STATEMENT OF COMMITMENT

Harding Display is committed to meeting the accessibility needs of persons with disabilities in an effective and timely manner by preventing and removing barriers for persons with disabilities in accordance with the Integrated Accessibility Standards Regulation (IASR). Harding Display’s goal is to foster an inclusive organizational culture that is guided by the principles and requirements of the Accessibility for Ontarians with Disabilities Act (AODA), 2005, the IASR and the Ontario Human Rights Code (“Code”).

PART 1- GENERAL REQUIREMENTS

ACTION
COMPLIANCE DATE
RESPONSIBILITY
STATUS

Establishment of Accessibility Policies

Every obligated organization shall develop, implement and maintain policies governing how the organization achieves or will achieve accessibility through meeting its requirements under the accessibility standards referred to in this Regulation

Action: Harding Display has developed all policies and procedures necessary to comply with the requirements set forth by AODA due Jan 1, 2014.

Jan 1, 2014
Human Resources
Complete

Accessibility Plans

Large organizations shall,

a) establish, implement, maintain and document a multi-year accessibility plan, which outlines the organization‘s strategy to prevent and remove barriers and meet its requirements under this Regulation;

b) post the accessibility plan on their website, if any, and provide the plan in an accessible format upon request; and

c) review and update the accessibility plan at least once every five years.

Action: Accessibility plan completed. HR and management to identify barriers in the workplace on an ongoing basis. HR will review the plan periodically and make changes as needed

Jan 1, 2014
Human Resources
Complete

Self Service Kiosks

Large organizations and small organizations shall have regard to the accessibility for persons with disabilities when designing, procuring or acquiring self-service kiosks.

Action: N/A

Jan 1, 2014
Senior Management
Not Applicable
Training

Every obligated organization shall ensure that training is provided on the requirements of the accessibility standards referred to in this Regulation and on the Human Rights Code as it pertains to persons with disabilities to:

(a) all employees, and volunteers;

(b) all persons who participate in developing the organization‘s policies; and

(c) all other persons who provide goods, services or facilities on behalf of the organization.

Action: Existing employees trained, new employees to be trained during onboarding.

Jan 1, 2015 & Ongoing
Human Resources
Ongoing

PART 2- INFORMATION AND COMMUNICATION STANDARDS

ACTION

COMPLIANCE DATE

RESPONSIBILITY
STATUS
Feedback Processes

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.

Action: Harding Display will review all feedback processes across the company and ensure all staff are away of the need to accommodate upon request and how to handle said requests. This will be integrated into the scheduled training on the Integrated Accessibility Standard.

Jan 1, 2015 & Ongoing
Human Resources
Ongoing
Accessible Formats and Communication Supports

Except as otherwise provided, every obligated organization shall upon request provide or arrange for the provision of accessible formats and communication supports for persons with disabilities

a) in a timely manner that takes into account the person‘s accessibility needs due to disability; and

b) at a cost that is no more than the regular cost charged to other persons.

The obligated organization shall consult with the person making the request in determining the suitability of an accessible format or communication support.

Every obligated organization shall notify the public about the availability of accessible formats and communication supports.

Action: Harding Display will determine what accessible formats and communication supports will be provided to persons with disabilities upon requests, to the extent practicable and will provide for provision of accessible formats and communication supports for persons with disabilities. Alternative communication methods will be available at our reception area and on our website.

Jan 1, 2016 & Ongoing
Human Resources & Marketing
Ongoing
Emergency Procedures, Plans or Public Safety Information

In addition to its obligations under section 12, if an obligated organization prepares emergency procedures, plans or public safety information and makes the information available to the public, the obligated organization shall provide the information in an accessible format or with appropriate communication supports, as soon as practicable, upon request.

Action: Harding Display will post emergency procedures, plans or safety information in an area where it is visible to the public and shall be provided in an accessible format or with appropriate communication supports, upon request as soon as practicable.

Jan 1, 2012
Human Resources & JHSC Team
Complete
Accessible Websites and Web content

Designated public sector organizations and large organizations shall make their internet websites and web content conform with the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0, initially at Level A and increasing to Level AA, and shall do so in accordance with the schedule set out in this section.

Action: Any new content or changes made to the Harding Display’s website in 2014 conforms to the WCAG 2.0 Level A Standards. Moving forward, all content in the years to come will meet the Level A standards. By 2021, using our web developer’s assistance, we will ensure that the website conforms to the WCAG 2.0 Level AA Standards, to the extent practicable other than criteria 1.2.4 (captions) and 1.2.5 (pre-recorded audio descriptions) that are not a requirement.

Please note: All 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.

Beginning Jan 1, 2014 & ongoing through to Jan 1, 2021.
Marketing
Ongoing

PART 3- EMPLOYMENT STANDARDS

ACTION
COMPLIANCE DATE
RESPONSIBILITY
STATUS
Recruitment – General

Every employer shall notify its employees and the public about the availability of accommodation for applicants with disabilities in its recruitment processes.

Action: Harding Display will include a statement in job advertisements and identify different options for where job advertisements may be posted.

January 1, 2016
Human Resources
Ongoing
Recruitment, Assessment, Selection

During a recruitment process, an employer shall 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, the employer shall 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.

Action: Harding Display will receive and update existing recruitment policies, procedures, and processes. Harding Display will determine how to notify applicants – telephone, email, letter, or alternative means that takes into account their need for accommodation. Harding Display will identify barriers in the recruitment process including location of interview room, format of tests (if applicable), room set up for interviewee, interviewing timelines, supports and paperwork. Harding Display will develop interview guidelines that takes into account accommodation for persons with disabilities.

January 1, 2016 & Ongoing
Human Resources
Ongoing
Notice to Successful Applicants

Every employer shall, when making offers of employment, notify the successful applicant of its policies for accommodating employees with disabilities.

Action: Harding Display will include a statement in future employment agreements confirming that Harding Display will support the accessibility needs of its employees.

January 1, 2016
Human Resources
Ongoing
Informing Employees of Supports

Every employer shall inform its employees of its policies used to support its employees with disabilities, including, but not limited to, policies on the provision of job accommodations that take into account an employee‘s accessibility needs due to disability.

Employers shall provide the information required under this section to new employees as soon as practicable after they begin their employment.

Employers shall provide updated information to its employees whenever there is a change to existing policies on the provision of job accommodations that take into account an employee‘s accessibility needs due to disability.

Action: Harding Display will inform current employees and new hires as soon as practicable after they begin employment of policies supporting employees with disabilities. New employees will be provided with accessibility policies and training as a part of onboarding process. Harding Display will keep employees up to date on changes to policies/procedures relating to accommodation.

January 1, 2016
Human Resources
Ongoing
Accessible Formats and Communication Supports for Employees

In addition to its obligations under section 12, where an employee with a disability so requests it, every employer shall consult with the employee to provide or arrange for the provision of accessible formats and communication supports for

(a) information that is needed in order to perform the employee‘s job; and

(b) information that is generally available to employees in the workplace.

The employer shall consult with the employee making the request in determining the suitability of an accessible format or communication support.

Action: Harding Display will conduct an audit of regular communications. Harding Display will make a list of what employees will require, and ensure that their accessibility needs are met through an individualized accessibility plan.

January 1, 2016
Human Resources
Ongoing
Workplace Emergency Response Information

Every employer shall provide individualized workplace emergency response information to employees who have a disability, if the disability is such that the individualized information is necessary and the employer is aware of the need for accommodation due to the employee‘s disability.

If an employee who receives individualized workplace emergency response information requires assistance and with the employee‘s consent, the employer shall provide the workplace emergency response information to the person designated by the employer to provide assistance to the employee.

Employers shall provide the information required under this section as soon as practicable after the employer becomes aware of the need for accommodation due to the employee‘s disability.

Every employer shall review the individualized workplace emergency response information

(a) when the employee moves to a different location in the organization;

(b) when the employee‘s overall accommodations needs or plans are reviewed; and

(c) when the employer reviews its general emergency response policies.


Action: In the event that Harding Display becomes aware of an employee’s disability, the Company will ensure that the employee is provided with information on emergency response protocols that will take into account their individualized requirements. We will review individualized workplace emergency response information every year, or as changes occur (i.e. legislation updates, job transfers, etc.). We will ensure the individualized emergency response information is updated and communicated to affected employees
January 1, 2012
Human Resources
Complete
Documented Individual Accommodation Plans

Employers, other than employers that are small organizations, shall develop and have in place a written process for the development of documented individual accommodation plans for employees with disabilities.

The process for the development of documented individual accommodation plans shall include the following elements:

1. The manner in which an employee requesting accommodation can participate in the development of the individual accommodation plan.

2. The means by which the employee is assessed on an individual basis.

3. The manner in which the employer can request an evaluation by an outside medical or other expert, at the employer‘s expense, to determine if and how accommodation can be achieved.

4. The manner in which the employee can request the participation of a representative from their bargaining agent, where the employee is represented by a bargaining agent, or other representative from the workplace, where the employee is not represented by a bargaining agent, in the development of the accommodation plan.

5. The steps taken to protect the privacy of the employee‘s personal information.

6. The frequency with which the individual accommodation plan will be reviewed and updated and the manner in which it will be done.

7. If an individual accommodation plan is denied, the manner in which the reasons for the denial will be provided to the employee.

8. The means of providing the individual accommodation plan in a format that takes into account the employee‘s accessibility needs due to disability.

Action: Harding Display will develop a written process for implementing accommodation plans for persons with disabilities which includes the above prescribed elements. Harding Display will create a template to document individual accommodation plans when the need arises.

January 1, 2016
Human Resources
Ongoing
Return to Work Process

Every employer, other than an employer that is a small organization

(a) shall develop and have in place a return to work process for its employees who have been absent from work due to a disability and require disability-related accommodations in order to return to work; and

(b) shall document the process.

The return to work process shall

(a) outline the steps the employer will take to facilitate the return to work of employees who were absent because their disability required them to be away from work; and

(b) use individual documented accommodation plans, as described in section 28, as part of the process.

The return to work process referenced in this section does not replace or override any other return to work process created by or under any other statute.

Action: Harding Display will develop a written process for implementing a return to work plan for persons with a disability which incorporates the above prescribed elements. Harding Display will create a template to document the return to work process.

January 1, 2016
Human Resources
Ongoing
Performance Management

An employer that uses performance management in respect of its employees shall take into account the accessibility needs of employees with disabilities, as well as individual accommodation plans, when using its performance management process in respect of employees with disabilities.

Action: Harding Display will review the current Performance Management process. Harding Display will evaluate different options for administering the performance management process to take into account the individual needs of persons with a disability and consider the different methods to provide feedback to employees – on paper, verbally, on-line, etc. If a person with a disability has an Individual Accommodation Plan (IAP), take into account how information needs to be communicated to these individuals.

January 1, 2016
Human Resources
Ongoing
Career Development and Advancement

An employer that provides career development and advancement to its employees shall take into account the accessibility needs of its employees with disabilities as well as any individual accommodation plans, when providing career development and advancement to its employees with disabilities.

Action: Harding Display will review current Succession Plan and Career Development processes.

We will keep IAP’s in mind when making career development and advancement decisions.

January 1, 2016
Human Resources
Ongoing
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.

Action: Harding Display will review current Re-deployment processes to take into account the individual needs of persons with a disability as well as any IAP’s.

January 1, 2016
Human Resources
Ongoing

Part 4- DESIGN OF PUBLIC SPACE STANDARDS

ACTION
COMPLIANCE DATE
RESPONSIBILITY
STATUS

Obtaining Service – Make Service counters, Queuing Guide and Waiting Areas Accessible.

Action: Where practicable, all indoor or outdoor newly constructed service counters and fixed queuing guides and all newly constructed or redeveloped waiting areas will conform to all of the required elements in accordance with the provisions of the IASR

January 1, 2017
Human Resources, Executive Team
Complete
Maintain the Accessible Parts of Our Public Spaces.

Action: Identify preventative and emergency maintenance procedures & alternatives & procedures for handling disruptions and alternatives in accordance with the provisions of the IASR.

January 1, 2017
Human Resources, Executive Team
Ongoing

Make Parking Accessible

Action: Where practicable, new and redeveloped parking areas meet certain technical requirements in accordance with the provisions of the IASR

January 1, 2017
Human Resources, Executive Team
Ongoing

Make Exterior Paths of Travel Accessible.

Action: Where practicable, new and redeveloped exterior paths of travel that are outdoor sidewalks or walkways designed and constructed for pedestrian travel and are intended to serve a functional purpose (includes stairs, ramps, curb ramps, depressed curbs, pedestrian signals, rest areas) and not to provide a recreational experience meet certain technical requirements in accordance with the provisions of the IASR.

January 1, 2017
Human Resources, Executive Team
Ongoing

Harding Display’s accessibility policies (The Customer Service Standard Policy & the Integrated Accessibility Standards Regulation Policy) are available upon request. The policies and the multi-year accessibility plan are available in accessible format, upon request.

FOR MORE INFORMATION, PLEASE CONTACT: 

Melissa McKinley

Phone Number: (416) 754-3215 ext. 338

Email: hr@hardingdisplay.com

In Writing:

150 Dynamic Drive

Scarborough, ON

M1V 5A5

Accessibility Plans

Large organizations shall,

a) establish, implement, maintain and document a multi-year accessibility plan, which outlines the organization‘s strategy to prevent and remove barriers and meet its requirements under this Regulation;

b) post the accessibility plan on their website, if any, and provide the plan in an accessible format upon request; and

c) review and update the accessibility plan at least once every five years.

Action: Accessibility plan completed. HR and management to identify barriers in the workplace on an ongoing basis. HR will review the plan periodically and make changes as needed.