1. ACCESSIBILITY FOR ONTARIANS WITH DISABILITIES (AODA)
1.1 CUSTOMER SERVICE STANDARD
Lorpon Labels is committed to providing excellent service to all clients including persons with disabilities. Lorpon’s goal is to focus on identifying, removing, and preventing barriers for persons with disabilities. This policy complies with the Accessibility for Ontarians with Disabilities Act, 2005 (AODA).
Definition of “Disability”:
- 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;
- A condition of mental impairment or a developmental disability, a learning disability, or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language;
- A mental disorder; or
- An injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997.
Four Guiding Principles
Lorpon will strive to ensure that its policies, practices and procedures are consistent with the following core principles as outlined in the AODA:
- Dignity – ensure persons with disabilities are provided with services in a manner that will allow them to maintain self-respect and the respect of others.
- Independence – ensure persons with disabilities have the right to work on their own and are able to do things in their own way.
- Integration – ensure persons with disabilities fully benefit from the same goods and services, in the same place and in the same or similar manner as others. This may require alternative formats and flexible approaches. It means complete and full participation.
- Equal Opportunity – ensure persons with disabilities have the same chances, options, benefits, and results as others.
Procedures and Responsibilities
Lorpon is committed to using reasonable efforts in providing goods and services to all customers including persons with disabilities and will carry out our functions and responsibilities in the following areas:
Lorpon is committed to ensuring that our employees are fully aware of how to interact and communicate with persons with disabilities. We will train our employees who communicate with customers, including but not limited to members, potential members or external stakeholders, and partners on how to interact and communicate with people with various types of disabilities.
Our employees are trained to consult the person with disabilities as to how best to assist them.
All visitors to Lorpon Label are required to be accompanied by an employee at all times. This includes persons with disabilities. This is for health and safety requirements.
Lorpon Label will have this policy available on our website and in our reception area.
Lorpon is committed to serving persons with disabilities who may use assistive devices to obtain, use, or benefit from goods and/or services. We will ensure that employees are aware of and become familiar with various assistive devices that may be used while accessing our goods and/or services.
If Lorpon needs to provide an assistive device to facilitate a requirement, this will be reviewed and assessed. Our goal is that there is no cost for any assistive device that may be required.
Use of Service Animals and Support Persons
- Lorpon is committed to welcoming persons with disabilities and their guide dogs or service animals in the areas of our premises that are open to the public. Please note that a “guide dog” is a dog trained by the regulations under the Blind Persons’ Rights Act. Also, a “service animal” is an animal for persons with disabilities. 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 a nurse confirming that the person requires the animal for reasons relating to the disability, then the individual may bring the service animal on office premises.
- Lorpon will also ensure that our employees are trained on how to interact with customers with disabilities who are accompanied by a guide dog or service animal.
- Service animals are not restricted for health and safety reasons. Lorpon Labels will review internally to ensure that we accommodate anyone who may have an allergy to any service animal in a different capacity. Ex. If a person needs to be involved in a meeting and they have an allergy they can be involved remotely, if there is a plant tour, then the person conducting the plant tour will be someone who does not have any allergy to a service animal. Any visitor in our facility is always accompanied by an employee at all times.
- Any persons with disabilities who are accompanied by a support person will be allowed to enter Lorpon’s premises open to the public or other third parties with that person. At no time will persons with disabilities who are accompanied by a support person be prevented from having access to that person while on our premises.
- Lorpon will not charge admission fees for support persons to attend Lorpon’s sponsored events. This policy will be included where admission fees are published.
Notice of Temporary Disruption
- We will provide visitors with notice in the event of a planned or unexpected temporary disruption in the Lorpon offices or services usually used by persons with disabilities. Notice will include information about the reason for the disruption, its anticipated duration, and a description of alternative facilities, services or systems that may be available.
- Notice will be given by posting the information in a visible place on premises owned or operated by the provider of goods and/or services.
- In the event that an unexpected disruption occurs, notice will be given as soon as possible.
Training for Employees
Lorpon will provide training to employees and others who deal with the public or third parties on behalf of Lorpon. The Company will also provide training to those who are involved in the development and approvals of customer service policies, practices and procedures.
Training will consist of the following:
- Purpose of the Accessibility for Ontarians with Disabilities Act, 2005 (AODA) and the requirements of the Accessibility Standards for Customer Service.
- How to interact and communicate with persons with various types of disabilities.
- How to interact with persons with disabilities who use an assistive device or require the assistance of a guide dog, service animal or a support person.
- What to do if persons with disabilities are having difficulty in accessing Lorpon’s services.
Training will be provided to employees upon this policy taking effect and upon amendments to the policy. New employees will be provided such training as part of their orientation. Documentation of the training of employees shall be maintained by the management team.
We ensure our feedback process is accessible by providing or arranging accessible formats and communication supports on request.
We will provide the accessible format in a timely manner and at no additional cost.
Comments and feedback about the delivery of services to persons with disabilities are welcome, as it may help identify areas that require change and assist in continuous improvement. Such contact can be made by emailing firstname.lastname@example.org . Feedback will be addressed immediately. Some feedback may require more effort to address and may need to be reviewed in detail.
Once we have completed a full review, feedback will be posted on our website or anyone can make a request for information regarding any feedback by emailing email@example.com.
Availability of AODA Policy
In accordance with the AODA, this policy will be made available to any person upon request.
1.2 INTEGRATED ACCESSIBILITY STANDARDS REGULATIONS
The following policy has been established by Lorpon to govern the provision of services with Regulation 191/11, “Integrated Accessibility Standards” (“Regulation”) under the Accessibility for Ontarians with Disabilities Act, 2005.
These standards are developed to break down barriers and increase accessibility for persons with disabilities in the areas of information, communications, and employment.
Lorpon is governed by this policy as well as the Accessibility Standards for Customer Service Policy and the Accessibility for Ontarians with Disabilities Act, 2005 in meeting the accessibility needs of persons with disabilities.
Lorpon 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 persons 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), 2005.
This policy will be implemented in accordance with the time frames established by the Regulation.
Lorpon will have consideration for accessibility when designing, procuring or acquiring our self-serve kiosks to better serve persons with disabilities.
Training Employees and Volunteers
Lorpon will ensure that training is provided on the requirements of the accessibility standards referred to in the Regulation and continue to provide training on the Human Rights Code as it pertains to persons with disabilities, to:
- all its employees and volunteers;
- all persons who participate in developing Lorpon’s policies; and,
- all other persons who provide goods, services or facilities on behalf of the Company
The training will be appropriate to the duties of the employees, volunteers and other persons.
Employees will be trained when changes are made to the accessibility policy. New employees will be provided such training as part of their orientation.
Lorpon will keep a record of the training it provides.
INFORMATION AND COMMUNICATIONS STANDARDS
Lorpon will continue to ensure that its process for receiving and responding to feedback is accessible to persons with disabilities by providing, or arranging for the provision of accessible formats and communications supports, upon request.
Accessible Formats and Communication Supports
Upon request, Lorpon will provide, or will arrange for the provision of accessible formats and communication supports for persons with disabilities in a timely manner that takes into account the person’s accessibility needs due to disability.
Lorpon will consult with the person making the request in determining the suitability of an accessible format or communication support. Lorpon will also notify the public about the availability of accessible formats and communication supports.
Accessible Websites and Web Content
Lorpon shall ensure any new web content on its internet website conforms with the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0 Level AA except where this is impracticable.
Lorpon will notify its employees and the public about the availability of accommodation for applicants with disabilities in its recruitment process.
Recruitment, Assessment or Selection Process
Lorpon will notify job applicants, when they are individually selected to participate further in an assessment or selection process that accommodations are available upon request in relation to the materials or processes to be used.
If a selected applicant requests an accommodation, Lorpon 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.
Notice to Successful Applicants
When making offers of employment, Lorpon will notify the successful applicant of its policies for accommodating employees with disabilities.
Informing Employees of Supports
Lorpon will continue to inform its employees of its policies (and any updates to those policies) used to support employees with disabilities, including policies on the provision of job accommodations that takes into account an employee’s accessibility needs due to disability. This information will be provided to new employees as soon as practicable after commencing employment.
Accessible Formats and Communication Supports for Employees
Upon the request of an employee with a disability, Lorpon will consult with the employee to provide, or arrange for the provision of, accessible formats and communication supports for information that is needed to perform their job and information that is generally available to other employees.
In determining the suitability of an accessible format or communication support, Lorpon will consult with the employee making the request.
Workplace Emergency Response Information
Lorpon 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 if Lorpon is aware of the need for accommodation due to the employee’s disability, Lorpon will provide this information as soon as practicable after becoming aware of the need for accommodation.
Where the employee requires assistance, Lorpon will, with the consent of the employee, provide the workplace emergency response information to the person designated by Lorpon to provide assistance to the employee.
Lorpon will review the individualized workplace emergency response information when the employee moves to a different location in the organization, when the employee’s overall accommodations needs or plans are reviewed.
Performance Management, Career Development and Advancement & Redeployment
Lorpon 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.
Questions about this Policy
This policy has been developed to break down barriers and increase accessibility for persons with disabilities in the areas of information, communications, and employment. If anyone has a question about the policy, or if the purpose of a policy is not understood, an explanation will be provided by:
Andrea Pontarollo Cindy Davis
President General Manager
2. ACCOMMODATION IN THE WORKPLACE
Lorpon is committed to providing an environment that is inclusive and free of barriers based on citizenship, race, place of origin, ethnic origin, colour, ancestry, disability, age, creed, sex (including pregnancy), gender identity, gender expression, family status, marital status, sexual orientation, receipt of public assistance and record of offence. The Company commits to provide accommodation for needs related to the grounds of the Ontario Human Rights Code, unless to do so would cause undue hardship, as defined by the Ontario Human Rights Commission’s Policy on Disability and the Duty to Accommodate.
Accommodation will be provided in accordance with the principles of dignity, individualization, and inclusion. Lorpon will work cooperatively, and in a spirit of respect, with all partners in the accommodation process.
This Policy and Procedure applies to all those working for Lorpon, including the Board of Directors, general members, full and part-time employees, temporary, casual and contract staff, as well as those who work to gain experience or for benefits, such as volunteers, co-op students, interns and apprentices. It also applies to individuals who are applying for employment with the organization.
It applies at all stages and to all aspects of the employment relationship, including recruitment and selection, promotions and transfers, discipline and conditions of work such as hours of work and leaves of absence.
Process for Accommodation Requests
The Employee’s direct supervisor/manager is responsible for dealing with all requests for accommodation. The direct supervisor/manager will refer the accommodation request to the President or General Manager for a final decision in the following instances:
- when the direct supervisor/manager is of the opinion that the accommodation request should be rejected;
- when the direct supervisor/manager is uncertain whether the accommodation should be granted;
- when the direct supervisor/manager requires advice on how to accommodate the requesting individual;
- for all decisions regarding whether the accommodation creates undue hardship for Lorpon.
Accommodation requests should, whenever possible, be made in writing. The accommodation request should indicate:
- The nature of the request for accommodation and its link to a protected ground under the Ontario Human Rights Code;
- Information as to whether the accommodation is required to do an essential or non-essential duty of the job;
- The reason why accommodation is required, including enough information to confirm the existence of a need for accommodation; and
- Any other information to confirm the existence of the need for accommodation and the measures of accommodation required.
All accommodation requests will be taken seriously. No person will be penalized for making an accommodation request.
The person responsible for dealing with the accommodation request will do so in a timely way. This may include seeking external help from professionals experienced in determining the appropriate accommodation. A number of accommodation strategies may be used to fulfill Lorpon’s obligation. In the interest of both prompt attention to the needs of an individual and the need to explore the utility of various accommodation strategies, an interim or experimental strategy may be implemented.
Provision of Information
The direct supervisor/manager may require further information related to the accommodation request, in the following circumstances:
- Where the accommodation request does not clearly indicate a need related to a Code ground;
- Where further information related to the employee’s limitations or restrictions is required in order to determine an appropriate accommodation;
- Where there is a demonstrable objective reason to question the legitimacy of the person’s request for accommodation.
Failure to respond to such requests for information may delay the provision of accommodation.
The direct supervisor/manager will maintain information related to:
- The accommodation request;
- Any documentation provided by the accommodation seeker or by experts;
- Notes from any meetings;
- Any accommodation alternatives explored; and
- Any accommodations provided.
This information will be maintained in a secure location, separate from the accommodation seeker’s personnel file, and will be shared only with those persons who need the information. The organization will maintain the confidentiality of information related to an accommodation request, and will only disclose this information with the consent of the employee or applicant.
Accommodation requests will be dealt with promptly. Where necessary, interim accommodation will be provided while long-term solutions are developed.
[Repeat Contact Person] and the person requesting accommodation related to a Code ground, will work together cooperatively to develop an Accommodation Plan for the individual.
The Accommodation Plan, when agreed on, will be put in writing, and signed by the individual requesting accommodation and direct supervisor/manager.
An Accommodation Plan may include the following:
- A statement of the accommodation seeker’s relevant limitations and needs, including any necessary assessments and information from experts or specialists, bearing in mind the need to maintain the confidentiality of medical reports;
- Arrangements for necessary assessments by experts or professionals;
- Identification of the most appropriate accommodation short of undue hardship;
- A statement of annual goals, and specific steps to be taken to meet them;
- Clear timelines for the provision of identified accommodations;
The aim of accommodation is to remove barriers and ensure equality. Accommodations will be developed on an individualized basis and when resources and programs allow. Appropriate accommodations may include:
- Workstation adjustments;
- Job redesign;
- Technical aids;
- Human support;
- Provision of materials in alternative formats;
- Counselling and referral services;
- Temporary or permanent alternative work;
- Modification of performance standards; or
- Changes to scheduling or hours of work.
The above list is not exhaustive.
Accommodation will be provided to the point of undue hardship, as defined by the Ontario Human Rights Commission’s Policy and Guidelines on Disability and the Duty to Accommodate.
A determination regarding undue hardship will be based on an assessment of costs, outside sources of funding, and health and safety. It will be based on objective evidence.
A determination that an accommodation will create undue hardship may only be made by the President or General Manager. In determining undue hardship, Lorpon will only consider the following factors:
- outside sources of funding, if any; and
- health and safety requirements, if any.
Where a determination is made that an accommodation would create undue hardship, the person requesting accommodation will be given written notice, including the reasons for the decision and the objective evidence relied upon. The accommodation seeker shall be informed of his or her recourse under Lorpon’s Anti-Discrimination Policy and Procedure, and under the Ontario Human Rights Code.