Introduction

The Integrated Accessibility Standards Regulations (“IASR”) under the Accessibility for Ontarians with Disabilities Act, 2005 (the “AODA”) require that the Company establish, implement, maintain and document its accessibility policies and multi-year accessibility plan (the “Accessibility Plan”), which outlines the Company’s strategy for preventing and removing barriers for persons with disabilities and to meet our requirements under the IASR.

The Accessibility Plan can be found on the Company’s website and is also available in an accessible format upon request. The Accessibility Plan will be reviewed and updated, if applicable, at least once every five years.

Application

The Accessibility Plan applies to all employees and customers of the Company, and, where indicated, to any independent contractor representatives working for the Company.

Our Commitment

In fulfilling its mission, the Company strives to treat all individuals in a manner that allows them to maintain their dignity and independence. The Company promotes integration and equal opportunity and is committed to meeting the needs of people with disabilities in a timely manner. The Company seeks to achieve this by preventing and removing barriers to accessibility and by meeting accessibility requirements under the AODA. This Accessibility Policy and Multi-Year Accessibility Plan sets out the Company’s policy on how it achieves accessibility generally, as well as in employment, information and communications and design of public spaces (built environment).

Under the IASR, the following accessibility strategies set out the requirements that are applicable to the Company:

1. Workplace Emergency Response Information
2. Training
3. Information and Communication
4. Kiosks
5. Employment
6. Design of Public Spaces Standards

Accessibility Standards for Customer Service

The Company is committed to compliance with the Accessibility Standards for Customer Service, as set out in O. Reg. 191/11 under the AODA, which requires providing its services in ways that respects the dignity and independence of people with disabilities.

The Company’s employees who are involved in providing customer service to its customers and the general public have been trained on the Company’s Customer Service Policy, and all new employees hired to provide such services will receive such training as part of their orientation with the Company.

A copy of the Company’s AODA Customer Service Policy is available at our premises and will be made available to members of the public and third parties on request.

Accessible Emergency Information

The Company is committed to providing all customers and clients with publicly available emergency information in an accessible way upon request.

Integrated Accessibility Standards Regulations (IASR)

1. Workplace Emergency Response Information

Where the Company is aware that an employee has a disability and that there is a need for accommodation, individualized workplace emergency response information will be provided to the employee as soon as practicable if such information is necessary given the nature of the employee’s disability.

Actions:

• Individualized workplace emergency response information procedures will be developed for employees with disabilities where required.
• Where employees disclose a disability and are being accommodated according to their disabilities, workplace emergency response information forms will be prepared where required.
• Where required, the Company provides assistance to specific disabled employees, with the disabled employees’ prior consent, to help them evacuate the workplace in case of an emergency or disaster. Plans for providing assistance will be set out in individualized emergency plans for the employees.
• Individualized emergency plans will be communicated to the employees’ respective managers and safety personnel on an ‘as needed’ basis.
• On an ongoing and regular basis, and as per the applicable terms of the IASR, the Company will review and assess general workplace emergency response procedures and individualized emergency plans to ensure accessibility issues are addressed.

2. Training

The Company is committed to providing training on the requirements of the accessibility standards referred to in the IASR and on the Ontario Human Rights Code, as it pertains to persons with disabilities.

Actions:

• Determines and ensures that appropriate training on the requirements of the IASR and on the Ontario Human Rights Code as it pertains to persons with disabilities is provided to all employees, volunteers, and persons providing goods, services, or facilities on behalf of the Company in Ontario, as well as all persons participating in the development and approval of the Company’s policies.
• Ensures that the training is provided to persons referenced above as soon as practicable.
• Keeps and maintains a record of the training provided, including dates the training was provided and number of individuals to whom it was provided.
• Ensures training is provided on any changes to the Company’s policies on an ongoing basis.

3. Information and Communication

The Company is committed to making company information and communications accessible to persons with disabilities. The Company will incorporate new accessibility requirements under the information and communication standards to ensure that its information and communications systems and platforms are accessible and are provided, upon request, in accessible formats that meet the needs of persons with disabilities.

a. Feedback, Accessible Formats and Communication Supports

Actions:

• Ensures that processes for receiving and responding to feedback are accessible to persons with disabilities by providing or arranging for the provision of accessible formats and communication supports, upon request and in a timely manner.
• As a general principle where accessible formats and communication supports for persons with disabilities are requested:
  • Provides or arranges for the provision of such accessible formats and communication supports.
  • Consults with the person making the request to determine the suitability of the accessible format or communication support.
  • Provides or arranges for the provision of accessible formats and communication supports in a timely manner that takes into account the person’s accessibility needs due to disability, and at a cost no more than the regular cost charged to other persons.
  • Notifies the public about the availability of accessible formats and communication supports.

b. Accessible Websites and Web Content

Actions: In accordance with the IASR, the Company recognizes its obligation to provide web content which conforms with the World Wide Consortium Web Content Accessibility Guidelines (WCAG 2.0) Level AA. Any website controlled by the Company shall meet the requirements set out in the IASR.

4. Kiosks

While the Company does not utilize kiosks in providing its services to the general public, the Company recognizes its obligations under the IASR should it choose to utilize kiosks for this purpose in the future.

5. Employment

a. Recruitment

The Company is committed to fair and accessible employment recruiting practices that attract and retain employees with disabilities. This includes providing accessibility at all stages of the employment cycle.

Actions:

• Notifies employees and the public of the availability of accommodation for applicants with disabilities in the recruitment process. Includes review and modification of recruitment policies and specifying availability on website/job postings.
• Notifies job applicants individually selected for assessment that accommodations are available, reviews policies, and arranges suitable accommodations.
• Notifies successful applicants of policies for accommodating employees with disabilities in offer letters.

b. Informing Employees of Supports and General Provision of Accessible Formats and Communications Supports

• Informs current employees and new hires of the Company’s policies supporting employees with disabilities, including policies on the provision of job accommodations.
• Provides information during employee orientation and keeps employees up to date on changes to policies.
• Where requested, provides suitable accessible formats and communication supports for job-related information and general workplace information, consulting with employees to determine suitability.

c. Documented Individual Accommodation Plans/Return to Work Process

The Company ensures barriers in accommodation and return to work processes are eliminated and policies are followed where applicable.

• Develops documented individual accommodation plans for employees with disabilities, if required.
• Accommodation plans include employee participation, assessment, medical evaluation, representative involvement, privacy, review frequency, reasons for denial, and provision in accessible format.
• Return to work process outlines steps to facilitate return after disability-related absence, including individualized return to work plans and use of accommodation plans.

d. Performance Management, Career Development and Redeployment

• Considers accessibility needs and accommodation plans during performance management, career development, and redeployment.
• Reviews, assesses, and modifies policies to ensure compliance with IASR.

6. Design of Public Spaces Standard

While the Company has no plans for new construction or redevelopment captured by IASR Design of Public Spaces requirements, it recognizes its obligations and is committed to incorporating barrier-free design principles for new or redeveloped public spaces on or after January 1, 2017.

Information and Feedback

For more information on this Accessibility Plan or to provide feedback please contact:

info@thetorontobeachclub.com

Accessible formats of this document are available free upon request.