Accessibility for Ontarians with Disabilities Act Policy
POLICY 1 — ACCESSIBLE CUSTOMER SERVICE POLICY
PURPOSE. To establish Three R Property Management's framework for providing goods, services and facilities to persons with disabilities in a manner consistent with the Accessibility for Ontarians with Disabilities Act, 2005 (AODA) and the Integrated Accessibility Standards Regulation (IASR).
1. STATEMENT OF COMMITMENT
Three R Property Management ("3R") is committed to providing an accessible environment in which persons with disabilities have equal access to the Company's goods, services and facilities in a manner that respects dignity, independence, integration and equality of opportunity. 3R will identify, prevent and remove accessibility barriers in a timely manner and will provide reasonable alternative methods of service where an accessible solution is not otherwise available.
2. SCOPE
This policy applies to 3R employees, volunteers, agents, contractors and other persons who provide goods, services or facilities on behalf of 3R in Ontario, and to persons involved in developing 3R policies governing the provision of goods, services or facilities.
3. COMMUNICATION AND ACCESSIBLE FORMATS
3R will communicate with persons with disabilities in ways that take their disability-related accessibility needs into account. Upon request, 3R will provide or arrange for accessible formats and communication supports in a timely manner and at a cost, if any, that is no more than the regular cost charged to other persons. 3R will consult with the person making the request to determine the suitability of the accessible format or communication support.
4. ASSISTIVE DEVICES
Persons with disabilities may use their own assistive devices when obtaining, using or benefiting from 3R's goods, services or facilities. Where a barrier prevents use of an assistive device, 3R will consult with the person and make reasonable efforts to provide an alternative method of access.
5. SERVICE ANIMALS
A person with a disability who is accompanied by a guide dog or other service animal will be permitted to enter areas of 3R premises that are open to the public or other third parties and to keep the animal with them, except where the animal is otherwise excluded by law. Where exclusion is required by law, 3R will explain the reason and explore alternative measures to enable access to its goods, services or facilities.
6. SUPPORT PERSONS
A person with a disability may be accompanied by a support person and will be permitted access to that support person while on premises open to the public. If 3R considers requiring a support person for health or safety reasons, it will first consult with the person with a disability, consider available evidence and determine whether another reasonable means of protecting health and safety is available. Where 3R requires a support person, any applicable admission fee for that support person will be waived.
7. TEMPORAY DISRUPTIONS
Where there is a planned or unexpected disruption in a facility or service ordinarily used by persons with disabilities, 3R will provide notice as soon as reasonably practicable. The notice will identify the affected facility or service, the reason for the disruption, its anticipated duration and any alternative facilities or services available. Notice will be provided in a manner appropriate to the circumstances, which may include posting at the affected premises, on a website or by another effective method.
8. FEEDBACK
3R welcomes feedback concerning the manner in which it provides accessible goods, services and facilities. The feedback process itself will be accessible. Upon request, accessible formats and communication supports will be provided or arranged. Feedback will be directed to the person or department designated by 3R, reviewed in a timely manner and, where a response is requested or appropriate, responded to using a communication method that takes the person's accessibility needs into account.
3R will retain accessibility-related feedback for a minimum of one (1) year from the date it is received and will use the information to support continuous improvement of accessibility services and practices.
Feedback can be provided in the following ways:
In writing/call: Three R Property Management
3520 Pharmacy Avenue, Unit 1
Toronto ON, M1W 2T8
Phone: 416-499-9350
Fax: 416-499-5312
By email: aoda@3rproperties.com
By online form: https://www.3rproperties.com/feedback
9. TRAINING
3R will provide appropriate accessibility training to all employees and persons who participate in developing 3R policies. Training will address the applicable accessibility standards, accessible customer service requirements and the Ontario Human Rights Code as it pertains to persons with disabilities. Training will be provided as soon as practicable and when changes are made to relevant policies or practices. 3R will maintain records of training, including dates and the number of persons trained, and may maintain participant records as appropriate.
10. DESIGN OF PUBLIC SPACES
Where 3R engages in construction or reconstruction of regulated public spaces, such construction or reconstruction shall comply with the requirements of the Integrated Accessibility Standard.
Public spaces, where applicable, include outdoor public eating areas; outdoor play spaces; outdoor paths of travel; accessible off-street parking; and service-related elements (i.e service counters, fixing queuing guides and waiting areas).
3R will take reasonable steps to prevent or minimize disruptions to accessible elements of public spaces. Where an accessible element is temporarily unavailable, 3R will provide notice of the disruption and, where applicable, information about available alternatives.
3R shall specifically consider procedures for preventative and emergency maintenance of the accessible elements in public spaces to minimize the disruption in access to the accessible parts of its public spaces.
11. DOCUMENTATION AND REVIEW
This policy will be made available to the public and will be provided in an accessible format upon request. 3R will notify the public of the availability of accessible formats and communication supports. This policy will be reviewed when required by legislative or operational changes and otherwise periodically to ensure continued effectiveness.
POLICY 2 — EMPLOYEE ACCESSIBILITY POLICY
PURPOSE. To integrate accessibility into the employment lifecycle and establish clear commitments under the IASR Employment Standard.
1. RECRUITMENT, ASSESSMENT AND SELECTION
Three R Property Management ("3R") will notify employees and the public about the availability of accommodation for applicants with disabilities in its recruitment processes. When an applicant is selected to participate in an assessment or selection process, 3R will notify the applicant that accommodations are available upon request in relation to the materials or processes to be used. If requested, 3R will consult with the applicant and provide or arrange a suitable accommodation that takes the applicant's accessibility needs into account.
2. SUCCESSFUL APPLICANT
When making an offer of employment, 3R will notify the successful applicant of its policies for accommodating employees with disabilities.
3. INFORMING EMPLOYEES OF SUPPORTS
3R will inform employees of policies used to support employees with disabilities, including policies respecting job accommodation. New employees will receive this information as soon as practicable after commencing employment, and employees will be informed of changes to such policies.
4. ACCESSIBLE FORMATS AND COMMUNICATION SUPPORTS.
Upon request by an employee with a disability, 3R will consult with the employee to provide or arrange accessible formats and communication support for information needed to perform the employee's job and information generally available to employees in the workplace.
5. WORKPLACE EMERGENCY RESPONSE INFORMATION
Where 3R is aware of an employee's need for accommodation due to disability and individualized workplace emergency response information is necessary, 3R will provide that information as soon as practicable. With the employee's consent, information may be provided to a person designated to assist the employee. The information will be reviewed when the employee changes work location, when accommodation needs or plans are reviewed, and when 3R reviews its general emergency-response policies.
6. INDIVIDUAL ACCOMMODATION PLANS
3R will maintain a written process for the development of documented individual accommodation plans for employees with disabilities. The process is set out in the Workplace Accommodation Policy and Process forming part of this package.
7. RETURN TO WORK
3R will maintain a documented 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. Where applicable, the process will use an individual accommodation plan. This process does not replace or override another return-to-work process created under other applicable legislation.
8. PERFORMANCE MANAGEMENT, CAREER DEVELOPMENT AND REDEPLOYMENT
Where 3R uses performance management, provides career development or advancement, or redeploys an employee with a disability, it will take into account the employee's accessibility needs and, where applicable, the employee's individual accommodation plan.
9. CONFIDENTIALITY
Disability and accommodation-related information will be handled confidentially and shared only to the extent reasonably necessary to assess, implement, administer or review accommodation, or as otherwise permitted or required by law.
10. RESPONSIBILITIES
Management and Human Resources are responsible for implementing this policy within their respective functions. Employees are expected to identify accommodation needs where assistance is required and to participate in the accommodation process in good faith. 3R will administer accessibility obligations in a manner consistent with applicable accessibility and human-rights requirements.
POLICY 3 — WORKPLACE ACCOMMODATION POLICY AND PROCESS
PURPOSE. To provide a consistent, individualized and documented process for identifying and addressing disability-related workplace barriers and accommodation needs.
1. COMMITMENT
3R will provide disability-related workplace accommodation in accordance with applicable accessibility and human-rights requirements, to the point of undue hardship where that legal standard applies. Accommodation will be individualized and will focus on removing workplace barriers and enabling employees to perform their work safely and effectively.
2. INITIATING A REQUEST
An employee may request accommodation verbally or in writing from their manager, Human Resources or another person designated by 3R. Use of the Accommodation Request Form is encouraged for consistency but is not a precondition to considering an accommodation need. A manager who becomes aware that an employee may require disability-related accommodation should refer the matter to the designated accommodation administrator, currently the Controller.
3. PARTICIPATION AND REPRESENTATION
The employee will participate in identifying restrictions, functional limitations, workplace barriers and potential accommodation measures. The employee may request the participation of a representative from the workplace, where applicable and appropriate, during development of the accommodation plan.
4. INFORMATION AND ASSESSMENTS
3R may request information reasonably necessary to understand the employee's disability-related functional limitations or restrictions and to assess appropriate accommodation. Requests will focus on functional workplace information rather than diagnosis except where additional information is reasonably necessary in the circumstances. Where appropriate, 3R may request an evaluation by an outside medical or other expert, at 3R's expense, to assist in determining whether and how accommodation can be achieved.
5. ASSESSMENT OF ACCOMMODATION OPTIONS
3R and the employee will consider reasonable accommodation options having regard to the employee's functional needs, the essential duties and circumstances of the position, workplace safety, operational requirements and applicable legal obligations. The employee's preferred accommodation will be considered, although 3R may implement another effective reasonable accommodation.
6. INDIVIDUAL ACCOMMODATION PLAN
Where required, 3R will prepare a written Individual Accommodation Plan. The plan may identify the employee's relevant restrictions or functional needs; accessible-format or communication-support requirements; individualized emergency-response information; agreed accommodation measures; implementation responsibilities; effective date and expected duration; and review dates. Medical diagnosis will not ordinarily be included in the plan unless necessary and appropriate.
7. DENIAL OF A REQUESTED ACCOMMODATION
If a requested accommodation is not accepted, 3R will communicate the decision and the basis for it to the employee and will consider whether another effective accommodation is available. Where required by the IASR, reasons for denying an individual accommodation plan will be provided in an appropriate manner.
8. REVIEW AND MODIFICATION
Accommodation plans will be reviewed at the review dates stated in the plan and earlier where the employee's needs, job duties, work location, workplace barriers or available accommodation measures materially change. Employees should advise 3R promptly when a plan requires review.
9. RETURN TO WORK
Where an employee returns from a disability-related absence and requires accommodation, 3R will consult with the employee, identify relevant restrictions and barriers, assess suitable measures, document them where required, establish implementation and review dates, and monitor the return-to-work arrangement.
10. PRIVACY AND RECORDS
Accommodation records will be kept separate from general personnel information where practicable, securely maintained and accessible only to persons who require the information for legitimate accommodation, safety, administrative or legal purposes. Managers will ordinarily receive only the information needed to implement restrictions and accommodation measures.
11. PROCESS SUMMARY
· Employee or manager identifies a potential accommodation need.
· Request is referred to the designated 3R accommodation administrator.
· 3R consults with the employee and identifies workplace barriers and functional limitations and accommodation needs.
· Reasonably necessary supporting information is obtained, where required.
· Accommodation options are assessed collaboratively.
· An Individual Accommodation Plan is documented where required.
· Agreed accommodation measures are implemented and communicated to those who need to act on them.
· The arrangement is monitored and reviewed; modifications are documented as necessary.
· Return-to-work and emergency-response requirements are coordinated with the plan where applicable.