This intermediate step would address the concerns of business and other respondents about the cost of federal litigation by providing a quicker and less costly alternative to court proceedings in circumstances where parties are unable to reach agreement themselves in a conciliation process. Reform 28: Subject to the inclusion of irrelevant criminal record and freedom of thought, conscience and religion as a protected attribute, the ILO complaints jurisdiction of the Commission should be repealed. (iv) Pillar 4: Improving the practical operation of laws Reform 30: The test for direct discrimination should be simplified by removing the ‘comparator test’. Major Reform 1: Building a preventative culture Major Reform 4: Improving the practical operation of laws Reform 29: All permanent exemptions under federal discrimination law should be reviewed on a periodic basis. Reform 31: The reasonable adjustments assessment currently in the DDA, should be clarified as a standalone obligation. The concept of reasonable adjustments should be considered beyond the DDA. Major Reform 2: Modernising the regulatory framework Reform 32: Amend the definition of indirect discrimination to remove the requirement that the aggrieved person ‘does not comply or is not able to comply’. Major Reform 3: Enhancing access to justice Reform 33: Any conduct that amounts to victimisation should form the basis of a civil action for unlawful discrimination, across all federal discrimination Acts. Reform 34: The term ‘special measure’ should be clarified so that it aligns with the understanding of this measure under international law. Recommended actions under Pillar 4 are: Reform 24: Volunteers and interns should be protected across all discrimination laws. Reform 25: Extend protections against family and carer responsibility discrimination under the SDA to, indirect as well as direct, discrimination and all areas of public life. Reform 26: The right to freedom of thought, conscience and religion should be considered as a protected attribute. There is a current review of this being conducted by the Australian Law Reform Commission. Reform 27: Discrimination on the basis of irrelevant criminal record should be included as a protected attribute in the ‘unlawful discrimination’ jurisdiction of the Commission. 88 Reform 35: A new provision should be added across all federal discrimination laws which identifies that discrimination may occur on the basis of a particular protected attribute ‘or a particular combination of 2 or more protected attributes’. Reform 36: Remove the obligation to notify individuals who are the subject of adverse allegations but who are not named respondents, in the AHRC Act. Reform 37: Amend the AHRC Act as a matter of priority to ensure the Commission is in compliance with the Paris Principles. Reform 38: Once the reforms to federal discrimination law have been made, there should be a review of reforms after 5 years, to consider their effectiveness. FREE & EQUAL: Revitalising Australia’s Commitment to Human Rights