ACCESSIBILITY POLICY
The following policy has been established by OSL Retail Services Inc. and OSL Direct Services Inc. (“OSL”) to govern company programs, services and facilities in accordance with Regulation 197/ll, “Integrated Accessibility Standards” (“Regulation”) under the Accessibility for Ontarians with Disabilities Act, 2005, as amended by 0. Reg. 765/76.
This policy has been developed to break down barriers and increase accessibility for persons with disabilities in the areas of information and communications as well as employment. OSL is governed by this policy as well as the Accessibility Standards for Customer Service Policy and the Accessibility for Ontarians with Disabilities Act, 2005.
COMMITMENT
OSL is committed to treating all people in a way that allows them to maintain their dignity and independence. We believe in integration and equal opportunity. We are committed to meeting the needs of persons with disabilities with respect to the company’s programs, services and facilities in a timely manner, and will do so by preventing and removing barriers to accessibility and meeting accessibility requirements under the Regulation and the Accessibility for Ontarians with Disabilities Act., 2005. This policy will be implemented in accordance with the time frames established by the Regulation.
ACCESSIBILITY PLAN
OSL has developed an Accessibility Plan outlining the company’s strategy to prevent and remove barriers from its workplace and to improve opportunities for persons with disabilities. The Accessibility Plan will be reviewed and updated annually and will be posted on the company’s website. Upon request, OSL will provide a copy of the Accessibility Plan in a downloadable and printable format.
INFORMATION AND COMMUNICATIONS STANDARDS
ACCESSIBLE FORMATS AND COMMUNICATION SUPPORTS
Upon request, OSL will provide, or will arrange for the provision of accessible formats and communication supports for persons with disabilities in a timely manner that considers the person’s accessibility needs due to disability. Alternate formats will be available for individuals seeking to provide feedback upon request. We are committed to providing all written communication including invoices, letters etc. in a format that is accessible to all our employees, customers and partners. This may include large print, email etc. We will answer any questions about the content of any written document in person, by telephone or email. OSL will consult with the person making the request in determining the suitability of an accessible format or communication support.
ACCESSIBLE WEBSITES AND WEB CONTENT
OSL will ensure that websites, including web content, conform to the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0, at Level A (January l, 2074). We will also take steps to ensure that all company websites and content conform with WCAG 2.0 Level AA (except as outlined in the Regulation).
TELEPHONE SERVICES
We are committed to providing fully accessible telephone service to all individuals. We will train staff to communicate over the telephone in clear and plain language and to speak slowly. We will offer to communicate by other means including letter mail, e-mail, or facsimile if telephone communication is not suitable to their communications needs or is not available.
NOTICE OF TEMPORARY DISRUPTION
OSL will provide employees, customers and partners with notice in the event of a planned or unexpected disruption in the facilities or services usually used by people with disabilities. This notice will include information about the reason for the disruption, its anticipated duration, and a description of alternative facilities or services, if available. The notice will be placed at all public entrances and reception areas on our premises.
EMPLOYMENT STANDARDS
RECRUITMENT
OSL will notify its employees and the public about the availability of accommodations for applicants with disabilities in its recruitment process.
RECRUITMENT, ASSESSMENT OR SELECTION PROCESS
OSL will notify job applicants, when they are individually selected to participate further 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, OSL will consult with the applicant and provide, or arrange for the provision of, a suitable accommodation in a manner that considers the applicant’s accessibility needs due to disability.
NOTICE TO SUCCESSFUL APPLICANTS
When making offers of employment, OSL will notify the successful applicant of its policies for accommodating employees with disabilities.
INFORMING EMPLOYEES OF SUPPORTS
OSL will continue to inform its employees of its policies (and any updates to those policies) used to support employees with disabilities, including policies on the provision of job accommodations that consider an employee’s accessibility needs due to disability. This information will be provided to new employees as soon as practicable after commencing employment.
ACCESSIBLE FORMATS AND COMMUNICATION SUPPORTS FOR EMPLOYEES
Upon the request of an employee with a disability, OSL will consult with the employee to provide, or arrange for the provision of, accessible formats and communication supports for information that is needed to perform their job, and information that is generally available to other employees.
In determining the suitability of an accessible format or communication support, OSL will consult with the employee making the request. However, the company reserves the flexibility to decide on the most appropriate accessible formats or communication supports for employees (based on the needs of the specific employee and the capacity of the company to provide the support).
WORKPLACE EMERGENCY RESPONSE INFORMATION
OSL will provide individualized workplace emergency response information to employees who have a disability, if the disability is such that individualized information is necessary, and if OSL is aware of the need for accommodation due to the employee’s disability. OSL will provide this information as soon as practicable after becoming aware of the need for accommodation.
Where the employee requires assistance, OSL will, with the consent of the employee, provide the workplace emergency response information to the person designated by OSL to assist the employee.
OSL will review the individualized workplace emergency response information (i) when the employee moves to a different location in the organization, (ii) the employee’s overall accommodations needs are reviewed, or (iii) when the employer reviews its emergency response policies.
DOCUMENTED INDIVIDUAL ACCOMMODATION PLANS
OSL will maintain a written process for the development of documented individual accommodation plans for employees with disabilities.
If requested, information regarding accessible formats and communications supports provided will also be included in individual accommodation plans.
In addition, the plans will include individualized workplace emergency response information (where required) and will identify any other accommodation that is to be provided.
RETURN TO WORK PRINCIPLES
OSL maintains a documented return-to-work process for its employees who have been absent from work due to a disability and who require disability related workplace accommodations to return to work.
The return-to-work process outlines the steps OSL will take to facilitate return-to-work and will include documented individual accommodation plans. We will consult with the person making the request in determining the suitability of an accessible format or communication supports, specifically for:
We will provide the information as soon as practicable after we become aware of the need for accommodation due to the employee’s disability. This return-to-work process will not replace or override any other return to work process created by or under any other statute (i.e., the Workplace Safety Insurance Act, 1997).
RETURN TO WORK PROCESS
OSL works in partnership with our third-party vendors, Crawford and Broadspire, to manage accommodation and leave of absence requests. Notwithstanding some unique process differences between our vendors, the leave and return to work processes adhere to the following steps:
Step 1 – Initiating the leave of absence or accommodation:
If an employee needs to take a disability leave, they will promptly inform their manager. The employee and manager will maintain regular contact, with the employee’s consent, to address any problems that may arise and facilitate the return-to-work process. If an employee needs to request an accommodation, then they will promptly inform their manager.
Step 2 – Gather relevant information and assess individual needs:
The employee will work with Crawford or Broadspire to share information. Our vendor will work with the employee and Human Resources to find the most appropriate accommodation. These plans will be developed in consultation with the employees, considering their needs.
Manager/ Human Resources/ Crawford/ Broadspire:
Employee
Step 3 – Develop a return-to-work/Accommodation Plan:
After identifying the most appropriate accommodation, safety considerations and any transitional measures, the Manager works with Crawford or Broadspire to capture the details in a written plan. Depending on circumstances, the employee may:
The return-to-work plans are documented through OSL’s third party vendors, Crawford and Broadspire. Plans include specific accommodations and safety considerations for the employee.
Step 4: Implement, Monitor and Update the Plan:
After implementing the return-to-work plan, the employee and manager will monitor and review the plan regularly to ensure that it remains effective in partnership with Crawford or Broadspire. The accommodation plan will also be reviewed and updated if:
PERFORMANCE MANAGEMENT, CAREER DEVELOPMENT, ADVANCEMENT AND REDEPLOYMENT
OSL will consider the accessibility needs of employees with disabilities, as well as individual accommodation plans, when conducting performance management, providing career development and advancement to employees, or redeploying employees.
TRAINING
OSL will provide training to employees and volunteers; persons who participate in developing OSL policies; and other persons who provide goods, services or facilities on behalf of the company. They will be trained in all aspects of the Ontario Himan Rights Code that relate to persons with disabilities.
Applicable staff will be trained on policies, practices and procedures that affect the way services are provided to people with disabilities. Staff will also be trained on an ongoing basis when changes are made to these policies, practices and procedures.
Our content is housed in our Learning Management System (OSL Learn) and is a hybrid of a pre-fabricated course through Access Forward, and customized information specific to our company. Content includes:
The training will be appropriate to the duties of the employees, volunteers and other persons as it relates to their specific roles. Training includes:
Employees will be trained when changes are made to the accessibility policy. New employees will be trained within 30 business days of their start date as part of their orientation.
OSL will keep a record of the training it provides, including the dates on which the training was provided and the number of individuals to whom it was provided.
CUSTOMER SERVICE
OSL is committed to providing accessible and inclusive customer service to all individuals, including those with disabilities. The principles of dignity, independence and equal opportunity are at the forefront when OSL delivers its services.
OSL will strive to provide services in a manner that promotes independence for individuals with disabilities. We provide integrated services to individuals with disabilities, allowing them to fully benefit from and participate in our offerings alongside those without disabilities.
We will ensure that individuals with disabilities have the same opportunities to access our services, in the same place and in a similar manner as others.
OSL will communicate with individuals with disabilities in ways that consider their disability. This includes training employees on how to interact and communicate with people with various disabilities.
We are committed to serving people with disabilities who use assistive devices to obtain, use or benefit from our services. We will ensure that our employees are trained and familiar with various assistive devices that may be used by people with disabilities while accessing our services.
OSL will accommodate individuals with disabilities to the point of undue hardship, including but not limited to offering accessible formats of information, assistive devices, service animals, and support persons.
We are committed to welcoming people with disabilities who are accompanied by a service animal on the areas of our offices that are open to the public and other third parties.
We will ensure that all staff dealing with the public are properly trained in how to interact with people with disabilities who are accompanied by a service animal. We are committed to welcoming people with disabilities who are accompanied by a support person. Any person with a disability who is accompanied by a support person will always have access to their support person while on our premises.
DESIGN OF PUBLIC SPACES
OSL is committed to incorporating inclusive design principles that consider the diverse needs of individuals with disabilities, ensuring that public spaces are usable by everyone to the greatest extent possible.
We will strive to provide spaces that afford individuals with disabilities the same opportunities to participate in and enjoy services, programs, and facilities as those without disabilities. This includes considering elements such as clear pathways, appropriate signage, and accessible amenities.
POLICY MODIFICATIONS AND QUESTIONS
We are committed to developing customer service policies that respect and promote the dignity and independence of people with disabilities. Therefore, no changes will be made to this policy before considering the impact on people with disabilities and any policy of OSL that does not respect and promote the dignity and independence of people with disabilities will be modified or removed.
This policy exists to achieve an accessible and equitable experience for every one of our diverse and valued employees, clients and partners in all office locations in Ontario in accordance with the requirements of the Accessibility for Ontarians with Disabilities Act, 2005 (“AODA”). Questions about the policy, or requests for clarification about the purpose of the policy, may be sent to:
Phone: (905) 766-4074
E-Mail: [email protected]
Mail: 5090 Orbitor Dr #7, Mississauga, ON L4W 5B5