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SIMONS - ACCESSIBILITY POLICY PURPOSE

We are committed to meeting the accessibility needs of people with disabilities in a manner that is consistent with the principles of independence, dignity, integration and equal opportunity for people with disabilities. The purpose of this Policy is to communicate our approach with respect to promoting an accessible environment and removing barriers to accessibility for people with disabilities and to continue to improve accessibility to persons with disabilities in our facilities, policies and processes.

POLICY

We have established this Accessibility Policy (the “Policy”) and an Accessibility Standards for Customer Service Policy to promote an accessible environment and remove barriers to accessibility for people with disabilities and to meet our obligations under Regulation 191/11, “Integrated Accessibility Standards” (the “Regulation”) under the AODA. Our vision for accessibility is that people with disabilities, visible or invisible, are given the same opportunity as others to obtain and benefit from services offered by us. Our goal is to make reasonable efforts to provide services in such a way that the key principles of independence, dignity, integration and equality of opportunity for persons with disabilities are respected. We welcome and encourage all members of our community to collaborate and provide creative input in future initiatives for accessibility.

Application
The Policy applies to every person who provides goods or services to customers of the public and third parties in Ontario on our behalf, whether that person does so as an employee, independent contractor, agent, volunteer, or otherwise. The Policy also applies to every person involved in the development of policies, procedures and practices pertaining to the provision of our goods and services to customers.

PROCEDURES

Multi-Year Accessibility Plan
Our Multi-Year Accessibility Plan outlines our strategies for preventing and removing barriers and meeting our requirements under the AODA regulations. We will post the plan on our website and will provide it in an accessible format upon request. The plan will be reviewed and updated at least once every five years.

Training
We will ensure that training is provided as required to all employees and volunteers, and all persons who participate in developing corporate policies, on the requirements of the accessibility standards referred to in the Regulation and in respect of the Human Rights Code as it pertains to persons with disabilities. Training will be provided as soon as practicable. If any changes are made to this Policy or the requirements, training will be provided to include those changes. We will ensure that others that provide goods, services or facilities on behalf of the company have had training.

INFORMATION AND COMMUNICATION STANDARDS

Feedback Process
We will ensure that our processes for receiving and responding to feedback are accessible to persons with disabilities by providing or arranging for the provision of accessible formats and with communication supports upon request. We will notify the public about the availability of accessible formats and communication supports.

Accessible Format and Communication Support
We will, upon request, provide or arrange for accessible formats and communication supports for persons with disabilities in accordance with the Regulation as follows:
1. In a timely manner that takes into account the person's accessibility needs due to a disability;
2. At a cost that is no more than the regular cost charged to other persons; and,
3. In consultation with the person making the request to determine suitability of an accessible format
  or communication support.
We will notify the public about the availability of accessible formats and communication supports.

Unconvertible Information or Communications
If we determine that information or communications are unconvertible, we will provide the person requesting the information or communication with:
1. An explanation as to why the information or communications are unconvertible; and
2. A summary of the unconvertible information or communications.
Information or communications are unconvertible if:
1. It is not technically feasible to convert the information or communications; or
2. The technology to convert the information or communications is not readily available.

Emergency Information
If we prepare emergency procedures, plans or public safety information and make the information available to the public, we will provide the information in an accessible format or with appropriate communication supports, as soon as practicable, upon request.

Website Accessibility
Where practicable, and to the extent required by the Regulation, we will make any new internet website and web content on those sites conform with the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0 Level A and Level AA. By December 31, 2022 all internet websites and web content backdated to 2012 will conform with WCAG 2.0 Level AA.

Training Resources and Materials
We will provide training resources or materials in an accessible format that takes into account the accessibility needs of the person with a disability to whom the materials are being provided by:
1. Procuring through purchase or obtaining by other means an accessible or conversion ready electronic format,
  where available; or
2. Arranging for the provision of a comparable resource in an accessible or conversion ready electronic format, if educational
  or training resources of materials cannot be procured.
We will provide information on program requirements, availability and descriptions in an accessible format to persons with disabilities.

Training to Educators
We will provide educators (those involved in program or course design delivery and instruction) with accessibility awareness training related to accessible program course delivery and instruction. We will keep a record of training, including dates will be provided and the number of individuals to whom it is provided.

AODA Employment Standards
We will comply with the requirements of the Employment Standards in the Regulation. The Employment Standards apply in respect of employees, and not volunteers or other non-paid individuals.

Recruitment
We will notify employees and the public about the availability of accommodations for applicants and employees with disabilities as follows:
1. In our recruitment processes;
2. During the recruitment process, when job applicants are individually selected to participate in an assessment or selection
  process. If a selected applicant requests an accommodation, we will 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;
3. If a selected applicant requests an accommodation, we will 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; and
4. When making offers of employment to a successful applicant. The successful applicant will also be notified of our policies
  for accommodating employees with disabilities.
If a selected applicant requests an accommodation, we will 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.

Employee Notification
We will inform our employees of our policies used to support 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 a disability. Such information will be provided as follows:
1. To new employees as soon as practicable after they begin their employment;
2. To existing 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 a disability.

Accessible Formats and Communication Supports
Upon request by an employee with a disability, we will consult with the employee to provide or arrange for the provision of accessible formats and communication supports for:
1. Information that is needed in order to perform the employee's job; and
2. Information that is generally available to employees in the workplace.
We will consult with the employee making the request in determining the suitability of an accessible format or communication support.

Individual Accommodation Plans (IAP)
We will develop and have in place a written process for developing a documented individual accommodation plan for employees with a disability. The process will 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.

Return to Work
We will have in place a return to work process for employees who have been absent from work due to a disability and require disability-related accommodation in order to return to work. Such processes shall be documented and must outline the steps that we will take to facilitate the return to work and include an individual accommodation plan.

Performance Management, Career Development and Advancement and Redeployment
Performance management processes related to assessing and improving employee performance, productivity and effectiveness will take into account the accessibility needs of employees with disabilities, as well as individual accommodation plans.
We will take into account the accessibility needs of our employees with disabilities as well as any individual accommodation plans when providing career development and advancement to our employees. Career development and advancement includes providing additional responsibilities within an employee's current position, the movement of an employee from one job to another which may provide greater responsibility and/or compensation, and/or which places the employee at a higher level in the company or any combination of these.
If we need to reassign employees to other departments or jobs within the company as a result of job elimination, we will take into account the accessibility needs of employees with disabilities as well as individual accommodation plans.

Workplace Emergency Response Information
We will provide individualized workplace emergency response information to employees who have a disability, if the disability is such that the individualized information is necessary and that we are aware of the need for accommodation due to the employee's disability. If the employee who receives individual workplace emergency response information requires assistance, and with the employee's consent, we will provide the workplace emergency information to a person designated by us to provide assistance to the employee.
This will be done as soon as practicable after we become aware of the need for accommodation due to the employee's disability. We will review the individualized workplace emergency response information when the employee moves to a different location in the company, when overall accommodation needs or plans are reviewed and when we review our general emergency response policies.

Design of Public Spaces
We will meet the Accessibility Standards for the Design of Public Spaces when building or redeveloping public spaces. Public spaces include, but are not limited to, outdoor public eating areas, outdoor paths of travel, accessible off-street parking and service-related elements such as counters and waiting areas. If we have accessible elements in public spaces, we will develop procedures for preventive and emergency maintenance of those accessible elements, as required by the Regulation. We will also develop procedures for dealing with temporary disruptions of accessible elements as required by the Regulation, should we ever have accessible elements in the future.

Posting/Availability
This Policy is available to the public and will be provided in an accessible format upon request.

Questions
If anyone has questions about this Policy or accessibility plan, or requires this information in an accessible format, please contact us through the following methods:
a) Speaking with a Store Director
b) Contacting Simons
  Telephone: 1-877-666-1840
  Email:   [email protected]
  Mail:      La Maison Simons Inc.
           Customer Service
           9205, rue John-Simons
           Québec QC G2B 0S6

DEFINITIONS
Accessible Formats may include, but are not limited to, large print, recorded audio and electronic formats, Braille and other formats usable by persons with disabilities.
Communications means the interaction between two or more persons or entities, or any combination of them, where information is provided, sent or received.
Communication Supports may include, but are not limited to, captioning, alternative and augmentative communication supports, plain language, sign language and other supports that
facilitate effective communications.
Information includes data, facts and knowledge that exists in any format, including text, audio, digital or images and that conveys meaning.
Redeployment means the reassignment of employees to other departments or jobs within the organization as an alternative to layoff, when a particular job or department has been eliminated.
Unconvertible means if it is not technically feasible to convert the information or communications. It also means if the technology to convert the information or communications is not readily available.

RESOURCES
Integrated Accessibility Standards–Multi Year Plan
Accessibility Policy–Integrated Accessibility Standards
Accessibility Standards–for Customer Service

Simons Accessibility – Customer Service Policy
We are committed to meeting the accessibility needs of people with disabilities in a manner that is consistent with the principles of independence, dignity, integration and equal opportunity for people with disabilities. The purpose of this Policy is to communicate our approach with respect to promoting an accessible environment and removing barriers to accessibility for people with disabilities.

The Accessibility for Ontarians with Disabilities Act and our Commitment
The Accessibility for Ontarians with Disabilities Act, 2005 (“AODA”) is an Ontario law that was created to develop, implement and enforce accessibility standards in order to achieve accessibility for Ontarians with disabilities. The integration of the AODA customer service standards into our stores and workplaces will bolster our continued commitment to meeting the accessibility needs of our customers and employees with disabilities.

Application and Scope
The Policy applies to every person who provides goods or services to customers of the public and third parties in Ontario on our behalf, whether that person does so as an employee, independent contractor, agent, volunteer, or otherwise. The Policy also applies to every person involved in the development of policies, procedures and practices pertaining to the provision of our goods and services to customers.

Providing Goods and Services to Ontarians with Disabilities
We are committed to using reasonable efforts to:
a) Provide goods and services in a manner that respects the dignity and independence of persons with disabilities;
b) Provide goods and services in a manner that enables a person with a disability to obtain, use or benefit from our goods
  and services; and
c) Provide persons with disabilities with an opportunity equal to that given to others to obtain, use and benefit from
  our goods and services.

Communications
When communicating with a person with a disability, we are committed to doing so in a manner that takes into account the person's disability.

Assistive Devices
We welcome the use of assistive devices by persons with disabilities in order to obtain, use or benefit from our goods and services. Some examples of assistive devices are canes, walkers, wheelchairs, and oxygen tanks.

Service Animals
We welcome people with disabilities and their service animals.
a) An animal is a service animal for a person with disability:
   If it is readily apparent that the animal is used by the person for reasons relating to his or her disability; or,
   If the person provides a letter from a physician or nurse confirming that the person requires the animal
     for reasons relating to the disability.
b) People with disabilities are allowed to use their service animals in the parts of our stores that are open to the public
  or to third parties, unless the animal is otherwise excluded by law from the stores.
c) If a service animal is excluded by law from our stores, then we will ensure that other measures are available to enable
  the person with a disability to obtain, use or benefit from our goods and services.
d) Service animals must be in the care and control of the individual at all times.

Support Persons
We welcome people with disabilities and their support persons.
a) A support person is a person who accompanies a person with a disability in order to help with communication, mobility,
  personal care or medical needs, or with access to goods or services.
b) Any person with a disability who is accompanied by a support person is permitted to access our stores in the same way
  as any other customer.

Notice of Temporary Disruption
In the event of a planned or unexpected disruption to services or facilities for customers with disabilities, we will notify customers promptly with a clearly posted notice. The notice will include information about the reason for the disruption, its anticipated duration and a description of available alternative facilities or services, if any.

Accessibility Training
Any person who interacts with the public or who participates in developing policies, practices and procedures will receive training on an ongoing basis, including information on how to serve persons with disabilities. Training topics will include:
a) An overview of the AODA and the requirements of the customer service standards set out in the AODA regulations;
b)Instruction on how to interact and communicate with people with disabilities;
c) Instruction on how to interact with people with disabilities who use assistive devices or require the assistance of a service
  animal or a support person;
d) Instruction on how use equipment or devices available on-site (if any) or otherwise, that may help with providing services
  to clients with disabilities; and,
e) Instruction on what to do if a person with a disability is having difficulty accessing our goods and services.

Feedback Process
We welcome feedback on how we provide accessible customer service. Comments can be addressed through the following methods:
a) Speaking with a Store Director
b) Contacting Simons
  Telephone: 1-877-666-1840
  Email:   [email protected]
  Mail:     La Maison Simons Inc.
          Customer Service
          9205, rue John-Simons
          Québec QC G2B 0S6

Availability of AODA Documents
We will give a copy of AODA documents upon request. In the event that we are to provide a copy of an AODA documents to a person with a disability, we will give the person the document, or the information contained in the document, in a format that takes into account the person's disability.

GENERAL

REQUIREMENT

DESCRIPTION

STATUS

COMPLIANCE DATE

ESTABLISHMENT OF
ACCESSIBILITY POLICIES

A. Develop, implement and maintain polices
  governing how we achieve or will achieve
  accessibility through meeting the
  requirements of the integrated accessibility
  standards.
B. Statement of organizational commitment to
  meeting the accessibility needs of persons with
  disabilities in a timely manner.
C. Prepare one or more written documents
  describing the policies and make the policies
  publicly available and provide them in an
  accessible format upon request.

Completed

Jan 1 2014

ACCESSIBILITY PLANS

A. Establish, implement, maintain and document a
  multi- year accessibility plan, which outlines
  our strategy to prevent and remove barriers
  and meet requirements of the integrated
  accessibility standards.
B. Post the accessibility plan on our website and   provide the plan in an accessible format upon
  request.
C. Review and update the accessibility plan at
  least once every five years.

Completed

Jan 1 2014

SELF-SERVE KIOSKS

A. Have regard to the accessibility for persons
  with disabilities when designing, procuring or
  acquiring self-service kiosks.

Completed

Jan 1 2014

TRAINING

A. Provide training on the requirements of the
  accessibility standards referred to in the
  integrated standards regulation and the
  Human Rights Code as it pertains to persons
  with disabilities to:
  • All employees and volunteers
  • All persons who participate in developing
      the organization's policies
  • All other persons who provide goods,
      services or facilities on behalf of our               company
B. The training required is appropriate to the
  duties of employees, volunteers and other
  persons
C. Training is done as soon as practicable
D. Training is provided on changes to policies and
  on an ongoing basis
E. Training records are maintained for all training,
  including the date of training and the number
  of individuals in attendance.

Prepared and ongoing

Jan 1 2015

INFORMATION AND COMMUNICATIONS STANDARDS

REQUIREMENT

DESCRIPTION

STATUS

COMPLIANCE DATE

FEEDBACK

A. Ensure our processes for receiving and
  responding to feedback are accessible to
  person with disabilities by providing or
  arranging for accessible formats and
  communication supports upon request.
B. Notify the public about the availability of
  accessible formats and communication
  supports.

Completed

Jan 1 2015

ACCESSIBLE FORMATS AND COMMUNICATION SUPPORTS

A. Upon request provide or arrange for accessible   formats and communication supports for
  persons with disabilities.
  • Provide in a timely manner that takes into       account the person's accessibility needs
      due to disability
  • Provide at a cost that is no more than the
      regular cost charged to other persons.
B. Consult with the person making the request to   determine the suitability of an accessible
  format or communication support.
C. Notify the public about the availability of
  accessible formats and communication
  supports.

Completed

Jan 1 2016

EMERGENCY PROCEDURES,
PLANS OR PUBLIC SAFETY INFO

A. Upon request provide in an accessible format
  or with appropriate communication supports,
  our emergency procedures, plans or public
  safety information that we make available to
  the public.

Completed

Jan 1 2012

ACCESSIBLES WEBSITES
& WEB CONTENT

A. Ensure the websites and web content conform
  with the World Wide Web Consortium Web
  Content Accessibility Guidelines (WCAG) 2.0:
  • Level A
  • Level AA

In progress

January 1, 2014
(Level A)

January 1, 2021
(Level AA)

EMPLOYMENT STANDARDS

REQUIREMENT

DESCRIPTION

STATUS

COMPLIANCE DATE

RECRUITMENT - GENERAL

A. Notify employees and the public about the
  availability of accommodations for applicants
  with disabilities in the recruitment process.

Completed

1 janv 2016

RECRUITMENT, ASSESSMENT
OR SELECTION PROCESS

A. During recruitment process, 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.
B. If the selected applicant requests
 accommodation, 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.

Completed

1 janv 2016

NOTICED TO SUCCESSFUL APPLICANTS

A. When making offers of employment, notify the   successful applicant of our policies for
  accommodating employees with disabilities.

Completed

1 janv 2016

INFORMING EMPLOYEES
OF SUPPORTS

A. Inform employees of our policies used to
  support employees with disabilities.
B. Provide the above information as soon as
  practicable after the employee begins
  employment.
C. Provide updated information to employees
  whenever there is a material change to existing
  policies on the provision of job
  accommodations.

Completed

1 janv 2016

ACCESSIBLE FORMATS & COMMUNICATION SUPPORTS FOR EMPLOYEES

A. Upon request, consult with an employee to
  provide or arrange for the provision of
  accessible formats and communication
  supports for information needed to perform
  employees job and information generally
  available to employees in the workplace.

Completed

1 janv 2016

WORKPLACE EMERGENCY RESPONSE INFORMATION

A. 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.
B. If the employee provides consent, provide the
  employee's individualized workplace
  emergency response information to another
  person designated by the employer to provide
  assistance to the employee.
C. Review the individualized workplace
  emergency response information when:
  • The employee moves to a different work
      location
  • The employee's overall accommodation
      needs or plans are reviewed
  • When the employer reviews its general
      emergency response information

Completed

1 janv 2012

DOCUMENTED INDIVIDUAL ACCOMMODATION PLANS

A. Develop and have in place a written process for
  the development of documented individual
  accommodation plans for employees with
  disabilities that includes all of the
  considerations set out in section 28(2) and (3)
  of the integrated accessibility standards.

Completed

1 janv 2016

RETURN TO WORK PROCESS

A. Develop and have a documented return to
  work process for employees who have been
  absent from work due to a disability and who
  require disability-related accommodations in
  order to return to work.
B. Ensure the return to work process outlines the
  steps that will be taken to facilitate the
  employee's return to work and that it uses
  documented individual accommodation plans,
  if any.

Completed

1 janv 2016

PERFORMANCE MANAGEMENT

A. Take into account the accessibility needs of
  employees with disabilities, as well as
  individual accommodation plans, when
  applying our performance management
  process.

Completed

1 janv 2016

CAREER DEVELOPMENT
& ADVANCEMENT

A. Take into account the accessibility needs of
  employees with disabilities as well as any
  individual accommodation plans, when
  providing opportunities for career
  development and advancement to employees
  with disabilities.

Completed

1 janv 2016

REDEPLOYMENT

A. Take into account the accessibility needs of
  employees with disabilities, as well as
  individual accommodation plans, when
  redeploying employees with disabilities.

Completed

1 janv 2016

DESIGN OF PUBLIC SPACES STANDARDS

REQUIREMENT

DESCRIPTION

STATUS

COMPLIANCE DATE

DESIGN OF PUBLIC SPACES STANDARDS

A. We will focus on removing barriers in our
  buildings and public spaces.
B. New construction and renovations will reflect   updated accessibility requirements as outlined
  by Ontario's Building Code.
C. Public Spaces will be redesigned to meet
  accessibility standards where there is new
  construction and major changes to existing
  facilities, including (where applicable):
  • Recreational trails/beach access routes
  • Outdoor public eating areas
  • Outdoor play spaces
  • Outdoor paths of travel, like sidewalks,       ramps, stairs, curb ramps, rest areas and
      accessible pedestrian signals
  • Accessible off-street parking
  • Service-related elements like service
      counters, fixed queuing lines and waiting
      areas
  • Maintenance and restoration of public
      spaces

Completed

1 janv 2017

COMPLIANCE

REQUIREMENT

DESCRIPTION

STATUS

COMPLIANCE DATE

COMPLIANCE REPORTING

A. Ensure we file online compliance reports in
  accordance with the schedule established
  under integrated standards regulation.

Completed

Ongoing

MULTI-YEAR PLAN REVIEW
AND UPDATE

A. This plan will be reviewed and updated at a
  minimum of once every five (5) years.

Completed

Ongoing