Statement of Organizational Commitment
Carmens Group is committed to meeting the objectives and requirements outlined in the IASR under the Accessibility for Ontarians with Disabilities Act, 2005 (the “AODA”) and meeting the needs of people with disabilities, in a timely manner, through the implementation of the requirements of the AODA.
PART 1: GENERAL
1.1 Multi-Year Accessibility Plan and Accessibility Reports
Carmens Group shall establish, implement, maintain and document a Multi-Year Accessibility. The Multi-Year Accessibility Plan will outline Carmen’s Group’s strategy to prevent and remove barriers and meet the requirements under the IASR.
The Multi-Year Accessibility Plan will be posted on the Company website and will be provided in an accessible format upon request.
The Multi-Year Accessibility Plan will be reviewed and updated at least once every 5 years.
Carmens Group shall file an accessibility report with the Province annually or at such other times as may be specified. Accessibility reports shall be made publicly available.
Carmens Group will provide training to employees, volunteers and other staff members on the requirements of the accessibility standards in the IASR and on the Ontario Human Rights Code as it relates to persons with disabilities. Training will be provided as soon as practicable. Training will be provided in a way that best suits the duties of employees, volunteers and other staff members. The Company will maintain a record of the dates training is provided and the number of individuals to whom it was provided.
1.3 Self-Service Kiosks
Carmens Group will have regard to accessibility for persons with disabilities when designing, procuring or acquiring self-service kiosks.
PART 2: ACCESSIBLE INFORMATION AND COMMUNICATIONS STANDARDS
2.1 Accessible Emergency Information
Emergency procedures, plans or public safety information, that is publicly available, shall be provided in an accessible format or with appropriate communication supports, as soon as practicable upon request.
2.2 Feedback Process
Carmens Group has a process in place to receive and respond to customer feedback and will take steps to ensure those processes are accessible to persons with disabilities Carmens Group will provide or arrange for the provision of accessible formats and communication supports as soon as practicable upon request. Customers are notified regarding the availability of accessible formats and communication supports on our website.
2.3 Accessible Formats and Communication Supports
Carmens Group will upon request provide or arrange for the provision of accessible formats and communication supports for persons with disabilities at a cost that is no more than the regular cost charged to other persons and in a timely manner (as soon as practicable) that takes into account the person’s accessibility needs due to disability.
Carmens Group will consult with the person making the request in determining the suitability of an alternative format or communication support
Customers are notified on the Company website about the availability of accessible formats and communication supports.
Note that IASR does not apply to product and product labels, unconvertible information and communication, information that Carmens Group does not control directly or indirectly through a contractual relationship. In the event the Company determines it is not technically feasible to convert the information or communications or the technology to convert the information or communications is not readily available, the Company will provide the person that requires the information an explanation as to why the information or communications are unconvertible.
2.4 Accessible Websites and Web Content
The Company shall make its internet website and web content conform to World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0, initially at Level A and increasing to Level AA. By January 1, 2021 all internet website and web content published after 2012 will conform to0 Level AA to the extent practicable other than criteria 1.2.4 (captions) and 1.2.5 (pre-recorded audio descriptions).
Note that WCAG2.0 requirements only apply to websites, web content and web based applications that an organization can control either directly or through a contractual relationship and where meeting the requirements are technically feasible, including considering the availability of commercial software or tools or both.
PART 3: ACCESSIBLE EMPLOYMENT STANDARDS
The Accessible Employment Standards apply to all paid employees. Carmens Group will inform employees of the policies and changes in policies used to support employees with disabilities throughout the employment life cycle.
3.1 Recruitment, Assessment, Selection
Carmens Group will specify that accommodation is available for applicants with disabilities in its recruitment processes on the website and on job postings.
Carmens Group will inform internal and external job applicants when they are individually selected to participate in an assessment or selection process, that accommodations are available upon request to participate in the recruitment process.
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, having regard for the applicant’s accessibility needs.
When making an offer of employment, Carmens Group will notify the successful applicant of the policies for accommodating workers with disabilities at the time of the offer and as soon as practicable after the new employee begins work (specifically, during orientation).
3.2 Informing Employees of Supports
Carmens Group informs employees of policies used to support employees with disabilities including policies on the provision of job accommodation that take into an account the employee’s accessibility needs.
The information will be provided to new employees as soon as practicable after they begin their employment.
Updated information will be provided to employees whenever there is a change to existing policies on the provision of job accommodations.
3.3 Accessible Formats and Communication Supports for Employees
When requested by an employee, Carmens Group will consult with the employee to provide or arrange for the provision of accessible formats and communication supports for information that is needed in order to perform the employee’s job and also for information generally available to employees in the workplace. Carmens Group will consult with the employee making the request in determining the suitability of an accessible format or communication support.
3.4 Individualized Workplace Emergency Response Information
Carmens Group will provide individualized workplace emergency response information to employees who have a disability if the disability is such that individualized information is necessary and Carmens Group is aware of the need for accommodation due to the disability.
If an employee who receives individualized workplace emergency response information requires assistance and with the employee’s consent, Carmens Group will provide the workplace emergency response information to the person designated by Carmens Group to provide assistance to the employee.
Individualized workplace emergency response information will be reviewed when an employee moves to a different location within the organization, when the employee’s overall accommodation needs or plans are reviewed and when Carmens Group reviews its general emergency response policies.
3.5 Documented individual accommodation plans
Carmens Group has a written process for the development of an Individual Accommodation Plan (IAP) for employees with disabilities. In accordance with the IASR, the process includes:
- the manner in which an employee requesting accommodating 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 the employer can request an evaluation by an outside medical or other expert, at the employer’s expense, to assist the employer in determining if accommodation can be achieved and, if so, how accommodation can be achieved;
- the manner in which the employee can request the participation of a workplace representative in the development of the accommodation plan;
- the steps 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 will be provided to the employee;
- the means of providing the individual accommodation plan in a format that takes into account the employee’s accessibility needs due to disability.
Individual accommodation plans shall: 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.
3.6 Return to work
Carmens Group has a written return to work process for employees who have been absent from work due to a disability and require disability-related accommodation to return to work. The return to work process:
- outlines the steps the Company will take to facilitate the return to work of employees who were absent because their disability required them to be away from work; and
- uses documented IAPs as described above.
3.7 Performance Management, Career Development, Advancement & Redeployment
Carmens Group shall take into account the accessibility needs of employees with disabilities and IAPs in its performance management processes, when providing career development and advancement opportunities and when considering redeployment of employees with disabilities.
PART 4: DESIGN OF PUBLIC SPACES STANDARDS
The Accessibility Standards for the Built Environment focus on removing barriers in two areas:
- public spaces, and
Enhancements to accessibility in buildings will happen at a later date through Ontario’s Building Code, which governs new construction and renovations in buildings.
4.1 Public Spaces
Carmens Group shall incorporate accessibility into public spaces that are newly constructed or redeveloped where practicable on and after January 1, 2017.
Public spaces include exterior paths of travel, parking, service counters, queuing lines, waiting areas, maintain accessible parts of public spaces, recreation trails and beach access routes, outdoor public eating areas, outdoor play spaces.
For questions or clarifications, please contact
1 King Street West, Suite 1200
Hamilton, ON L8P 1A4
Ontarians with Disabilities Act, 2001
Accessibility for Ontarians with Disabilities, 2005
Ontario Regulation 191/11 – Integrated Accessibility Standards
Ontario Regulation 429-07 – Accessibility Standards for Customer Service
Accessible Customer Service Policy
Ontario Human Rights Code
Disability, as defined by the AODA and the Ontario Human Rights Code, is:
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.