of a page – perhaps the navigational links –
and move directly to the start of the page content.

Structure
        ƒ    0 = Headings are absent or incorrectly implemented
        ƒ    1 = Headings are present and correctly implemented.
Headings should be used to structure a web page, providing a logical order to content.
They should not be used purely as a means of visual demarcation, but should indicate the
significance and relationship of information.
The correct nesting of headings is imperative. The first heading on a page must be a level one
heading, with subsequent headings falling in consequent order. For example, after a level one
heading, the next subheading should be level two, not level three.

Alt Quality
        ƒ    0 = For every image, alt text is not appropriate or equivalent to the image
        ƒ    1 = For every image, alt text is appropriate or equivalent to the image
Given that all images should have an alt attribute set, it is crucial that the alt text is appropriate to
the graphic.
For images that display pertinent information, the alt text must convey that information exactly.
Images that are purely decorative should either carry a short descriptive alt text or a null (empty)
text.
For layout or spacer images the alt text should be null. Using asterisks (*) or text such as “spacer”
are not considered appropriate.

Link Quality
        ƒ    0 = Link text is context dependant or repeated multiple times on a page
        ƒ    1 = Link text is context independent and is unique on the page
Link text should be concise and should accurately indicate the nature of the page that it points
to. Unless one or more links lead to the same destination, each link should also be unique.
It is also necessary that link text is meaningful when read out of context of the surrounding page,
in order that the destination may be correctly interpreted without needing to investigate content
in the immediate vicinity.

Page Titles
        ƒ    0 = Page titles are absent or generic to the site
        ƒ    1 = Page titles are present and unique to the page
Each page, regardless of whether it uses frames, should be given a unique and helpful title. This
should provide global information about the site in general, as well as a more precise indication
of the given page content. For example, “Page Content – Section – Company Name”. If frames
are used within a site, it is extremely important that each frame is also given an accurate and
relevant title.
Research Results
The following sections reveal the results of our recent research in greater detail than is available
by viewing the tabular data in the Results Table starting on page 18.
Each category is addressed in turn, providing a comparison between the original FTSE 100
Accessibility Report statistics and those found in the present research.
At the start of each section the results for that category will be given as a percentage pass rate
(the percentage who achieved a mark of 1 or higher). The first figure will be the result from the
initial research and will be marked “2003”. The second figure will be the result from this latest
research and will be marked “2004”. The year given indicates the time when the testing was
carried out.

Results and Comparisons
Conformance
        ƒ    2003:- 11% (Level A pass or higher)
        ƒ    2004:- 37% (Level A pass or higher)
The marked increase in the Conformance category – an improvement of 26% in terms of Level A
(or higher) compliance under the WCAG, is tremendously encouraging. It clearly demonstrates a
trend towards accessibility in commercial web design and a recognition of the legal obligations
placed upon corporate bodies.
It is disappointing however to find that the increase is not prevalent in terms of Level AA and
AAA compliance with the WCAG. The absolute absence of Level AA and AAA passes across the
board reveals that there is significant scope for improvement. The first FTSE 100 company to
achieve Level AAA conformance will be at the cutting edge of web accessibility excellence and
will receive all the associated benefits that accompany such a prestigious position.
Without doubt checks against the Web Content Accessibility Guidelines are the benchmark by
which legal cases will be made. A Level A pass may be satisfactory, but only a Level AA or AAA
pass takes the site to a point where the expectations of the Disability Discrimination Act (1995)
can safely said to have been met.
Alt Text
        ƒ    2003:- 21% (of the FTSE 100 sites passed this test)
        ƒ    2004:- 41% (of the FTSE 100 sites passed this test)
Another strong increase, this time in the Alt Text category, with an additional 20% of the sites
demonstrating recognition of this crucial accessibility concept.
Despite this, the majority of sites tested still do not appreciate the absolute necessity of setting
an alt attribute for all images. In failing to meet this requirement they are restricting millions of
people from accessing company information and services.

Code Validity
        ƒ    2003:- 1%
        ƒ    2004:- 1%
The Code Validity category is the only aspect of our research not to show any change, which
demonstrates how developers’ understanding of code and construction quality needs to
improve.
Frequently the validity of code is an area that suffers from lack of knowledge and appreciation of
the benefit that it brings to published digital documents.
Understandably it is a difficult problem to remedy by retrofitting. However, as we move into a
time where accessibility is not only the remit of good CSR but also a legal requirement, it is
surprising to find that this first line of digital accessibility and usability is not viewed with the
significance it deserves.

Scalability
        ƒ    2003:- 23%
        ƒ    2004:- 38%
Once again results are favourable, with a 15% advance in the Scalability category. The ability to
resize text is something that will assist almost all types of user, from those with mild myopia
(short sightedness) through to those using devices with smaller than average screens (mobile
phones or PDAs).
Reading from a screen is widely understood to place a greater strain on the eyes than reading
from print. By providing the user with the opportunity to rescale the size of the text, a more user
friendly environment is created.

Access Keys
        ƒ    2003:- 1%
        ƒ    2004:- 2%
With a category that is among the least familiar of accessibility concepts, an advance of only 1%
in Access Keys is understandable.
The lack of convention for implementing access keys and the frequency with which they override
browser functions makes this a difficult feature to implement correctly. The absence of a
standard set of access keys raises the possible combinations of keys exponentially and, along
with it, the memory load on the user.
Used appropriately they can be a useful asset to a site and should be implemented as such, but
growing wisdom suggests that the future for access keys is a long way from certain.

Skip Links
        ƒ   2003:- N/A
        ƒ   2004:- 3%
Even without being able to draw comparisons with previous research, the lack of success in the
Skip Links category is extremely disappointing. Internal page anchor links have been in existence
for a long time and have always been used to facilitate moving between sections of lengthy
content.
However, their importance in terms of usability appears to be an unknown factor amongst many
web developers. Used competently they can be one of the more useful tools for users who do
not have the ability to visually scan a page for the section they want.
This is, however, a new category for our research and it is hoped that as awareness grows that
future results will be more promising.

Structure
        ƒ   2003:- 10%
        ƒ   2004:- 7%
Here we arrive at the first of the categories to have undergone a change in the scoring
mechanism. The criteria for this category were tightened, allowing less room for interpretation.
The new results revealed a 3% drop when compared to the previous report results and this can
most likely be attributed to the change in the scoring mechanism.
It should be noted, however, that the overall standard of page structure has one of the lowest
pass rates of the tested categories and makes clear the lack of coherence evident on many pages.
It is particularly ironic that the business world, with evident requirements for quick and easy
access to important information such as share prices, is so unaware of the benefit that well
structured digital content can offer.
Irrespective of accessibility, it is well understood that information broken down into logical,
manageable segments is easier to locate, access and comprehend.

Alt Quality
        ƒ   2003:- 44%
        ƒ   2004:- 56%
In the second of the categories to undergo a scoring overhaul, the results for Alt Quality have
shown a fair improvement, with a 12% rise in the appropriateness of alt text.
Although growth in the overall presence of alt text is flourishing, the appreciation of appropriate
alternate text is a more difficult concept to master. It is encouraging to find an improvement in
this test result, despite the testing criteria being stricter than before.
Link Quality
        ƒ   2003:- 46%
        ƒ   2004:- 34%
The Link Quality category is the second of two categories to show a drop in success – the other
being Structure. Part of the 12% drop is likely to be due to the changes made to the scoring
system, but there is also empirical evidence that suggests that due to the fluid nature of the
content on many home pages the problem is still reasonably serious.
The frequency with which repetitive, context dependent links are found on the home pages of
FTSE 100 company web sites represents a failure to communicate information as effectively as
possible, by forcing the user to explore the surrounding page content in order to understand
where the link will lead.

Page Titles
        ƒ   2003:- 49%
        ƒ   2004:- 76%
Despite changes in the testing criteria the Page Titles category shines through with the second
most pronounced rise of all the tests in this research.
An advance of 27% makes Page Titles have the highest pass rate of all the tests on the FTSE 100
web sites. It is a clear indication that developers are recognising the validity and benefit of
ensuring that each and every page across a site carries a unique title.
The most encouraging aspect of this last result is that it provides further evidence that
accessibility and usability are becoming more apparent in commercial web development.
Results Table

                                                        Alternate Text
                                          Conformance

                                                                         Code Validity

                                                                                                                                                            Link Quality
                                                                                                       Access Keys

                                                                                                                                                                           Page Titles
                                                                                                                                              Alt Quality
                                                                                         Scalability

                                                                                                                     Skip Links
            Company

                                                                                                                                  Structure
Position

                                                                                                                                                                                         Total
=1          Gallaher Group                         1               1                0             1             1            1           1             1              1             1        9
=1          Prudential                             1               1                0             1             1            1           1             1              1             1        9
3           Centrica                               1               1                0             1             0            0           1             1              1             1        7
=4          HBOS                                   1               1                0             1             0            0           1             1              0             1        6
=4          Intercontinental                       1               1                0             0             0            0           1             1              1             1        6
            Hotels Group
=4          Rolls Royce                           1                1               0              1             0            0           0             1              1             1        6
=7          BG Group                              1                1               0              1             0            0           0             1              0             1        5
=7          BHP Billiton                          1                1               0              1             0            0           1             0              0             1        5
=7          BT Group                              1                1               0              0             0            0           0             1              1             1        5
=7          Friends Provident                     1                1               0              1             0            0           0             1              0             1        5
=7          GUS                                   0                0               0              1             0            1           0             1              1             1        5
=7          Imperial Tobacco Grp                  1                1               0              1             0            0           0             1              0             1        5
=7          Kingfisher                            1                1               0              1             0            0           0             1              0             1        5
=7          Legal & General                       1                1               0              1             0            0           0             1              0             1        5
=7          MMO2                                  1                1               0              0             0            0           0             1              1             1        5
=7          National Grid                         1                1               0              1             0            0           0             0              1             1        5
=7          Northern Rock                         1                1               0              0             0            0           0             1              1             1        5
=7          Rio Tinto                             1                1               1              0             0            0           0             0              1             1        5
=7          Sainsbury (J)                         1                1               0              0             0            0           0             1              1             1        5
=7          Shell                                 1                1               0              1             0            0           0             1              0             1        5
=7          Shire Pharmaceuticals                 1                1               0              1             0            0           0             1              1             0        5
=7          Standard Chartered                    1                1               0              1             0            0           0             0              1             1        5
=7          WPP Group                             0                1               0              1             0            0           0             1              1             1        5
=24         Boots Group                           0                0               0              1             0            0           1             1              0             1        4
=24         BP                                    1                1               0              0             0            0           0             1              0             1        4
=24         Cadbury Schweppes                     1                1               0              1             0            0           0             0              0             1        4
=24         Exel                                  1                1               0              1             0            0           0             0              0             1        4
=24         Hanson                                1                1               0              0             0            0           0             1              0             1        4
=24         HSBC                                  1                1               0              1             0            0           0             0              0             1        4
=24         Lloyds TSB                            1                1               0              1             0            0           0             0              0             1        4
=24         Next                                  1                1               0              0             0            0           0             0              1             1        4
=24         Reed Elsevier                         1                1               0              1             0            0           0             0              0             1        4
=24         Rentokil Initial                      0                1               0              1             0            0           0             0              1             1        4
=24         Royal Bank of Scotland                1                1               0              1             0            0           0             0              0             1        4
=24         Schroders                             1                1               0              0             0            0           0             0              1             1        4
=24         Unilever                              0                0               0              1             0            0           0             1              1             1        4
=37         3i Group                              -2               0               0              0             0            0           0             1              1             1        3
=37         Abbey National                        0                0               0              1             0            0           0             1              0             1        3
=37         Alliance & Leicester                  1                1               0              0             0            0           0             0              1             0        3
=37         Alliance Unichem                      1                1               0              0             0            0           0             0              0             1        3
=37         Amersham                              0                0               0              0             0            0           0             1              1             1        3

2
    The Bobby tool was unable to check 3i Group’s web site, so no score has been assigned.
Alternate Text
                                    Conformance

                                                                   Code Validity

                                                                                                                                                      Link Quality
                                                                                                 Access Keys

                                                                                                                                                                     Page Titles
                                                                                                                                        Alt Quality
                                                                                   Scalability

                                                                                                               Skip Links
           Company

                                                                                                                            Structure
Position

                                                                                                                                                                                   Total
=37        AstraZeneca                       0               0                0             1             0            0           0             1              0             1        3
=37        Barclays                          0               0                0             1             0            0           0             0              1             1        3
=37        British Airways                   0               0                0             1             0            0           0             1              0             1        3
=37        British Land Co.                  1               1                0             0             0            0           0             0              0             1        3
=37        Daily Mail & General              1               1                0             0             0            0           0             1              0             0        3
           Trust
=37        GKN                               1               1                0             0             0            0           0             0              1             0        3
=37        GlaxoSmithKline                   0               0                0             0             0            0           0             1              1             1        3
=37        ITV                               0               0                0             1             0            0           0             1              0             1        3
=37        Johnson Matthey                   0               0                0             1             0            0           0             1              0             1        3
=37        Marks & Spencer                   0               0                0             1             0            0           0             1              0             1        3
=37        Reuters Group                     0               0                0             1             0            0           0             1              1             0        3
=37        Scottish Power                    0               0                0             0             0            0           0             1              1             1        3
=37        Severn Trent                      0               0                0             1             0            0           0             1              0             1        3
=37        Smith & Nephew                    0               0                0             0             0            0           0             1              1             1        3
=37        Vodafone Group                    0               0                0             0             0            0           0             1              1             1        3
=37        Xstrata                           1               1                0             0             0            0           0             0              0             1        3
=58        Associated British                0               0                0             0             0            0           0             1              0             1        2
           Foods
=58        Aviva                             0               0                0             0             0            0           0             1              0             1        2
=58        Bradford & Bingley                0               1                0             0             0            0           0             0              0             1        2
=58        British American                  0               0                0             0             0            0           0             1              0             1        2
           Tobacco
=58        Bunzl                             0               0               0              0             0            0           0             0              1             1        2
=58        Compass Group                     0               0               0              0             0            0           0             1              0             1        2
=58        Hilton Group                      0               0               0              0             0            0           0             1              0             1        2
=58        ICI                               0               0               0              0             0            0           0             1              0             1        2
=58        Land Securities Group             0               0               0              0             0            0           0             1              1             0        2
=58        Man Group (EMG)                   0               0               0              0             0            0           0             1              0             1        2
=58        Old Mutual                        0               0               0              1             0            0           0             0              0             1        2
=58        Pearson                           0               0               0              0             0            0           0             1              0             1        2
=58        Royal & Sun Alliance              0               0               0              0             0            0           0             1              0             1        2
=58        Scottish & Newcastle              0               0               0              0             0            0           0             1              0             1        2
=58        Tomkins                           0               0               0              1             0            0           0             0              1             0        2
=58        United Utilities                  0               0               0              0             0            0           0             1              0             1        2
=58        Yell Group                        0               0               0              0             0            0           0             1              1             0        2
=75        Anglo American                    0               0               0              0             0            0           0             0              0             1        1
=75        BAA                               0               0               0              0             0            0           0             0              1             0        1
=75        BAE Systems                       0               0               0              0             0            0           0             1              0             0        1
=75        BSkyB                             0               0               0              0             0            0           0             1              0             0        1
=75        Cable & Wireless                  0               0               0              0             0            0           0             0              0             1        1
=75        Carnival                          0               0               0              0             0            0           0             0              0             1        1
=75        Diageo                            0               0               0              0             0            0           0             0              0             1        1
=75        Dixons Group                      0               0               0              1             0            0           0             0              0             0        1
=75        Emap                              0               0               0              0             0            0           0             1              0             0        1
=75        Foreign & Col. Invest.            0               0               0              0             0            0           0             0              0             1        1
=75        Hays                              0               0               0              0             0            0           0             0              0             1        1
=75        Reckitt Benckiser                 0               0               0              0             0            0           0             0              0             1        1
Alternate Text
                                                       Conformance

                                                                                             Code Validity

                                                                                                                                                                                      Link Quality
                                                                                                                                Access Keys

                                                                                                                                                                                                        Page Titles
                                                                                                                                                                       Alt Quality
                                                                                                               Scalability

                                                                                                                                              Skip Links
                      Company

                                                                                                                                                           Structure
 Position

                                                                                                                                                                                                                          Total
 =75                  Rexam                                     0                  1                     0                 0             0            0           0             0               0                0            1
 =75                  SABMiller                                 0                  0                     0                 0             0            0           0             0               0                1            1
 =75                  Sage Group                                0                  0                     0                 0             0            0           0             1               0                0            1
 =75                  Scottish & Southern                       0                  0                     0                 0             0            0           0             0               0                1            1
                      Energy
 =75                  Smiths Group                              0                  0                     0                 0             0            0           0             0               0                1            1
 =75                  Tesco                                     0                  0                     0                 0             0            0           0             1               0                0            1
 =93                  Allied Domecq                             0                  0                     0                 0             0            0           0             0               0                0            0
 =93                  Amvescap                                  0                  0                     0                 0             0            0           0             0               0                0            0
 =93                  BOC Group                                 0                  0                     0                 0             0            0           0             0               0                0            0
 =93                  Liberty International                     0                  0                     0                 0             0            0           0             0               0                0            0
 =93                  Morrison (WM)                             0                  0                     0                 0             0            0           0             0               0                0            0
 =93                  Safeway                                   0                  0                     0                 0             0            0           0             0               0                0            0
 =93                  Whitbread                                 0                  0                     0                 0             0            0           0             0               0                0            0
 =93                  Wolseley                                  0                  0                     0                 0             0            0           0             0               0                0            0
 Table 2: FTSE 100 web sites and their associated scores
 Note: The web sites tested for each company can be found in Appendix A starting on page 26.

 Result Analysis
 The most apparent aspect of the results is the considerable shake up of positioning. Of course
 this is partially attributable to the changes in the testing process, but that fact should not detract
 from the very real changes taking place.

 One clear example of a successful accessibility strategy is that of Intercontinental Hotels Group.
 With a marked rise from position 88 in our original report, to joint fourth place in this current
 research, Intercontinental Hotels Group have made a creditable move toward improving the
 online experience for all their shareholders.
 The move from failing to achieve any degree of conformance against the WCAG, to passing Level
 A, is a commendable improvement, as is the notable increase in many of the categories.
 The comparison table below provides ample indication of the work that Intercontinental Hotels
 Group have done and demonstrates a level of achievement that strongly indicates that the user
 experience is an important aspect of corporate business for this organisation.
                                                  Conformance

                                                                                         Code Validity

                                                                                                                                                                                         Link Quality
                                                                                                                               Access Keys

                                                                                                                                                                                                            Page Titles
                                                                                                                                                                        Alt Quality
                                                                                                             Scalability

                                                                                                                                              Skip Links
            Company

                                                                                                                                                           Structure
                                       Position

                                                                     Alt Text

                                                                                                                                                                                                                            Total
                                Year

Intercontinental 2003 88                                0                 0                      0                 0                 0        N/A                0             0                1                 0               1
Hotels Group 2004 =4                                    1                 1                      0                 0                 0         0                 1             1                1                 1               6
 Table 3: Intercontinental Hotels Group scores for 2003 and 2004.
What this meteoric ascendancy does not hint at is the need to ensure that standards, once
achieved, are maintained. Corporate sites are constantly updated; it isn’t enough to rest on
laurels and assume that once a site is accessible that it will stay that way.
However, for this research overall the accessibility trend of the FTSE 100 company web sites is
positive, with six of the categories tested showing an improvement, one displaying no change
and only two resulting in a drop.
With respect to standards compliance, certain web sites are showing promising improvements.
As our research continues for future reports, it will be interesting to note which, if any, of the FTSE
100 will be the first to attain Level AAA compliance and leapfrog the competition.
One of the more curious discoveries of the current research was the number of sites that
attempted to implement access keys, but failed to do so successfully. British American Tobacco,
Centrica, Hanson, Imperial Tobacco, Kingfisher, Next and Reed Elsevier all ran into problems with
their implementation.
In some cases the existing browser shortcut keys were overridden, causing significant problems
for people unable to use a mouse. In others the access keys were redundant, labelled inaccessibly
or non existent where information on the page leads the user to believe they should be present.
Irrespective of the future of access keys and the debate about their benefits, it is imperative that if
they are to be implemented that they be done so without adding to the difficulties faced by
users who might otherwise benefit from them.
Another category with a significant advancement in success was Page Titles. A unique,
explanatory page title is of benefit to all users, whether it is the first confirmation that the right
page has been reached (for screen reader users), a quick reminder of position for those with
cognitive restrictions or an easy way to identify the area of a site you are visiting.
Finally, the rise in sites that have adopted suitable page titles as best practice is encouraging,
again reinforcing the belief that the benefits of accessibility are reaching far into the corporate
world.
Conclusions
The conclusions that can be drawn from this current round of research are short, sharp and
significant. Both accessibility and usability are becoming more prominent within the digital remit
of the corporate sector. Awareness of the Disability Discrimination Act is driving the need for all
companies, not only those within the FTSE 100, to rise to the occasion. Time is perhaps running
out for those companies who persistently fail to heed the growing voice of the disabled
communities, but for those who place a high value on customer and shareholder opinion the
future is looking brighter.
It has been said before (and doubtless it will be said again) that for all the demonstrable effort
put in by those companies who have faired well in this research, there is still a long way to go
before true web accessibility can said to have been achieved.
The gap between technical designers and the people who will ultimately be using the sites they
create is vast. In the future the divide between the technology savvy and the average user will
continue to grow and unless web developers begin to understand the diversity of user
requirements, the range of user experience and the way that all people interact with web sites,
problems with accessibility and usability will continue to manifest and, ultimately, hinder user
performance.
The responsibility must also lie with the people who contract developers or are responsible for
in-house development teams. The concepts of accessibility and usability must be built in as
standard and to do that, all involved parties must be capable of implementing these concepts
with assurance.
All bar two of the categories tested still show that the majority of sites are failing to meet this
requirement. In doing so, companies are undermining the very CSR programmes put in place to
prevent the corporate sector being accused of monolithic indifference to the general public.
Nomensa has already turned toward the future and the hope and anticipation that, given the
upward swing illustrated in the results from our current research, the results in our 2005 report
will indicate considerable improvements.
We are already aware of certain FTSE companies who are in the process of upgrading their web
presence and who expect to make considerable progress within the coming months. At
Nomensa we hope this will become prevalent among those companies who are otherwise
considered to be the elite.
Glossary
Accessibility
        Ensuring that all information and services are available to all people, regardless of
        their experience, technology or ability.
Accessibility Strategy
        The plan enacted by an organisation to implement accessibility and usability
        wherever required.
Access Keys
        Keyboard shortcuts that allow the user to quickly return to the component of a web
        page that has the Access Key assigned to it.
Adaptive Technology
        A piece of software or hardware that facilitates computer usage for a disabled
        person.
Alternate Text
        The textual description that can be added to images on web pages.
Assistive Technology
        Please see Adaptive Technology.
Bobby
        An automated system that checks a web site against the WCAG. It is available online
        at bobby.watchfire.com.
Braille Display
        A device that is connected to a computer running a Screen Reader and which
        translates screen text into Braille on a refreshable display.
Browser Functions
        The built-in tools of a browser, such as Text Enlarge.
Disability Discrimination Act (DDA)
        1995 UK legislation governing the provision of goods, services and premises of
        public and private organisations, with reference to disabled people.
Document Type Definition (DTD)
        The declaration at the start of a web page’s code which states the language, such as
        HTML 4.01, used to write the page.
Fixed
        The term used to describe units of measurement that are given a set value. For
        example a column on a web page may be given a value of 300 pixels.
A fixed measurement will not expand or collapse if the browser window is resized.
Fluid Design
      The term used to describe a web site design that uses Relative rather than Fixed
      measurements.
Formal Specification
      The official blueprint of a technology, language or practice, defined by a recognised
      body of industry experts.
Link Phrase
      The word or phrase used to indicate a textual link.
Navigation Links
      The links that are common to every page throughout a site and which provide a
      means of navigating to different areas.
Page Anchor Links
      A link that leads to a point on the same page, rather than to a new page.
Page Titles
      A unique phrase that is assigned to each web page, providing an indication of the
      page content.
Relative
      A term used to describe units of measurement that are relative to the surrounding
      context. For example, a column on a web page may be given a width of 50% which
      means that it will take up half of the available space.
Retrofitting
      The act of adding accessibility to a previously designed web site.
Scalability
      The ability of the visual structure and text of a site to expand or collapse according
      to the user’s preference (such as the user’s choice of browser window size).
Screen Reader
      The software used by blind and vision impaired people to help access their
      computer.
Skip Links
      Please see Page Anchor Links.
Structure
      The way page content is laid out and organised.
Text Enlarge
      The Browser Function of Internet Explorer that allows the text on a web page to be
      resized according to user preference.
Usability
      Ensuring that the process of accessing information and services is as easy and
      efficient as possible.
Valid Code
      Code that accurately follows the grammatical and syntactical rules laid out in its
      Formal Specification.
World Wide Web Consortium (W3C)
      The organisation lead by World Wide Web founder Tim Berners-Lee, who oversee
      much of the technical progress made within the web development field.
Web Accessibility Initiative (WAI)
      A working group set up by the W3C to provide guidelines and support for
      accessible web design.
Web Content Accessibility Guidelines (WCAG)
      Guidelines laid out by the WAI Working Group to govern accessible web design.
Appendices
Appendix A: Company web site addresses
Company                  Web site address                   Company                  Web site address
3I Group                 www.3igroup.com                    ITV                      www.itv.com
Abbey National           www.abbeynational.com              Johnson Matthey          www.matthey.com
Alliance and Leicester   www.alliance-leicester-            Kingfisher               www.kingfisher.co.uk
                         group.co.uk
Alliance Unichem         www.alliance-unichem.com           Land Securities Group    www.landsecurities.com
Allied Domecq            www.allieddomecqplc.com            Legal & General          www.LandG.com
Amersham                 www.amersham.com                   Liberty International    www.liberty-
                                                                                     international.co.uk
Amvescap                 www.amvescap.com                   Lloyds TSB               www.lloydstsb.co.uk
Anglo American           www.angloamerican.co.uk            Man Group (EMG)          www.mangroupplc.com
Associated British       www.abfoods.com                    Marks and Spencer        www.marks-and-spencer.com
Foods
AstraZeneca              www.astrazeneca.com                MMO2                     www.mmo2.com
Aviva                    www.aviva.com                      Morrison (WM)            www.morereasons.com
BAA                      www.baa.co.uk                      National Grid            www.ngtgroup.com
BAE Systems              www.baesystems.com                 Next                     www.next.co.uk
Barclays                 www.barclays.com                   Northern Rock            www.northernrock.co.uk
BG Group                 www.bg-group.com                   Old Mutual               www.oldmutual.co.uk
BHP Billiton             www.bhpbilliton.com                Pearson                  www.pearson.com
BOC Group                www.boc.com                        Prudential               www.prudential.co.uk
Boots Group              www.boots-plc.com                  Reckitt Benckiser        www.reckitt.com
BP                       www.bp.com                         Reed Elsevier            www.reed-elsevier.com
Bradford and Bingley     www.bbg.co.uk                      Rentokil Initial         www.rentokil-initial.com
British Airways          www.britishairways.com             Reuters Group            www.reuters.com
British-American         www.bat.com                        Rexam                    www.rexam.com
Tobacco
British Land Co          www.britishland.co.uk              Rio Tinto                www.riotinto.com
BSkyB                    www.sky.co.uk                      Rolls Royce              www.rolls-royce.com
BT Group                 www.bt.com                         Royal and Sun            www.royalsunalliance.com
                                                            Alliance
Bunzl                    www.bunzl.com                      Royal Bank of            www.rbs.co.uk
                                                            Scotland
Cable and Wireless       www.cw.com                         SABMiller                www.sabplc.com
Cadbury Schweppes        www.cadburyschweppes.com           Safeway                  www.safeway.co.uk
           3
Carnival                 www.carnival.com                   Sage Group               www.sage.com
Centrica                 www.centrica.co.uk                 Sainsbury (J)            www.jsainsbury.com
Compass Group            www.compass-group.com              Schroders                www.schroders.com

3
 Carnival’s corporate site (www.carnivalcorp.com) was unavailable to Nomensa at the time of the testing, so
www.carnival.com was tested instead.
Company             Web site address             Company                 Web site address
Daily Mail and GT   www.dmgt.co.uk               Scottish and            www.scottish-newcastle.com
                                                 Newcastle
Diageo              www.diageo.com               Scottish & Southern     www.scottish-southern.co.uk
                                                 Energy
Dixons Group        www.dixons-group-plc.co.uk   Scottish Power          www.scottishpower.com
Emap                www.emap.com                 Severn Trent            www.severn-trent.com
Exel                www.exel.com                 Shell                   www.shell.com
Foreign and Col.    www.fandc.co.uk              Shire Pharmaceuticals   www.shire.com
Investments                                      Group
Friends Provident   www.friendsprovident.co.uk   Smith and Nephew        www.smith-nephew.com
Gallaher Group      www.gallaher-group.com       Smiths Group            www.smiths-group.com
GKN                 www.gknplc.com               Standard Chartered      www.standardchartered.com
GlaxoSmithKline     www.gsk.com                  Tesco                   www.tesco.com
GUS                 www.gusplc.co.uk             Tomkins                 www.tomkins.co.uk
Hanson              www.hansonplc.com            Unilever                www.unilever.com
Hays                www.hays-plc.com             United Utilities        www.unitedutilities.com
HBOS                www.hbosplc.com              Vodafone Group          www.vodafone.com
Hilton Group        www.hiltongroup.com          Whitbread               www.whitbread.co.uk
HSBC                www.hsbcgroup.com            Wolseley                www.wolseley.com
ICI                 www.ici.com                  WPP Group               www.wpp.com
Imperial Tobacco    www.imperial-tobacco.com     Xstrata                 www.xstrata.co.uk
Intercontinental    www.ihgplc.com               Yell Group              www.yell.com
Hotels

Table 4: FTSE 100 Companies and their associated web site addresses
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