Accessibility Policy and Accessibility Plan

February 7th, 2017

Haines, Jones & Cadbury Corporation (“HJC”) Accessibility Policy and Accessibility Plan – Ontario

Purpose

To establish policies, practices and procedures to ensure HJC is accessible to customers and to others in Ontario in accordance with the Accessibility for Ontarians with Disabilities Act, 2005 (the “Act”) including Ontario Regulation 191/11 Integrated Accessibility Standards.

Statement of Organizational Commitment

HJC is committed to meeting the accessibility needs of persons with disabilities in a timely manner, and will do so by preventing and removing barriers to accessibility and meeting accessibility requirements under the Act. HJC’s core values complement its commitment to treat all people in a way that allows them to maintain their dignity and independence. We believe in integration and equal opportunity.

Application

This policy applies to all Ontario teammates who deal with the public, other organizations, or third parties on or off HJC premises and applies to those teammates who participate in developing HJC’s policies, practices and procedures governing the provision of goods and services to the public.

Principles and Practices

Training

HJC will provide training, as soon as practicable, on the requirements of the accessibility standards of the Act and of the Human Rights Code as it pertains to persons with disabilities to:

  • all teammates;
  • all persons who participate in developing HJC’s policies; and
  • all other persons who provide goods, services or facilities on behalf of

The training on the requirements of the accessibility standards and on the Human Rights Code referred will: be appropriate to the duties of the teammates and other persons; be provided on an ongoing basis; be recorded (including the dates on which the training is provided and the number of individuals to whom it is provided); and will occur prior to January 1, 2018.

Information and Communications

Feedback

HJC will develop processes for receiving and responding to feedback and will ensure that the processes are accessible to persons with disabilities by providing or arranging for the provision of accessible formats and communication supports, upon request.

HJC will notify the public about the availability of accessible formats and communication supports.

HJC will implement the feedback process by January 1, 2018.

 

Accessible Formats and Communication Supports

HJC will, upon request, provide or 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 at a cost that is no more than the regular cost charged to other people.

HJC will consult with the person making the request in determining the suitability of an accessible format or communication support.

HJC will notify the public about the availability of accessible formats and communication supports.

HJC will implement this process by January 1, 2018.

 

Accessible Websites and Web Content

HJC will ensure its websites and web content conform with the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0 Level A by January 1, 2014.

HJC will ensure its websites and web content conform with the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0 Level AA by January 1, 2021.

 

Employment Standards

Recruitment

HJC will notify its teammates and the public about the availability of accommodation for applicants with disabilities in its recruitment processes.

During the recruitment process, HJC will notify job applicants when they are selected to participate 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, HJC 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

HJC will, when making offers of employment, notify the successful applicant of its policies for accommodating teammates with disabilities.

 

Informing Teammates of Supports

HJC will inform its teammates of its policies used to support its teammates with disabilities, including, but not limited to, policies on the provision of job accommodations that take into account a teammate’s accessibility needs due to disability. HJC will provide the required information to new teammates as soon as practicable after they begin their employment. HJC will provide updated information to its teammates whenever there is a change to existing policies on the provision of job accommodations that take into account a teammate’s accessibility needs due to disability.

 

Accessible Formats and Communication Supports for Teammates

Where a teammate with a disability so requests, HJC will consult with the teammate to provide or arrange for the provision of accessible formats and communication supports for information that is needed in order to perform the teammate’s job and information that is generally available to teammates in the workplace. HJC will consult with the teammate making the request in determining the suitability of an accessible format or communication support.

 

Documented Individual Accommodation Plans

HJC will develop and have in place a written process for the development of documented individual accommodation plans for teammates with disabilities. The process for the development of documented individual accommodation plans will include the following elements:

  1. The manner in which a teammate requesting accommodation can participate in the development of the individual accommodation
  2. The means by which the teammate is assessed on an individual
  3. The manner in which HJC can request an evaluation by an outside medical or other expert, at HJC’s expense, to assist HJC in determining if accommodation can be achieved and, if so, how accommodation can be
  4. The manner in which the teammate can request the participation of a representative from the workplace in the development of the accommodation
  5. The steps taken to protect the privacy of the teammate’s personal
  6. The frequency with which the individual accommodation plan will be reviewed and updated and the manner in which it will be
  7. If an individual accommodation plan is denied, the reasons for the denial will be provided to the
  8. The means of providing the individual accommodation plan in a format that takes into account the teammate’s accessibility needs due to

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

Return to work process

HJC will develop and have in place a return to work process for its teammates who have been absent from work due to a disability and require disability-related accommodations in order to return to work; and will document the process.

The return to work process will outline the steps HJC will take to facilitate the return to work of teammates who were absent due to disability, and, will use documented individual accommodation plans as part of the process.

 

Performance management

HJC will take into account the accessibility needs of teammates with disabilities, as well as individual accommodation plans, when using its performance management process in respect of teammates with disabilities. For the purposes of this policy, “performance management” means activities related to assessing and improving teammate performance, productivity and effectiveness, with the goal of facilitating teammate success.

 

Career Development and Advancement

When providing career development and advancement, HJC will take into account the accessibility needs of its teammates with disabilities as well as any individual accommodation plans. For the purposes of this policy, “career development and advancement” means providing additional responsibilities within a teammate’s current position and the movement of a teammate from one job to another in the organization (that may be higher in pay, provide greater responsibility or be at a higher level in the organization or any combination of them) and, for both additional responsibilities and teammate movement, is usually based on merit or seniority, or a combination of them.

 

Redeployment

HJC will take into account the accessibility needs of its teammates with disabilities, as well as individual accommodation plans, when redeploying teammates with disabilities. For the purposes of this policy, “redeployment” means the reassignment of teammates to other departments or jobs within the organization as an alternative to layoff, when a particular job or department has been eliminated by the organization.

The target date for all Employment Standards outlined in this portion of this policy is January 1, 2018.