Accessibility

Multi-Year Accessibility Plan

Policy No.:  HR-3.0
Effective Date: December 1, 2023

Approved By: IS - President | JW - Human Resources

1.0 Purpose and Statement of Commitment

This accessibility plan outlines the policies and actions that The Williams Brothers and Strike First Co. (hereinafter referred to as “the Company”) has put in place to improve opportunities for people with disabilities. The Company 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 people with disabilities in a timely manner and will do so by preventing and removing barriers to accessibility and meeting accessibility requirements under the Accessibility for Ontarians with Disabilities Act (AODA).

Under the AODA and the Integrated Accessibility Standards Regulation (IASR), the following accessibility standards set the requirements that are applicable to the Company:

  • Customer Service;
  • Information and Communications;
  • Employment; and Design of Public Spaces.

2.0 General Requirements

The Company is committed to continuing to comply with all general requirements set out by the AODA and the IASR. This includes the requirement to develop, implement, and maintain written policies and procedures; and the requirement to train all employees, volunteers, and other members of the company on the requirements of the accessibility standards set out in the IASR and in the Ontario Human Rights Code as it relates to persons with disabilities.

Actions:

  • The Company has developed, implemented, and maintained an Accessibility Policy (HR-4.0 Accessibility Standards for Customer Service). The Policy is reviewed and updated annually. The Policy is posted on our website(s) and is available in an accessible format, upon request.
  • The Company has developed, implemented, and maintained a Multi-Year Accessibility Plan (HR-3.0). The Plan is reviewed and updated at least every five (5) years. The Plan is posted on our website(s) and is available in an accessible format, upon request.
  • The Company has trained and will continue to train all employees and other members of the organization on Ontario’s accessibility laws, the Ontario Human Rights Code as it relates to people with disabilities, and the accessibility requirements that apply to the Company. Training is provided in a way that best suits the duties of employees. Training records are maintained by the Company. The training is facilitated as follows:
    • New Hire Orientation Program.
    • Refresher Training is completed every two (2) years.

3.0 Customer Service Standard

The Company strives at all times to provide our goods and services in a way that respects the dignity and independence of people with disabilities. We are committed to giving people with disabilities the same opportunity to access the Company’s goods and services and allowing them to benefit from the same services, in the same place and in a similar way as other customers.

Actions:

  • The Company has met and continues to meet all requirements of the Customer Service Standard, including the establishment of policies related to the use of service animals and support persons; notice of temporary service disruptions; training employees; providing documents in an accessible format or with communication supports upon request; and establishing a feedback process.
  • The detailed Customer Service Standard policy and procedure (HR-4.0 Accessibility Standards for Customer Service) is posted on our website(s) and is available in an accessible format, upon request.

4.0 Information and communications Standard

The Company is committed to meeting the communication needs of people with disabilities. We will consult with people with disabilities to determine their information and communication needs.

Website

The Company has met the website requirements of WCAG 2.0, Level AA. All new content on our website(s) will continue to be reviewed regarding the requirements of WCAG 2.0, Level AA.

Accessible Formats and Communication Supports

The Company has taken and will continue to take steps to make sure all publicly available information is made accessible upon request. Where a request for an accessible format or communication support is received, we will:

  • Consult with the individual making the request to determine their accessibility needs and what would be a suitable format or support.
  • Provide the requested information in a timely manner.

Accessible Emergency Information

The Company will continue to provide contractors, 3rd parties or any members of the public with publicly available emergency information in an accessible format, upon request.

Feedback Processes

The Company is committed to ensuring our feedback processes are accessible to people with disabilities by offering various methods of providing feedback, i.e., email, phone, through our website(s), etc., and will provide our feedback process in an accessible format, upon request. Please refer to HR-4.0 Accessibility Standards for Customer Service Policy which details the feedback process and the designated individual responsible for receiving the feedback.

5.0 Employment Standard

The Company is committed to fair and accessible employment practices that attract and retain employees with disabilities. This includes providing accessibility across all stages of the employment cycle.

  • Accessible recruitment and selection processes: 
    • The Company notifies candidates that accommodations are available upon request by including accommodation statements in all job ads posted; when contacting candidates to schedule interviews; and in offers of employment sent to prospective employees.
  • Accessible formats and communication supports:
    • The Company’s Employee Handbook contains a Communication Systems Policy that notifies employees that we will provide accessible formats and communication supports, upon request.
  • Workplace emergency response information:
    • The Company is committed to providing employees with emergency information in an accessible format, upon request.
    • The Company’s Employee Handbook includes a Workplace Accommodation Policy that states that we will provide individualized workplace emergency response information to employees, in an accessible format, upon request.
    • Upon hire, all employees are required to complete the Employee Emergency Information Form, and when necessary, the Company will develop an individualized emergency response plan, if requested.
  • Documented individual accommodation plans:
    • The Company’s Employee Handbook includes a Workplace Accommodation Policy that notifies employees of our individual accommodation plan process.
  • Performance management, career development, and advancement:
    • The Company’s Employee Handbook includes a Performance Management Policy that notifies employees that accommodations are available when required per our individual accommodation plan process.
  • Return to work process:
    • The Company’s Employee Handbook includes a Workplace Accommodation Policy that notifies employees of our individual accommodation plan process for employees returning to work and requiring accommodations.

Actions:

All policies have been documented in the Employee Handbook and have been implemented.

6.0 Design of Public Spaces Standard

The Company will meet the Accessibility Standards for the Design of Public Spaces when building or making major modifications to public spaces. The Company has not built or made major modifications to our facility, however, will meet these standards in the future, if required.

7.0 Additional Information

This policy will be reviewed at least every five (5) years, and the Company will continue to file the Accessibility Compliance Reports.

For more information on this accessibility plan, please contact Jennifer Williams, H.R. Director at:

Accessible formats of this document are available upon request from: Jennifer Williams, H.R. Director.

Accessibility Standards for Customer Service

Policy No.:  HR-4.0
Effective Date: December 1, 2023

Approved By: IS - President | JW - Human Resources

1.0 Purpose

The purpose of this policy is to develop, implement, and enforce accessibility standards in order to achieve accessibility for persons with disabilities with respect to goods and services.

2.0 Scope

This policy has been developed in accordance with the Accessibility for Ontarians with Disabilities Act, 2005, S.O. 2005, c. 11 and the Ontario Regulation, O. Reg. 191/11: INTEGRATED ACCESSIBILITY STANDARDS and the provisions of the Ontario Human Rights Code.

All legislated changes impacting this policy will be reflected in The Williams Brothers and Strike First Co. (hereinafter referred to as “the Company”) policy through updates, on an ongoing basis.  The policy will be reviewed annually in accordance with applicable legislation. No changes will be made to this policy before considering the impact on people with disabilities.

This policy applies to all employees and any other member of the Company.

Our Commitment

The Company is committed to excellence in serving all people with disabilities. We strive to provide our goods, services and facilities in a respectful and accessible manner to all customers, including persons with disabilities. Persons with disabilities will benefit from the same services, in the same place, in a similar way, as other customers. It is the commitment of the Company to provide equitable treatment, with respect to providing our goods and services without discrimination in accordance with the Accessibility for Ontarians with Disabilities Act, 2005, S.O. 2005, c. 11 and the Ontario Regulation, O. Reg. 191/11: INTEGRATED ACCESSIBILITY STANDARDS and the provisions of the Ontario Human Rights Code.

When providing our goods and services to a person with a disability, we are committed to the following four core principles:

  • Dignity – Service is provided in a way that allows the person with a disability to maintain self-respect and the respect of other people. People with disabilities are not treated as an afterthought or forced to accept lesser service, quality, or convenience.
  • Independence – Allowing a person with a disability to do things on their own without unnecessary help, or interference from others.
  • Integration – Service is provided in a way that allows the person with a disability to benefit from the same services, in the same place, and in the same or similar way as other customers, unless an alternate measure is necessary to enable the person to access goods or services.

Equal Opportunity – People with disabilities have an opportunity equal to that given to others to access our goods and services.

3.0 Responsibilities

3.1 The President and the H.R. Director are responsible to:

  • Be knowledgeable of all related legislation
  • Provide training to all employees and other members of the organization
  • Establish a process for individuals to provide feedback on how goods or services are provided to people with disabilities and outline how the Company will respond and take action. This feedback process must be accessible, and the Company will provide or arrange accessible formats and communication supports, upon request
  • Ensure policies, practices, and procedures are consistent with core principles of the standard

3.2 Employees and other members of the Company are responsible for and must do the following:

  • Comply with this policy
  • Attend training

4.0 Definitions

4.1 Disability (as per the Ontario Human Rights Code)

  1. any degree of physical disability, infirmity, malformation or disfigurement that is caused by bodily injury, birth defect or illness and, without limiting the generality of the foregoing, includes diabetes mellitus, epilepsy, a brain injury, any degree of paralysis, amputation, lack of physical co-ordination, blindness or visual impediment, deafness or hearing impediment, muteness or speech impediment, or physical reliance on a guide dog or other animal or on a wheelchair or other remedial appliance or device,
  2. a condition of mental impairment or a developmental disability,
  3. a learning disability, or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language,
  4. a mental disorder, or
  5. an injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997; (“handicap”)

4.2 Customers
People who receive goods or services from the Company.

4.3 Persons with Disabilities
Individuals who have a disability as defined under the Ontario Human Rights Code.

4.4 Barrier
Anything that prevents a person with a disability from fully participating in all aspects of society because of their disability, including a physical barrier, an architectural barrier, an information or communications barrier, an attitudinal barrier, a technological barrier, a policy, or practice.

4.5 Accessibility
Accessibility is the degree to which a product, device, service, environment, or facility is usable by as many people as possible, including persons with disabilities.

4.6 Goods and Services
The goods and services provided by the Company.

4.7 Assistive Device
A device used to assist a person with a disability in carrying out activities or in accessing the services of persons or organizations covered by the customer service standard. (i.e., canes, hearing aids, wheelchairs, etc.)

4.8 Support Person
A support person is an individual hired or chosen by a person with a disability to accompany them in order to help with communication, mobility, personal care, medical needs, or with access to goods or services.

4.9 Service Animal
A service animal is an animal for a person with a disability:

  • If it is readily apparent that the animal is used by the person for reasons relating to their disability; or
  • If the person provides a letter from a physician or nurse, or a regulated health professional (including psychologists, psychotherapists, audiologists, chiropractors, and optometrists) confirming that the person requires the animal for reasons relating to the disability

4.10 Guide Dog
A dog trained as a guide for a blind person and has the qualifications prescribed by the regulations of the Blind Persons’ Rights Act.

5.0 Procedures

Communication

5.1 We will communicate with people with disabilities, to the best of our ability, in ways that take into account their disability and offer communication methods that are suitable to their communication needs (i.e., email, telephone, or in-person, etc.).

5.2 If a person with a disability requiring a wheelchair enters our premises and they require assistance, an employee is required to come out to greet them. If an extended visit is required, suitable meeting accommodation will be arranged and the employee scheduling the meeting is required to take into consideration the person’s disability when making these arrangements.

5.3 Information provided on our company website(s) and promotional marketing materials will be offered in alternative formats, upon request, (i.e., small print vs. large print, offering an in-person meeting to review and read materials or website information if requested, etc.).

5.4 All employees will be educated and trained on how to address and communicate effectively and appropriately with customers with disabilities.

Use of Guide Dogs and Service Animals

5.5 We are committed to welcoming persons with disabilities accompanied by their guide dog or service animal in those areas of the company premises that are open to the public and other third parties, unless the animal is otherwise excluded by another law. If a service animal is excluded by law, we will use other measures to provide services to the person with a disability.

5.6 The Company is permitted to ask for proof that the animal is a service animal. The person with a disability is required to provide a letter from a physician or nurse, or a regulated health professional (including psychologists, psychotherapists, audiologists, speech pathologists, chiropractors, occupational therapists, optometrists, registered psychotherapists, and mental health therapists) confirming that the person requires the animal for reasons relating to the disability.

5.7 All employees and other members of the organization will be trained on the different types of service animals, as well as how to properly interact with those using service animals.

Support Persons

5.8 We are committed to welcoming persons with disabilities who are accompanied by a support person. A person with a disability who is accompanied by a support person will be allowed to have that person accompany them in those areas of the company premises that are open to the public and other third parties.

In certain cases, the Company may require a person with a disability to be accompanied by a support person for health and safety reasons.  Before making this decision, the Company will:

  • Consult with the person with a disability to understand their needs
  • Consider health or safety reasons based on available evidence
  • Determine if there is no other reasonable way to protect the health or safety of the person or others on the premises

In such a situation, admission fees or fares (if applicable) will be waived for the support person.  At no time will a person with a disability who is accompanied by a support person be prevented from having access to their support person while on our premises. 

Assistive Devices

5.9 We are committed to serving people with disabilities who use assistive devices to obtain, use or benefit from our goods and services. We will ensure employees and other members of the organization are trained on and familiar with various assistive devices that may be used by customers with disabilities while accessing our goods and services.

5.10 Persons with disabilities shall be permitted to obtain, use, or benefit from our goods and services through the use of their assistive devices.

5.11 It is the responsibility of the person with a disability to ensure that their own assistive device is operated in a safe manner at all times.

5.12 All employees and other members of the organization will be trained as required about assistive devices and the Company will maintain accurate records of training delivered. These records will be made available upon inspection as may be required.

Notice of Temporary Disruption to Facilities or Services

5.13 We will provide notice when facilities or services that people with disabilities rely on to access or use goods or services are temporarily disrupted. The notice will be placed in a conspicuous place in areas open to the public or third parties. The notice will include the reason for the disruption, its anticipated duration, and a description of alternative facilities or services, if available.

Feedback Process

5.14 People with disabilities who wish to provide feedback on the way the Company provides accessibility to our premises and/or general communication are encouraged to do so. Comments and feedback can be submitted:

  • By email to Jennifer Williams, H.R. Director at:
  • By phone to Jennifer Williams, H.R. Director at: (416) 299-7767
  • By using the Contact Us Form found on our website at: https://www.strike-first.com/contact/

5.15 All feedback, including complaints, will be handled by the H.R. Director and will respond back within one week of receiving the feedback. The H.R. Director will ensure that our feedback process is accessible by providing or arranging for accessible formats and communication supports, if requested.

Training

5.16 Upon hire, the Company will provide training to all employees and other members of the organization on providing accessible customer service and how to interact with people with various types of disabilities. Employees will complete refresher training every two (2) years. The Company will maintain accurate records of training delivered. These records will be made available upon inspection as may be required.

6.0 Communication

This policy standard will be communicated as follows: 

  • During new hire orientation  
  • In the Employee Handbook

7.0 References, Associated Documents, and Forms

Accessibility for Ontarians with Disabilities Act, 2005, S.O. 2005, c. 11
O. Reg. 191/11: INTEGRATED ACCESSIBILITY STANDARDS
Ontario Human Rights Code

LEGAL | ACCESSIBILITY | © 2024 The Williams Brothers Corporation.