Disability Discrimination in Employment: Three Countries Comparison

Abstract

Firms to date regard their employees as one of the most critical components for their business success. Among them, one group of employees particularly raises our attentions and thoughts. Disabled employees are devoting themselves to make greater business achievements, as well as creating better lives. However, disabled employees to date are still differentiated to be neglected, despised, or even repudiated in many businesses. In this regard, it is important to understand the status quo of governmental actions in protecting employment of handicapped. So, this article employs a structured literature review with a disaggregated analysis of disability protection acts in three countries (i.e., United States, United Kingdom, and China) towards the issue of disability discrimination in employment. Based on the analysis, we suggest that either national legislation or corporate regulation needs to dedicate on protecting disabilities through a growing law-system. Simultaneously, they can also work on protecting disabilities from an active way by advancing their abilities of self-security.

Keywords: Disability Discrimination, Convention on the Rights of Persons with Disabilities (CRPD), Americans with Disabilities Act (ADA), Disability Discrimination Act (DDA), Hong Kong Equal Opportunities Commission (HKEOC)