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