Integrated Accessibility Standards Policy

Purpose

The purpose of this Policy is to address the accessibility requirements of Ontario Regulation 191/11, Integrated Accessibility Standards under the Accessibility for Ontarians with Disabilities Act, 2005 (“AODA”). 

Scope

This Policy applies to any Ontario employees of the Company as well as volunteers, agents, contractors, third parties or any other individuals who interact with the public or other third parties located in Ontario, who represent or act on behalf of the Company in any manner. 

Statement of Commitment

The Company is committed to treating people in a way that allows them to maintain their dignity and independence. We are committed to equal opportunity and to meeting the needs of persons with Disabilities in a timely manner, and will do so by preventing and removing Barriers to accessibility where possible and meeting accessibility requirements under the AODA. In support of this Policy, corresponding procedures and practices will be set out to support the Policy and may be amended from time to time. 

Administration

Procedures and Practices may be amended or added to the Policy as necessary and appropriate in order to ensure that it is current and applicable. 

Definitions

  • Accessible Formats, formats that are an alternative to standard print and are accessible to people with Disabilities. Accessible formats may include larger print, Braille, and audio electronic formats such as DVD’s and CD’s.
  • Barrier all mean anything that prevents a person with a Disability from fully participating in all aspects of society because of the Disability. Barriers may include a physical, architectural and attitudinal barrier as well as, an information or communication barrier, technological barriers, a policy, procedure or a practice. 
  • Communications Supports supports that individuals with Disabilities may need to access information. Some examples include plain language formats, sign language, as well as reading out loud captioning, or using written notes to communicate.
  • Disability shall be defined as found in the Ontario Human Rights Code (Part II, Section 10.(1) of the OHRC):
    • any degree of physical disability, infirmity, malformation or disfigurement that is caused by bodily injury, birth defect or illness and, without limiting the generality of the foregoing, includes diabetes mellitus, epilepsy, a brain injury, any degree of paralysis, amputation, lack of physical co-ordination, blindness or visual impediment, deafness or hearing impediment, muteness or speech impediment, or physical reliance on a guide dog or other animal or on a wheelchair or other remedial appliance or device,
    • a condition of mental impairment or a developmental disability,
    • a learning disability, or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language,
    • a mental disorder, or
    • an injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997 (“handicap”).
  • Policy means this Integrated Accessibility Standards Policy.
  • Procedures shall mean how the Company will go about implementing their Policy.
  • Practices shall mean what the Company does on a day to day basis.
  • WCAG refers to the World Wide Web Consortium Content Accessibility Guidelines.

Accessibility Plan

The Company will develop, maintain and document an Accessibility Plan outlining the Company’s strategy to prevent and remove Barriers from its workplace and to improve opportunities for persons with Disabilities.

The Accessibility Plan will be reviewed and updated at least once every five (5) years, and will be made available to any person who requests one. The Company will also provide a copy of the Accessibility Plan in an Accessible Format upon request. 

Training Employees and Volunteers

The Company will ensure that training is provided on the requirements of the accessibility standards referred to in the Regulation and continue to provide training on the Human Rights Code as it pertains to persons with Disabilities, to: 

  • all its employees and volunteers;
  • all persons who participate in developing the Company’s policies; and,
  • all other persons who provide goods, services or facilities on behalf of the Company

The training will be appropriate to the duties of the employees, volunteers and other persons. Employees will be trained when changes are made to the Policy. New employees will be trained during the orientation process, or when practicable. The Company will keep a record of the training it provides. 

Information and Communication Standards

Feedback

The Company will continue to ensure that its process for receiving and responding to feedback is accessible to persons with Disabilities by providing, or arranging for the provision of, Accessible Formats and Communications Supports, upon request. 

Accessible Format and Communication Supports

Upon request, the Company will provide, or will arrange for the provision of Accessible Formats and Communication Supports for persons with Disabilities in a timely manner that takes into account the person’s accessibility needs due to Disability. The Company will consult with the person making the request in determining the suitability of an Accessible Format or Communication Support. The Company will also notify the public about the availability of Accessible Formats and Communication Supports by posting this Policy on its external website. 

Accessible Websites and Web Content

The Company will ensure that, as of January 1, 2014, new internet websites and web content on these sites will confirm to the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0, at Level A except where this is impracticable. 

Employment Standards

Recruitment

The Company will notify its employees and the public about the availability of accommodation for applicants with Disabilities in its recruitment process. 

Recruitment, Assessment or Selection Process

The Company will notify job applicants, when they are individually selected to participate further in an assessment or selection process that accommodations are available upon request in relation to the materials or processes to be used. If a selected applicant requests an accommodation, the Company will consult with the applicant and provide, or arrange for the provision of, a suitable accommodation in a manner that takes into account the applicant’s accessibility needs due to Disability. 

Notice to Successful Applicants

When making offers of employment, the Company will notify the successful applicant of its policies for accommodating employees with Disabilities. 

Informing Employees of Supports

The Company will continue to inform its employees of its policies (and any updates to those policies) used to support employees with Disabilities, including policies on the provision of job accommodations that take into account an employee’s accessibility needs due to Disability. This information will be provided to new employees as soon as practicable after commencing employment. 

Accessible Formats and Communication Supports for Employees

Upon the request of an employee with a Disability, the Company will consult with the employee to provide, or arrange for the provision of, Accessible Formats and Communication Supports for information that is needed to perform his/her job, and information that is generally available to other employees. In determining the suitability of an Accessible Format or Communication Support, the Company will consult with the employee making the request. 

Workplace Emergency Response Information

The Company will provide individualized workplace emergency response information to employees who have a Disability, if the Disability is such that the individualized information is necessary, and if the Company is aware of the need for accommodation due to the employee’s Disability. The Company will provide this information as soon as practicable after becoming aware of the need for accommodation.

Where the employee requires assistance, the Company will, with the consent of the employee, provide the workplace emergency response information to the person designated by the Company to provide assistance to the employee.

The Company will review the individualized workplace emergency response information when the employee moves to a different location in the organization, when the employee’s overall accommodations needs, or plans are reviewed. 

Documented Individuals Accommodation Plans

The Company will maintain a written process for the development of documented individual accommodation plans for employees with Disabilities where required. If requested, information regarding Accessible Formats and Communications Supports provided will also be included in individual accommodation plans.
In addition, the plans may include individualized workplace emergency response information. 

Return to Work Process

The Company maintains a documented return to work process for its employees who have been absent from work due to a Disability and who require Disability-related accommodations in order to return to work. 

Performance Management

In administering performance appraisal processes in respect of employees with Disabilities, the Company will take into account the accessibility needs of employees with Disabilities as well as individual accommodation plans, where required. 

Career Development

Where the Company provides career development and advancement to its employees, the Company will take into account the accessibility needs of employees with Disabilities as well as any individual accommodation plans, where required. 

Redeployment

Where the Company has in place a redeployment process, the Company will take into account the accessibility needs of employees with Disabilities as well as any individual accommodation plans, where required.

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