MULTI-YEAR ACCESSIBILITY PLAN

Standards Sections and Obligations Deadline Actions Taken Status Responsibility
General Establishment of Accessibility Policies
Section 3:
“Every obligated organization shall develop, implement and maintain policies governing how the organization achieves accessibility through meeting its requirements referred to in this Regulation.”

Accessibility Plans

Section 4: “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.”

January 1, 2014 Dye & Durham has developed its Accessibility policy and Multi-year Accessibility plan in line with regulations.

Dye & Durham has also established an AODA Project team that will meet annually to review the Accessibility Policies to ensure they continue to provide sufficient procedures/practices for removing barriers with Dye & Durham products, services and within its workplace.

Compliant Human Resources department

AODA Project Team

General Training
Section 7:
“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.”
January 1, 2015 Dye & Durham will source training vendors and a platform to deliver training to employees, volunteers and contractors.

Implement an annual training program for all employees and contractors.

We are updating our onboarding procedures to develop a checklist for all new and existing hires providing customer focused services on

Ongoing Human Resources department
Information and Communication Feedback
Section 11: ”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 the provision of accessible formats and communications supports, upon request.”
January 1, 2015 Feedback process for customers established and posted to our product sites and this is tracked by our marketing department.

Process updated to create unique phone/email for improved tracking of questions/requests and consistent responses/actions.

This Process is reviewed annually based on changes to internal workflows.

Compliant Marketing and I.T. Department
Information and Communication Accessible Formats and Communication Supports
Section 12. (1) 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.
January 1, 2016 Dye & Durham provides accessible formats and communication supports for persons with disabilities upon request. Compliant Human Resources and I.T. Department
Information and Communication Emergency Procedure, Plans Or Public Safety Information
Section 13. (1) 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.”
January 1, 2012 Dye & Durham will make available any updated emergency procedure, plans or public safety information in an accessible format upon request. Ongoing Human Resources
Information and Communication Accessible Websites and Web Content
Section 14(2) 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
January 1, 2014
new internet websites and web content on those sites must conform with WCAG 2.0 Level A

January 1, 2021, all internet websites and web content must conform with WCAG 2.0 Level AA, other than,
i. success criteria 1.2.4 Captions (Live), and ii. success criteria 1.2.5 Audio Descriptions (Pre-recorded).

Efforts to make our websites and content meet AODA and WCAG 2.0 guidelines to improve accessibility are ongoing, and we will make every effort to incorporate accessibility features where possible and practical into new material added to our online products and websites.

We are carrying out the following activities to meet compliance requirements:

• Conducting thorough annual accessibility audits (including automated and manual scans) to assess existing level of accessibility for websites/online products and determine approach to implement WCAG 2.0 Guidelines for new products/content introduced after January 1, 2014.
• Incorporating AODA success criteria as part of design specifications and product requirements for all products to be launched after January 1, 2021 as part of the conception process.
• AODA compliance requirements incorporated into roles/responsibilities and expectations for employees in product development, marketing, IT, content/editorial.
• As new external websites are designed, or as existing external websites are reviewed for redesign/relaunch, WCAG 2.0 guidelines will be incorporated where practicable.
• We include contractual provisions in all supplier contracts for upgrades and contents to our public facing websites to ensure services provided conform to AODA requirements.

Ongoing Product/
Marketing/
I.T.
Employment Recruitment, Assessment or Selection Process
(Notification of candidates and employees of policies for accommodating employees with disabilities)
23. (1) 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.

Section 24-Every employer shall, when making offers of employment, notify the successful applicant of its policies on accommodation.

Section 25- “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.

January 1, 2016 Standard accommodation statement included in all Dye & Durham job postings to make applicants (internal/external) aware that in accordance with AODA accommodation is available. Compliant Human Resources
Employment Workplace Emergency Response Information
27. (1) 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.

(2) 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.

January 1, 2012 Where we have been informed 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.

Individualized emergency response plans are maintained in HR and are:
• Communicated to the employee’s manager, where the employee’s consent has been obtained, and on an as needed basis.
• Reviewed and assessed on an ongoing and regular basis to ensure that accessibility issues are addressed.

We will appoint a Floor Warden as part of our Health and Safety Committee whose responsibility will be to implement our Health and Safety Plan and ensure that during emergency situations, persons with disabilities are not left behind.

Compliant Human Resources
Employment Documented Individual Accommodation Plans
28. (1) 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.

(2) 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 assist the employer in determining if accommodation can be achieved and, if so, 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.

January 1, 2012 Our current process is compliant with these requirements.

We have created an easily accessible Accommodation Request form posted to our intranet site where employees with disabilities can confidentially request for accommodation

Ongoing Human Resources
Employment Return to Work
29. (1) 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.
(2) 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 documented individual accommodation plans, as described in section 28, as part of the process.
Performance Management

30. (1) 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.

January 1, 2016 Dye & Durham will take into account 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 when redeploying employees.

We will continue to review our current process and update if required.

Ongoing Human Resources
Employment Career Development and Advancement
31. (1) 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.
January 1, 2016 Dye & Durham will take into account 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 when redeploying employees.

We will continue to review our current process and update if required.

Compliant Human Resources
Employment Redeployment
32. (1) 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.
January 1, 2016 Dye & Durham will take into account 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 when redeploying employees.

We will continue to review our current process and update if required

Compliant Human Resources