AODA Multi-Year Plan
Introduction
This multi-year plan outlines Emond Harnden LLP’s (“Emond Harnden”) strategy for preventing and removing barriers to address the current and future requirements of the Integrated Accessibility Standards Regulation (O. Reg. 191/11) to the Accessibility for Ontarians with Disabilities Act, 2005 (“AODA”), and to fulfill Emond Harnden’s commitments, as outlined in our Accessibility Policy.
Statement of Commitment
Emond Harnden is committed to providing a barrier-free environment and to meeting the accessibility needs of persons with disabilities in a timely manner. As a Firm, we recognize our responsibility to ensure a safe, dignified and welcoming environment for everyone, including our clients, customers, job applicants, employees, suppliers and visitors who enter our offices, use our services, or access our information.
Emond Harnden is committed to ensuring its compliance by incorporating accessibility legislation into our training programs, requirements, policies, procedures, equipment and best practices.
This Plan adheres to the objectives outlined in the AODA and its associated regulations and standards, as applicable to Emond Harnden.
General Requirements
In accordance with the requirements of the Integrated Accessibility Standards, Emond Harnden will:
- Develop, implement, and maintain policies on its measures and efforts to achieve accessibility;
- Ensure that any written policies are available to the public in an accessible format, upon request;
- Establish, review, and update this Plan at least once every five years;
- Post this Plan on its website; and
- Provide this Plan in an accessible format upon request.
Required legislative compliance: January 1, 2014
Status: Complete
Accessible Customer Service
Commitment
Emond Harnden is committed to providing accessible customer service.
Planned Action
Emond Harnden will:
- Train employees and volunteers to service customers of all abilities and keep a written record of the training;
- Welcome service animals and support persons;
- Create accessible ways for people to provide feedback; and
- Make our written Accessibility Policy publicly available, so that employees, volunteers, clients and customers can know what to expect.
Required legislative compliance: January 1, 2012.
Status: Complete
Training
Commitment
Emond Harnden will provide training to employees and other staff members regarding the requirements of the Integrated Accessibility Standards and on the Ontario Human Rights Code, as it pertains to persons with disabilities. Training will be provided in a way that best suits the duties of employees and other staff members.
Planned Action
In accordance with the Integrated Accessibility Standards, Emond Harnden will:
- Determine and ensure that appropriate training on the requirements of the Integrated Accessibility Standards and on the Ontario Human Rights Code, as it pertains to persons with disabilities, is provided to employees in a way that best suits their duties
- Ensure that the training is provided as soon as practicable;
- Keep and maintain a record of the training provided, including the dates that the training was provided and the number of individuals to whom it was provided; and
- Ensure that the training is provided on any changes to the prescribed policies on an ongoing basis, as needed.
Required legislative compliance: January 1, 2012 (as it relates to customer service); January 1, 2015 (as it relates to all other accessibility standards).
Status: Complete
Information and Communication Standards
Commitment
Emond Harnden is committed to meeting the communication needs of persons with disabilities. Emond Harnden will consult with people with disabilities to determine their information and communication needs.
1. Feedback
Planned Action
In accordance with the Integrated Accessibility Standards, Emond Harnden will ensure that existing and new processes for receiving and responding to feedback are accessible to persons with disabilities, and will notify the public of same. Individuals will have the option of providing feedback in person, via email, by phone, or in writing.
Required legislative compliance: January 1, 2015
Status: Complete
2. Publicly Available Information
Planned Action
In accordance with the Integrated Accessibility Standards, Emond Harnden will provide or arrange for the provision of accessible formats, upon request, in a timely manner.
More broadly, as a general principle, where accessible formats and communication supports for persons with disabilities are requested, Emond Harnden will:
- Provide or arrange for the provision of such accessible formats and communication supports;
- Consult with the person making the request to determine the suitability of the accessible format or communication support;
- Provide or arrange for the provision of accessible formats and communication supports in a timely manner that takes into account the person’s accessibility needs due to disability, and at a cost no more than the regular cost charged to other persons; and
- Notify the public about the availability of accessible formats and communications supports.
Required legislative compliance: January 1, 2016
Status: Complete
3. Accessible Emergency Information
Commitment
Emond Harnden is committed to providing customers and clients with publicly available emergency information in an accessible format, upon request. We will also provide employees with disabilities with individualized emergency response information when necessary.
Planned Action
Emond Harnden will implement the following measures:
- Emergency procedures, plans, and public safety information that are prepared by Emond Harnden and made available to the public will be made available in an accessible format or with appropriate communication supports, as soon as practicable, upon request;
- Individualized workplace emergency response information measures for employees with disabilities will be developed as soon as practicable, as required;
- Where required, Emond Harnden will provide assistance to specific disabled employees, with the disabled employee’s prior consent, to help them evacuate the workplace in case of an emergency or disaster;
- Individualized emergency plans will be communicated to employees’ respective managers with the employees’ prior consent, on an “as needed” basis; and
- On an ongoing and regular basis, in accordance with the Integrated Accessibility Standards, Emond Harnden will review and assess general workplace emergency response procedures and individualized emergency plans to ensure accessibility needs continue to be addressed.
Required legislative compliance: January 1, 2012
Status: Complete
4. Accessible Website and Web Content
Planned Action
In accordance with the Integrated Accessibility Standards, Emond Harnden will:
- Ensure that its internet websites and web content that are controlled within Ontario conform with the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0;
- Advise staff responsible for websites and web content of the requirements of the Integrated Accessibility Standards; and
- Expand corporate awareness of requirements for compliance with Information and Communication Standards of the AODA.
Required legislative compliance: January 1, 2014 (WCAG 2.0 Level A – for new internet websites and new web content); January 1, 2021 (WCAG 2.0 Level AA – all internet websites and web content created post January 1, 2012).
Status: Complete
Employment Standards
Commitment
Emond Harnden is committed to fair and accessible employment practices. This includes identifying and removing barriers and providing accessibility across all stages of the employment cycle. Emond Harnden will continue to ensure compliance with the current requirements under the employment standards in the Integrated Accessibility Standards and incorporate new accessibility requirements as applicable.
1. Recruitment
Planned Action
In accordance with the Integrated Accessibility Standards, Emond Harnden will take the following steps to notify the public and staff that, when requested, Emond Harnden will accommodate people with disabilities during the recruitment and assessment process, and once individuals are hired:
- Review and modify, as necessary, existing recruitment policies, procedures, and processes;
- On its website and on job postings, specify that accommodation is available for applicants with disabilities;
- Notify job applicants, when 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 in the assessment/selection process;
- If an applicant requests accommodation, consult with the applicant and arrange for suitable accommodation in a manner that takes into account the applicant’s individual accessibility needs;
- Include information about accommodation policies into offers of employment; and
- Provide newly-hired employees with copies of accommodation policies as soon as practicable after they begin their employment.
Required legislative compliance: January 1, 2016
Status: Complete
2. Existing Employees
Planned Action
In accordance with the Integrated Accessibility Standard, Emond Harnden will take the following steps to notify employees that, when requested, Emond Harnden will accommodate people with disabilities throughout their employment:
- Inform all employees of 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 disability; and
- Provide updated information to all 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 disability.
Required legislative compliance: January 1, 2016
Status: Complete
3. Individual Accommodation Plans / Return to Work Processes
Commitment
Emond Harnden will incorporate the requirements under the Integrated Accessibility Standards to ensure that we have a process for developing individual accommodation plans and return to work policies for employees who have been absent due to disability.
Planned Action
Emond Harnden will include in our policies the steps that we will take to accommodate an employee with a disability and to facilitate an employee’s return to work after absenteeism due to a disability.
Emond Harnden will review and assess existing policies to ensure that they include a process for the development of documented individual accommodation plans for employees with a disability if such plans are required.
Emond Harnden will ensure that the process for the development of documented individual accommodation plans includes the following elements, in accordance with the provisions of the Integrated Accessibility Standards:
- The manner in which the employee requesting accommodation can participate in the development of the plan;
- The means by which the employee is assessed on an individual basis;
- The manner in which Emond Harnden can request an evaluation by an outside medical or expert, at Emond Harnden’s expense, to assist in determining if and how the accommodation can be achieved;
- The manner in which the employee can request the participation of a representative from the workplace in the development of the accommodation plan;
- Steps to protect the privacy of the employee’s personal information;
- An outline of the frequency with which the individual accommodation plans will be reviewed and updated, and the manner in which this will be done;
- The reasons for the denial if an individual accommodation plan is denied; and
- The means of providing the individual accommodation plan in a format that takes into account the employee’s accessibility needs.
When individualized accommodation plans are established, Emond Harnden will ensure that they include:
- Required individualized workplace emergency response information;
- Any information regarding accessible formats and communication supports that have been provided for or arranged, to provide the employee with information required to perform the employee’s job and information generally available to employees in the workplace; and
- Any other accommodation that is to be provided to the employee;
Emond Harnden will ensure that its return to work process outlines the steps Emond Harnden will take to facilitate the employee’s return to work following a disability-related absence including the use of individual accommodation plans as part of this process.
Required legislative compliance: January 1, 2016
Status: Complete
4. Performance Management, Career Development and Redeployment
Commitment
Emond Harnden will take into account the accessibility needs and the disabilities of an employee, as well as individual accommodation plans when:
- Using its performance management process;
- Providing career development and advancement; and
- Redeploying employees.
Planned Action
In accordance with the Integrated Accessibility Standards, Emond Harnden will:
- Review, assess and, as necessary, modify existing policies, procedures, and practices to ensure compliance with the Integrated Accessibility Standards;
- Take into account the accessibility needs of employees with disabilities and, as applicable, their individualized accommodation plans, when:
- Assessing performance;
- Managing career development and advancement; and
- Redeploying employees.
Required legislative compliance: January 1, 2016
Status: Complete
5. Workplace Information
Planned Action
Emond Harnden will provide workplace information in an accessible format if an employee asks for it. This includes:
- Any information required by employees to perform their jobs (e.g. job descriptions and manuals); and
- General information that is available to all employees at work (e.g. Firm newsletters, bulletins about Firm policies, and health and safety information).
Required legislative compliance: January 1, 2016
Status: Complete
Emond Harnden will provide accessible emergency information to employees when we become aware that an employee may require accommodation in an emergency.
Required legislative compliance: January 1, 2012
Status: Complete
Proposed Accessibility Standards for the Design of Public Spaces
Commitment
Emond Harnden will meet the Accessibility Standards for the Design of Public Spaces when building or making major modifications to public spaces. In the event of a service disruption, Emond Harnden will notify the public of the service disruption and alternatives available.
Planned Action
Emond Harnden will advise staff responsible for public spaces of the requirements of the Integrated Accessibility Standards.
Required legislative compliance: January 1, 2017
Status: complete
For Further Information
If you have questions, comments, or suggestions on this Accessibility Plan, please contact Sara Florakas at sflorakas@ehlaw.ca. Accessible formats of this document are available free upon request from Sara Florakas.
