Accessibility Policy

To request an alternate format, please contact: accessibilities@iovate.com.

Statement of Commitment

Iovate is committed to treating all people in a way that allows them to maintain their dignity and independence. In support of this commitment, Iovate goods and services, as well as employment opportunities, are provided in an equitable manner, promoting integration and equal opportunity without discrimination. Iovate will use reasonable efforts to adhere to this commitment, providing accommodation where required and in a timely manner.

Application

This Policy applies to all individuals who do business with Iovate, whether as employees, contractors, consultants, customers or otherwise, and to any individual or organization that provides goods, services or facilities to the public or other third parties on behalf of Iovate regardless of the province, state or territory in which they may reside.

Principles

All services, programs, goods and facilities will be available to any individual in a manner that:

is free from discrimination;
provides accessible formats and communication supports;
seeks to provide integrated services;
provides an opportunity equitable to others to provide or obtain, use and benefit from the goods or services and/or employment opportunities; and
takes into consideration a person’s disability.

Definition of Disability

“Disability” is defined as:

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, brain injury, any degree of paralysis, amputation, lack of physical coordination, 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; or
A mental disorder.

It is important to note that a disability may or may not be visible.

POLICY COMPONENTS

Iovate is committed to excellence in serving all individuals, including people with disabilities, except to the point of undue hardship. This commitment is demonstrated in the following areas:

Accessible Formats and Communication

Iovate is committed to meeting the communication needs of people with disabilities in a manner that takes into account their disabilities. Iovate will, upon request, and in consultation with the individual making the request, provide or make available accessible formats and communication supports for individuals with disabilities, in a timely manner and at no additional cost to the individual, taking into account the individual’s accessibility requirements. Iovate will consider how a disability may affect the way an individual expresses, receives or processes communications and, where possible, the individual will be asked how to best communicate with them. Individuals are encouraged to identify any barriers to communication that they are experiencing in order to assist Iovate in meeting this commitment.

“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.

Accessible Formats may be provided, upon request, for general communications and information, as well as individualized accommodation plans, emergency procedure plans and workplace information (e.g., job descriptions, performance management tools, etc.). If Iovate determines that the information or communication cannot be made available in an accessible format, Iovate shall provide the individual making the request with:

an explanation as to why the information or communications are unconvertible; and
a summary of the unconvertible information or communications.

Iovate has also taken action to ensure its websites are accessible to individuals with disabilities by making website content compliant with the World Wide Web Consortium – Web Content Accessibility Guidelines (WCAG) 2.0, Level A and Level AA.

Assistive Devices

Persons with disabilities who use assistive devices are encouraged to use their devices as necessary. An assistive device is a tool, technology or other mechanism that enables a person with a disability to do everyday tasks and activities, such as moving, communicating or lifting, and includes but is not limited to wheelchairs, canes, crutches, walkers, scooters, oxygen tanks, screen readers, listening devices, speech amplification devices, magnification devices, note-taking devices, teletypewriters and communication boards.

Service Animals

Iovate welcomes guide dogs or other animals that serve individuals with disabilities, except for those animals that are otherwise excluded by law from the premises. In the event that a service animal is otherwise excluded by law from the premises (for example, GMP restricted areas), Iovate will ensure that other measures are available to provide the individual with an alternative method of obtaining, using or benefitting from its goods or services or to avail themselves of employment opportunities.

Support Persons

Iovate welcomes persons who support individuals with disabilities to accompany them onto Iovate’s premises. In some instances, support persons may be asked to sign a Confidentiality Agreement. Iovate will require a support person to accompany an individual, as applicable, when it is determined by Iovate that such an arrangement is necessary for health and safety reasons.

Recruitment and Selection Process

Iovate will take all appropriate steps to ensure that all applicants have an awareness of Iovate’s commitment to accommodation and applicants may request accommodation support during the recruitment process. Job postings and offer letters will reflect Iovate’s commitment to accommodation of individuals with disabilities.

**Employee Accommodation Supports (Individualized Accommodation Plans)**

Employee accommodation will mirror any accommodations outlined in this Policy and as may reasonably be required in the circumstances. Any employee with a disability may request an Individualized Accommodation Plan (IAP) by contacting Human Resources. An IAP will include the following:

a “Return to Work Checklist” when employees return to work after disability-related absence;
the specific accommodations to be provided by Iovate;
if requested, any information regarding accessible formats and communication supports provided; and
if required, the individualized workplace emergency response information (see below).

Iovate may request any evaluation by an outside medical or other expert, at Iovate’s expense, to assist Iovate in determining if the accommodation can be achieved and, if so, how the accommodation can be achieved.

All accommodation plans will protect the privacy of the individual’s personal information and only document the necessary accommodation requirements and agreed outcomes amongst persons on a need-to-know basis only.

In the event that an IAP is denied, the reasons for denial will be provided to the employee.

IAPs will be reviewed as follows:

change of job within the organization;
changing needs for accommodation because of recurring or sporadic illness;
changes to Iovate policies and practices;
performance reviews; and/or
a return to work following an illness or injury.

Emergency Response Information

Iovate will prepare an emergency response plan for any employee with a disability whose IAP (see above) necessitates this or for any employee who requests one, and Iovate will work to ensure that all employees requiring such a plan as well as those emergency responders supporting the plan are fully trained in any requirements. Emergency response plans will be reviewed in any situation where the employee moves to a new location and as the organization reviews its overall emergency response programs. Employees with disabilities requiring support of this nature must communicate their need to Human Resources and/or the Joint Health & Safety Committee.

Return to Work Process

Iovate has a documented “Return to Work Checklist” for its employees who have been absent from work due to a disability and require disability-related accommodations to return to work. The document outlines the steps to be taken to facilitate the return to work of employees whose absence was related to their disability. Documented individual accommodation and emergency response plans (if applicable) shall be part of the process. Iovate will:

ensure that barriers are identified and removal of barriers is planned and implemented;
review and consider IAPs and accessibility needs when managing employee performance, redeployment processes, career development and advancement;
determine whether the format and location of meetings is accessible;
ensure that managers review IAPs prior to performance management or career development sessions, ensuring that all relevant accommodations are implemented and taken into account in the assessment and discussion of same;
ensure management of any employee who has moved to a new position due to advancement or redeployment is aware of any IAP.

Training

Iovate will provide training to employees on its accessibility requirements as it relates to people with disabilities in accordance with this Policy. Training will be provided to all new hires during orientation and, additionally, as job responsibilities may require. Training will be provided in a way that best suits the duties of the respective employees. Training refreshers will be provided, as necessary, based on updated information or changes to this Policy or existing laws. Training will be organized by Human Resources and training records shall be kept, including the dates of the training session(s), content of the training, and the individuals to whom the training was provided. In addition, the Policy shall be posted in accessible locations and will be made available (upon request) in accessible formats.

Other Barriers

Iovate will take steps to prevent and remove other accessibility barriers as they are identified. Formal and informal feedback will be collected by the Joint Health and Safety Committee and members of the Human Resources team to aid Iovate’s ongoing commitment to remove barriers.

Design of Public Spaces

Iovate will design its public spaces, when building or making major modifications, to be accessible to those with disabilities. Public spaces include:

outdoor public eating areas;
outdoor paths of travel, such as sidewalks, ramps, stairs, curb ramps, and rest areas;
accessible off-street parking; and
waiting areas.

Notice of Temporary Disruption

In the event of a service disruption, Iovate will notify the public of the service disruption, outlining the reason for the disruption, its anticipated duration, and alternatives available. Notice will be posted at a conspicuous location on the premises, on Iovate’s external and internal websites, and any other reasonable means appropriate to the circumstances.

Feedback

Iovate is committed to receiving and responding to feedback about the way it implements this Policy. Comments regarding how well these expectations are being met are welcome and appreciated. For more information on the Accessibility Policy and the Iovate Multi-Year Accessibility Plan (Appendix I), please contact any member of the Human Resources team:

By phone: 905-678-3119;
By e-mail: accessibilities@iovate.com; or
In person (including by digital meeting).

Any provider of feedback on this Policy will be provided a response in the format requested (or the most appropriate format, which takes into account their disability, where no request was made).

From Planning into Action

Every member of Iovate has a role to play in increasing the accessibility of our work environment. Part of our commitment to building a culture of accessibility is in the added focus of our Joint Health and Safety Committee to be aware of and create a culture around accessibility. The Committee will work with the various departments and with a variety of stakeholders to facilitate the ongoing removal of barriers and the implementation of innovative solutions. The Committee will annually review this Policy and accessibility plans and progress with Human Resources.

Version: June 2021

Appendix I: Multi-Year Accessibility Plan

Item	Details	Who is Responsible	Due Date	Status	Hours to complete
Compliance Reports	File with Ontario government Accessibility Compliance Report	HR	December 31, 2014	Complete
	File Accessibility Compliance Report 2	HR	December 31, 2017
	File Accessibility Compliance Report 3	HR	June 30, 2021
Training	HR members to attend webinar held by the government of Ontario	HR	December 8, 2014	Complete
Gap Analysis/ Readiness Assessment	Determine areas we need to have a plan for in order to attain compliance	HR	End of 2013	Complete	0.5
Communicate	Plan and Policy with statement of commitment to be posted on iovation.	HR	December 1, 2014	Complete	.25
Plan	Plan and Policy to be reviewed and updated every 5 years. Add to 1^st quarter meeting agenda every year.	HR and Health & Safety Committee	Ongoing	Complete
Communicate	Plan and Policy to be posted on external iovate.com website and other related websites	HR & Digital Marketing Team	December 15, 2014		.25
Employment Compliance	Post our feedback process including email on: Iovation – job posting sectionIovate.com – careersLinked in – company profile	HR	January 1, 2015
Communicate	Emergency Procedures and response information	HR and Health & Safety Committee		Complete	0.5
Policy	Accommodation and return to work policy (work with 3^rd party benefits), as well as documented individual accommodation plans and processes for people returning to work. .	HR	November 30, 2014	Complete	3
Policy	Performance Management – put statement on Review form and Employee Increase Letters Build statement into Offer Letter template	HR	November 30, 2014	Complete Complete	0.5
Training	Update new hire orientation to put a slide in presentation on AODA. Distribute training slides to: ELTSLT MLTHR/Office Services TeamJoint Health & Safety Committee		November 30, 2014	Complete	2
	Conduct refresher training	HR	June 30, 2021
Web Compliance	Work with Digital Marketing to ensure compliance to the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) All websites and content must conform with WCAG 2.0, Level AA by January 1, 2021	HR and & Digital Marketing Team	January 1, 2021	Complete