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ACCESSIBLE SERVICES AND ACCESSIBILITY POLICY AND PLAN

STATEMENT OF COMMITMENT TO ACCESSIBILITY (AODA)

Last updated: December 2023

Equiton and its associate and affiliated companies (the “Company” or “Equiton”) is committed to providing an accessible environment for all clients, employees, job applicants, suppliers, and visitors who may enter our premises, access our information, or use our services. As an organization, we respect and comply with the requirements of the Accessibility for Ontarians with Disabilities Act, 2005, and its associated regulations. We strive to provide an accessible and welcoming environment for everyone by identifying and removing barriers in our workplace and ensuring that new barriers are not created. The company ensures that persons with disabilities are provided with equal opportunities. We are committed to meeting the needs of individuals with disabilities in a timely and integrative manner that respects their dignity and independence.


Providing an accessible environment is a shared effort, and we work with the necessary parties to make accessibility for all a reality. For more detailed information on our accessibility policies, plans, and training, please contact Equiton Human Resources at EquitonHR@equiton.com.

A. ACCESSIBLE CLIENT SERVICE POLICY

1. Assistive Devices
People with disabilities may use their personal assistive devices when accessing our goods, services or facilities.

In cases where the assistive device presents a significant and unavoidable health or safety concern or may not be permitted for other reasons, other measures will be used to ensure the person with a disability can access our goods, services or facilities.

We will ensure that our staff are trained and familiar with various assistive devices we have on site or that we provide that may be used by clients with disabilities while accessing our goods, services or facilities.

2. Communication
We will communicate with people with disabilities in ways that take into account their disability. We will work with the person with a disability to determine what method of communication works for them.

3. Service Animals & Support Person
We welcome people with disabilities and their service animals. Service animals are allowed on the part of our premises which is open to the public, specifically, our client services areas. When we cannot easily identify whether an animal is a service animal, our staff may ask the person to provide documentation from a regulated health professional that confirms the person needs the service animal for reasons relating to their disability.

If service animals are prohibited by another law, we will ensure the customer with disabilities can access our goods, services or facilities by explaining why the animal is excluded and discussing with the customer another way of providing goods, services or facilities.

A person with a disability who is accompanied by a support person will be allowed to have that person accompany them on our premises. In certain cases, we might require a person with a disability to be accompanied by a support person for the health or safety reasons of the person with a disability or others on the premises.

4. Notice of Temporary Disruption
In the event of a planned or unexpected disruption to services or facilities for clients with disabilities, we will notify clients promptly. This clearly posted notice will include information about the reason for the disruption, its anticipated length of time, and a description of alternative facilities or services, if available.

5. Training
The Company will provide accessible customer service training to all employees and volunteers, any person involved in developing our policies, and any person who provides goods, services, or facilities to clients on the Company’s behalf.

The training will encompass:

• the purpose of the Accessibility for Ontarians with Disabilities Act, 2005, and the requirements of the customer service standard;
• the Company’s policies related to the customer service standard;
• how to interact and communicate with people with various types of disabilities;
• how to interact with people with disabilities who use an assistive device or require the assistance of a service animal or a support person;
• how to use the equipment or devices available on-site or otherwise that may help with providing goods, services, or facilities to people with disabilities; and
• what to do if a person with a disability is having difficulty accessing the Company’s goods, services, or facilities.
Staff will be trained on accessible customer service as part of their training when they are first hired and again if changes are made to our accessible customer service policy.

6. Feedback Process
We welcome feedback.

Clients who wish to provide feedback on the way the Company provides goods, services or facilities to people with disabilities can provide feedback in the following way(s):
• In-person at our Head Office, Human Resources
• By telephone by calling: 905-635-1381
• By email to: EquitonHR@equiton.com
• By mail to: Equiton Partners Inc, 1111 International Blvd, Suite 500,
Burlington ON L7L 6W1

The Company will make sure our feedback process is accessible to people with disabilities by providing or arranging for accessible formats and communication supports, on request. All feedback received will be reviewed within a reasonable time period and the Company will take all appropriate steps to address any issues raised. All complaints will be processed in accordance with the Company’s complaints process.

7. Documents
The Company will notify the public that documents related to accessible customer service are available upon request by posting a notice in the following location: www.equiton.com

The Company will provide this document in an accessible format or with communication support, on request. We will consult with the person making the request to determine the suitability of the format or communication support. We will provide the accessible format in a timely manner and at no additional cost.

Any policies of the Company that do not respect and promote the principles of dignity, independence, integration and equal opportunity for people with disabilities will be modified or removed.

B. ACCESSIBILITY POLICY AND MULTI-YEAR ACCESSIBILITY PLAN

1. Commitment to Accessibility
Equiton (the “Company”) is committed to ensuring equal access and participation for people with disabilities. We are committed to treating people with disabilities in a way that allows them to maintain their dignity and independence.
We believe in integration, and we are committed to meeting the needs of people with disabilities in a timely manner. We will do so by removing and preventing barriers to accessibility and by meeting our accessibility requirements under Ontario’s accessibility laws.

2. Application and Scope
This Policy and Multi-Year Accessibility Plan are made pursuant to the requirements of the Accessibility for Ontarians with Disabilities Act, 2005 (“AODA”) and the Integrated Accessibility Standards Regulation (“IAS Regulation”) of the AODA and address how the Company will achieve accessibility. This Policy and Multi-Year Accessibility Plan will be reviewed and updated as necessary at least every five years and posted on our website.

For purpose of this Policy and Plan, “disability” is defined as follows:

(i) 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,
(ii) a condition of mental impairment or a developmental disability,
(iii) a learning disability, or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language,
(iv) a mental disorder, or
(v) an injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997.

3. Self-Service Kiosks
Equiton shall incorporate accessibility features when designing, procuring or acquiring self-service kiosks. “Kiosk” means an interactive electronic terminal, including a point-of-sale device, intended for public use that allows users to access one or more services or products or both.

4. Training
Equiton provides training to all its employees, volunteers, persons who participate in developing its policies, and all other persons who provide goods, services, or facilities on behalf of Equiton.

The training shall be:

(a) on the requirements of the IAS Regulation and the Human Rights Code as it relates to persons with disabilities;
(b) appropriate to the duties of the employees, volunteers and other persons;
(c) provided as soon as practicable, on an ongoing basis and as necessary to comply with all statutory requirements.
Equiton shall keep a record of the training provided, including the dates on which the training is provided and the number of individuals to whom it was provided.

5. Information and Communications Standards
Accessible Formats and Communication Supports
Upon request, and in accordance with the compliance schedule set out in the IAS Regulation, Equiton will provide or arrange for the provision of accessible formats and communication supports for persons with disabilities in a timely manner and at a cost that is not greater than the cost charged to other persons, if any. Equiton will consult with the person making the request to determine the suitability of an accessible format or communication support and notify the public about the availability of these formats and supports.

Feedback
In accordance with the requirements of the IAS Regulation, Equiton ensures that its feedback processes are accessible to persons with disabilities by providing or arranging for the provision of accessible formats and communication supports, upon request. We will notify the public of the availability of accessible formats and communication supports including by posting this information online.
Further information about our feedback process is available at the end of this Policy.

Accessible Websites and Web Content
In accordance with the compliance requirements set out in the IAS Regulation, and subject to applicable exceptions, Equiton will ensure that its website and the applicable web content will conform with the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG 2.0) Level AA (other than criteria 1.2.4 (live captions) and 1.2.5 (pre-recorded audio descriptions)).

Emergency Information
Where Equiton prepares emergency procedures, plans or public safety information and makes such information available to the public, it shall provide the information in an accessible format or with appropriate communication supports, as soon as practicable, upon request.

6. Employment Standards
Equiton is committed to ensuring that its employment practices are in compliance with the AODA, IAS Regulation, and the Ontario Human Rights Code.

Recruitment
Accommodations for applicants (including existing employees) with disabilities are available in Equiton’s recruitment processes.

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

Equiton shall notify successful applicants of Equiton policies for accommodating employees with disabilities when making offers of employment.

Equiton shall also notify employees of its policies that support employees with disabilities including, but not limited to, policies on the provision of job accommodations that take into account an employee’s accessibility needs due to a disability.

Accessible Formats & Communication Supports for Employees
Where an employee with a disability requests it, Equiton will consult with the employee to provide or arrange for the provision of accessible formats and communication supports for information that is (a) needed in order to perform the employee’s job and (b) generally available to employees in the workplace.

Documented Individual Accommodation Plans & Return-to-Work Process
In accordance with the requirements set out in the IAS Regulation, Equiton shall continue to develop a process for the development of individual accommodation plans for employees with disabilities. Our processes will include the following elements:

• the manner in which an employee requesting accommodation can participate in the development of the individual accommodation plan;
• the means by which the employee is assessed on an individual basis;
• the manner in which Equiton may request an evaluation by an outside medical professional or other experts to assist with determining if an accommodation can be achieved and, if so, how to achieve accommodation
• the manner in which the employee can request the participation of a representative from the workplace in the accommodation process;
• the steps are taken to protect the privacy of the employee’s personal information;
• the frequency with which the individual accommodation plan will be reviewed and updated and the manner in which it will be done;
• if an individual accommodation plan is denied, the manner in which the reasons for the denial are to be provided to the employee;
• the means of providing the accommodation plan in a format that takes into account the employee’s accessibility needs.

Individual accommodation plans shall, if requested, include: any information regarding accessible formats and communication supports provided; individualized workplace emergency response information; and identify any other accommodation that is to be provided.

Equiton has in place documented return-to-work processes for employees who have been absent from work due to a disability and require a disability-related accommodation in order to return to work. Building on that foundation, we will ensure that those processes clearly outline the steps that Equiton will take to facilitate the return-to-work process amongst other requirements that facilitate that process. Our return-to-work processes will include individualized accommodation plans.

Recruitment, Performance Management, Career Development and Advancement, Redeployment
Upon request, Equiton provides candidates with reasonable accommodations during the interview process and is committed to hiring decisions that are unbiased and based on qualifications and experience.

Equiton shall take into account the accessibility needs and/or individual accommodation plans of employees when using performance management processes, providing career development and advancement, and using redeployment.

Workplace Emergency Response Information
Equiton provides individualized workplace emergency response information to employees who have a disability if the disability is such that individualized information is necessary and the employer is aware of the need for accommodation. Equiton provides this information as soon as practicable after becoming aware of the need for accommodation.

If an employee who receives individualized workplace emergency response information requires assistance and provided that the employee’s consent is obtained, Equiton will provide the workplace emergency response information to the person designated by the employer to provide assistance to the employee.

Equiton reviews the individualized workplace emergency response information in the following circumstances: when the employee moves to a different location in the organization when overall accommodation needs or plans are reviewed, and when it reviews its general emergency response policies.

Inability to Accommodate
Equiton provides workplace accommodation up to the point of undue hardship. Undue hardship may occur where it is established that no forms of reasonable accommodation exist, or where the creation of accommodation would create a health and safety hazard or cause unreasonable costs for the company.

Where accommodation is found to cause undue hardship on the organization, the company will work to find a fair and equitable compromise that meets the needs of the employee and the company to the greatest extent possible.

7. Accessibility Standards for our Facilities
Equiton is committed to designing our facilities free from barriers and accessible to all persons we serve. Equiton will comply with the Design of Public Spaces Standards with respect to public spaces that are newly constructed or redeveloped in accordance with the requirements of the IAS Regulation.

8. References
• Accessible Customer Service Policy
• Accessibility for Ontarians with Disabilities Act, 2005
• Regulation 191/11 made under the Accessibility for Ontarians with Disabilities Act, 2005 (Integrated Accessibility Standards)

9. Copies
Upon request, all of our policies can be made available in an accessible format, and we can provide or arrange to provide communication support as necessary.

10. Feedback and Questions
If you have any questions about this Policy or our accessibility initiatives, please let us know. Feedback on this Policy and the Company’s accessibility measures is welcome. Feedback can be provided through various means and in various forms. If you have questions, concerns, or comments, please contact Human Resources, at EquitonHR@equiton.com.
All feedback received will be reviewed within a reasonable time period and Equiton will take all appropriate steps to address any issues raised. All complaints will be processed in accordance with Equiton’s complaints process.

POLICY REVIEW
The executive owner of the Accessibility Services & Accessibility Plan and Policy will conduct an annual review of the policy. This is a control measure taken on a continuous basis to ensure the policy is accurate, relevant and applied.