Multi-Year Accessibility Plan

Northern Reflections - Multi-Year Accessibility Plan

Accessibility Standards – Statement of Commitment

Northern Reflections is committed to providing a barrier-free environment for our Customers, Vendors and Associates who enter our premises, and access our information. As an organization, we respect and uphold the requirements set forth under the Accessibility of Ontarians with Disabilities Act, Customer Service Standard and the Integrated Accessibility Standards Regulations for Information and Communication, Employment and Transportation, and eventually, Built Environment.

Northern Reflections has an important responsibility for ensuring a safe, dignified and welcoming environment for everyone. We are committed to ensuring compliance with accessibility legislation by incorporating policies, procedures, equipment requirements, training for Associates and best practices. We will review these policies and practices on a regular basis. Our commitment to making our organization accessible to everyone includes the integration of accessibility legislation with our policies, procedures, programs and training.

Accessibility for Ontarians with Disabilities Act, 2005 (“AODA”)

The AODA develops, implements and enforces accessibility standards so that goods, services, facilities, accommodation, employment, buildings, structures and premises are accessible to persons with disabilities. The AODA intends to achieve an accessible Ontario by January 1, 2025. To do so, mandatory and enforceable standards have been implemented.

The Standards include:

A) Customer Service Standard – Ontario Regulation 429/07

The Customer Service Standard ensures that people with disabilities can receive goods and services in a manner that takes into account one’s disability.

Requirements include development of a policy, practices, procedures and the provision of training for Associates.

Northern Reflections submitted compliance reports to the Province indicating we had addressed the requirements of the Regulation and are meeting the compliance obligation. We will continue to ensure compliance with the Customer Service Standard.

We developed feedback processes to respond to inquiries and suggestions received by phone, email, mail or in person. This has been communicated to internal and external stakeholders.

B) Integrated Accessibility Standard Regulation (“IASR”) – Ontario Regulation 191/11

The IASR brings together the following standard areas in one Regulation: Information and Communication, Employment, Built Environment and Transportation. (The Transportation Standard does not apply to Northern.) General requirements common to all standard areas include policy development and training (on the requirements of the IASR and the Ontario Human Rights Code). There is also a requirement to ensure that accessibility features are considered in the kiosk procurement process.

The requirements have staggered compliance dates up to the year 2021.

Northern Reflections Multi-Year Accessibility Plan

Part 1 – General

This section of the Regulation requires us to:

develop & maintain an accessibility policy and a multi-year accessibility plan
self-service kiosks – consider accessibility features that best meet the needs of customers
ensure staff and volunteers are trained on the Integrated Accessibility Standards Regulation and the Ontario Human Rights Code

Action	Responsibility	Compliance Date
Accessibility Policies Develop and implement Integrated Accessibility Standards Policy Make the Policy publicly available in an accessible format, upon request Review and update as required	Human Resources, Marketing, IT	January 1, 2014
Develop a Multi-Year Accessibility Plan Create a multi-year accessibility plan Post multi-year accessibility plan on our website and provide in an accessible format, upon request Review and update the plan at least once every five years	Project Team IT	January 1, 2014 January 1, 2019
Self-Service Kiosks Currently, we do not have self-service Kiosks Should we consider this in the future, Real Estate procurement processes will be enhanced with accessibility compliance expectations	Real Estate, Marketing	January 1, 2014
Training Develop and implement training materials for IASR and the Human Rights Code Update training as required Keep a record of the individuals who received the training	Human Resources	January 1, 2015

Part 2 – Information and Communications Standards

This section of the Regulation includes requirements related to:

Accessible website and web content
accessible feedback processes
accessible formats and communication supports
publically available emergency procedures, plans, public safety information

Action	Responsibility	Compliance Date
Accessible Websites and Web Content Review current internet website and conform to WCAG version 2.0 Level A Ensure that all websites comply with WCAG 2.0 Level AA by 2021	Marketing, IT	January 1, 2014 December 31, 2020
Feedback Processes Ensure that processes for receiving and responding to feedback are accessible and meet the requirements of the IASR. (Email, verbal, written)	Marketing, IT, Store Operations	January 1, 2015
Accessible Formats and Communication Support Upon request, provide or arrange for the provision of accessible formats and communication supports for person with disabilities Consult with the person making the request to determine suitability Notify the public about the availability of accessible formats and communications support	Marketing, IT, Store Operations	January 1, 2016
Accessible Emergency Information Provide Customers with publicly available emergency information in an accessible way upon request Upon request, Associates with disabilities will be provided an individualized emergency response plan and/or can reference our Emergency Response Plan Policy in the HR Manual	Marketing, IT, Human Resources	January 1, 2012

Part 3 – Employment Standards

This section of the Regulation includes requirements related to:

workplace emergency response
recruitment, assessment and selection
informing Associates of support
accessible formats and communication supports for Associates
individual accommodation plans and return to work processes
performance management, career development and redeployment

Action	Responsibility	Compliance Date
Workplace Emergency Response Information Upon request, Associates with disabilities will be provided an individualized emergency response plan and/or can reference our Emergency Response Plan Policy in the HR Manual	Human Resources	January 1, 2012
Recruitment, Assessment and Selection Review and update existing recruitment policies, procedures and processes Specify that accommodation is available for applicants with disabilities on the website and on job postings Inform applicants about the availability of accommodation If selected applicant requests accommodation, consult with the applicant and arrange the provisions	Human Resources	January 1, 2016
Informing Associates of Support Communication will be sent to all Associates notifying them of policies supporting Associates with disabilities	Human Resources	January 1, 2016
Accessible formats and communication supports for Associates Upon request by an Associate with a disability, Northern shall consult with the Associate and provide or arrange for the provision of suitable accessible formats and communication support needed to perform the job	Human Resources	January 1, 2016
Documented individual accommodation plans/return to work process Create a written process for the development of documented individual accommodation plans and return to work plans for Associates with disabilities Include in the process and plans all the required elements in accordance with the provisions of the IASR	Human Resources	January 1, 2016
Performance management, career development, advancement and redeployment Review and update existing policies to ensure compliance with IASR Take the accessibility needs of Associates with disabilities and if applicable individual accommodation plans, into account as part of performance management processes when assessing performance, providing career development and advancement opportunities and considering redeployment	Human Resources	January 1, 2016

Part 4 – Design of Public Space Standards

This section of the Regulation includes requirements related to:

recreational trails and beach access routes (N/A)
outdoor public use eating areas & outdoor play spaces (N/A)
exterior paths of travel (N/A)
parking (N/A)
obtaining service
maintenance

Action

Responsibility

Compliance Date

Obtaining Service

Where practicable, all newly constructed service counters will conform to all of the required elements in accordance with the provisions of the IASR

Real Estate

January 1, 2017

Maintenance

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

Real Estate, Store Operations

January 1, 2017