AODA Multi-Year Plan

Authorization: People & Culture Department

Effective Date: March 1, 2018

Revision Date: November 13, 2023

Initiative

Commitment

Action

Status

1.1 Establishment of Accessibility Policies

• Develop, implement, and maintain policies governing how the organization achieves or will achieve accessibility through meeting its requirements referred to in the IASR.

• Communicate compliance requirements to all employees.
• Draft and distribute an Integrated Standard Accessibility policy document.

Complete

• Include a statement of organizational commitment to meeting accessibility needs.

• Draft a written commitment statement and include it in MYAP and policy.

Complete

• Prepare a written document describing policies and make it publicly available in an accessible format.

• Draft the written accessibility policy document(s). 
• Coordinate with Communications and IT/ Marketing to post the required document(s) on our website in an accessible format.

Complete

1.2 Accessibility Plans

• Establish, implement, maintain, and document a Multi- Accessibility Plan (MYAP); post online in an accessible format, and update it every five years.

• Draft a MYAP and post it to the website.
• Complete review at least every five years.
• Amend MYAP and repost on our website as necessary.
• Provide in an accessible format upon request.

Ongoing 

1.3 Training

• Provide training on the requirements of the accessibility standards referred to in IASR and on the Human Rights Code as they pertain to persons with disabilities to employees, volunteers, persons who participate in developing the organization’s policies, persons who provide goods, services or facilities on behalf of the organization.

• Create online training materials and programs. 
• Provide training to all current employees and new employees, etc. as part of orientation.
• Record future changes in policy and update training accordingly.

Ongoing

• Training must be appropriate to the duties of the employee, etc.
• Employees, etc. must be trained as soon as practicable. 
• Provide training in respect of any changes to the policies on an ongoing basis.

• Reviewing training and adjusting as appropriate for various levels and duties of employees.
• Adjust training and re-train each time changes to policies take place.

Ongoing

• Keep a record of training, including dates and number of those trained.

• Create and maintain an online record of training completion.

Ongoing

Initiative

Commitment 

Action

Status

2.1 Feedback

• Every obligated organization that has processes for receiving and responding to feedback shall ensure that the processes are accessible to persons with disabilities by providing or arranging for accessible formats and communications supports, upon request.

• Respond to email inquiries or telephone calls from employees, customers, and other stakeholders as required. 
• Provide or arrange for accessible formats for giving and receiving feedback upon receiving a request. 
• Consult and utilize alternative technologies and/or outside consultants as necessary.

Complete 

2.2 Accessible Formats & Communication Supports

• Upon request, provide or arrange for accessible formats and communication supports for persons with disabilities.
• Do so in consultation with the requesting person, in a timely manner, considering the person’s accessibility needs, at a cost no greater than the cost charged to other persons.
• Notify the public about the availability of accessible formats and communication supports.

• Respond to email inquiries or telephone calls from employees, customers, and other stakeholders as required.
• Provide or arrange for accessible formats for giving and receiving feedback upon receiving a request.
• Consult and utilize alternative technologies and/or outside consultants as necessary.
• Include notification wherever accessibility procedures are described.

Complete 

2.3 Accessible Websites & Web Content

• Ensure that new web content conforms to WCAG 2.0 Level A.

• Identify all new content as of 2023. 
• Re-write all new content to comply with WCAG 2.0 Level A.

Complete

• All web content must conform to WCAG 2.0 Level AA, subject to exceptions.

• Assess current compliance status.
• Re-write all new content not subject to exceptions to comply with WCAG 2.0 Level AA. 
• Continue to update existing content to WCAG level AA.

Ongoing

Initiative

Commitment 

Action

Status 

3.1 Recruitment, General

• Notify employees and the public about the availability of accommodation for applicants with disabilities during the recruitment processes.

• Review and revise any applicable HR policies to explain requirements and the Company’s commitment to compliance.
• Include an accessibility notification as part of all job postings.

Complete

3.2 Recruitment, Assessment, or Selection Process

• During a recruitment process, notify job applicants when they are individually 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, 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.

• Review and revise any applicable HR policies to explain requirements and the Company’s commitment to compliance.
• Include an accessibility notification as part of all job postings.
• Ensure that applicants with disabilities are properly accommodated as required.
• Consult with the applicant as required.
• Ensure enough time in the application process to receive, assess, and implement an accommodation request.

Complete 

3.3 Notice of Successful Applicants

• When making offers of employment, notify the successful applicant of the policies for accommodating employees with disabilities.

• Revise offer of employment templates to include requisite accessibility/ accommodation information

Complete

3.4 Informing Employees of Supports

• Inform employees of policies used to support its employees with disabilities including, but not limited to, policies on the provision of job accommodations that consider an employee’s accessibility needs due to disability.
• Provide this information to new employees as soon as practicable after they begin their employment.
• Provide updated information to employees whenever there is a change to existing policies

• Continue to revise and re-issue Employee Policies at all levels as necessary. 
• Include AODA and disability policies in orientation package(s). 
• Re-issue updated policies and communicate in employee meetings as necessary

Complete 

3.5 Accessible Formats and Communication Supports for Employees

• Upon request, provide or arrange for the provision of suitable accessible formats and communication supports for information needed to perform the employee’s job and information that is generally available to employees in the workplace.
• Consult with the employee making the request in determining the suitability of an accessible format or communication support

• Provide all information that is generally available to employees in an accessible manner as required. 
• Continue with existing procedures for responding to accommodation/ accessibility requests and determining the suitability of the request. 
• Respond to additional accessibility requests on a case-by-case basis as required. 
• Consult with requesting employees regarding the suitability of accessibility as required.

Ongoing 

3.6 Workplace Emergency Response Information

• If aware of need for accommodation, provide individualized workplace emergency response information (IWERI) to employees who have a disability, if the disability is such that the individualized information is necessary
• If an employee who receives individualized workplace emergency response information (IWERI) requires assistance and consents, provide the IWERI to the person designated by the employer to assist the employee.
• Provide the information required under Section 27 as soon as practicable after the employer becomes aware of the need for accommodation due to the employee’s disability.
• Review the IWERI whenever (i) an employee moves to a different location; (ii) the employee’s overall needs change; or (iii) the employer reviews the general emergency response policy

• Continue to review existing and future accommodation needs and provide individualized information as necessary
• Record the consent of the person receiving IWERI and keep a record of all designated persons. 
• Provide the IWERI to the designated persons as necessary
• Record and track response times via email and determine reasonable implementation time.
• Employees to notify management in a timely manner when their needs change; respond accordingly. 
• Review all affected IWERIs when the Company’s general emergency response policy changes.

Complete 

3.7 Documented Individual Accommodation Plans

• Develop and have in place a written process for the development of documented individual accommodation plans for employees with disabilities.

• Refine existing written process for responding to accommodation/accessibility requests and developing accommodation plans in accordance with the elements set out in ss. 28(2) and (3).

Complete

3.8 Return to Work Process

• Develop and have in place a documented return to work process for employees who have been absent from work due to a disability and require accommodations to return to work. 
• The process shall outline the steps the employer will take to facilitate the return to work of employees who were absent due to disability, utilizing the individual accommodation plans referred to in s. 28.

• Refine existing written process for employees who have been absent from work due to disability and require accommodation to return to work. 
• Refine existing written process for responding to accommodation/accessibility requests and developing accommodation plans in accordance with the elements set out in ss. 28(2) and (3).

Complete

3.9 Performance Management

• Take into account the accessibility needs of employees with disabilities when providing performance management.

• Continue using established performance management processes; assess accommodation needs on an individual basis.

Complete

3.10 Career Development & Advancement

• Take into account the accessibility needs of employees with disabilities when using career development and advancement.

• Continue using established advancement process; assess accommodation needs on an individual basis.

Complete 

3.11 Redeployment

• An employer that uses redeployment shall take into account the accessibility needs of its employees with disabilities, as well as individual accommodation plans when redeploying employees with disabilities. 

• Review and update current transfer and redeployment practices and processes to ensure accommodation plans are referenced
• Educate hiring managers to ensure redeployment efforts/activities take into account the employee’s accommodation needs. 

Complete 

Initiative

Commitment 

Action

Status 

4.1 Policies, Practices, Procedures

• Establish policies, practices, and procedures on providing goods or services to persons with disabilities according to requirements set out in regulation.
• Create a document describing policies, procedures, and practices; provide upon request in an alternative format.

• Communicate compliance requirements to all employees. 
• Draft and distribute AODA policies addressing customer service standards. 

Complete 

4.2 Communication

• Must communicate with a person with a disability in a manner that takes into account his/her disability

• Respond to employees, customers, and other stakeholders as required.

Ongoing 

4.3 Use of Service Animals or Support Persons

• Establish policies, practices, and procedures around a person with a disability being accompanied by a service animal or support person.

• Communicate compliance requirements at all employee levels. 
• Included in Customer Service policy updates in employment policies. 

Complete

4.4 Notice of Temporary Disruptions

• Provide public notice of disruption in facilities or services by posting on the premises or the website. 
• Include in the notice the reason for disruption, anticipated duration, and description of alternatives, if available. 
• Create a document describing steps to be taken for temporary disruptions; provide upon request.

• Commitment written into policies. 
• Advise service areas of requirement and follow-up as required. 

Ongoing 

4.5 Training for Staff

• Provide training to: 
• employees, agents, and volunteers who deal with the public or others. 
• everyone who participates in developing the policies, practices, and procedures governing providing goods or services to the public or others. 
• Include training on specific topics set out in the regulation. 
• Provide training on an ongoing basis to reflect any changes to policies, practices, and procedures. 
• Create document describing training policy, summary of content and details of when provided. 
• Keep records of training provided, including dates and number trained.

• Develop a training delivery program. 
• Draft training slides; upload to training delivery format. 
• Communicate requirements at all employee levels
• Distribute training program with instructions and deadlines for reporting. 
• Deliver training to all employees 
• Monitor training roll-out and audit completion records. 
• Create and maintain a database of training records. 

Complete 

4.6 Feedback Process

• Establish a process for receiving and responding to feedback; make information about the process publicly available. 
• Create a document describing the process; make it available upon request.

• Create and maintain database of any and all feedback received. 
• Description of process included in policies and made publicly available binders at reception of all facilities.
• All feedback to be processed and sent to Director, People and Culture for review

Complete 

4.7 Notice of Availability of Documents

• Notify customers that the documents covered by this Regulation are available upon request by posting conspicuously on premises, website, or other reasonable method.

• All policies and other material made publicly available. 

Complete

4.8 Format of Documents

• Alternate format of documents covered by this regulation must take into account person’s disability.

• Respond to employees, customers and other stakeholders as required.

Ongoing