Statement of Commitment and Multi-Year Accessibility Plan
This Statement of Commitment and Multi-Year Accessibility Plan (this “Plan”) outlines Northleaf Capital Partner’s (“Northleaf”) strategy to prevent and remove barriers and meet the requirements of the Integrated Accessibility Standards, Ontario Regulation 191/11 (“IAS”). Northleaf will review and, if necessary, update this Plan at least once every five years in consultation with persons with disabilities.
This Plan, as amended from time to time, will be available in accessible formats upon request by any person.
Northleaf is committed to meeting the accessibility needs of persons with disabilities in a timely manner. Set out below are the details of how Northleaf intends to fulfil its obligations under the Accessibility for Ontarians with Disabilities Act, 2005 (“AODA”) over the coming years.
A. Customer Service Standard Requirements
Statement of Commitment
Northleaf has been in compliance with its obligations under the Accessibility Standards for Customer Service, Ontario Regulation 429/07 (“ASCS”) since January 1, 2012, and will continue to ensure ongoing compliance. As set out in Northleaf’s Accessibility for Ontarians with Disabilities Act Policy (the “Policy”), Northleaf is committed to giving people with disabilities the same opportunity or a reasonable alternative to access its work environment and allowing them to benefit from the same or similar services as other visitors.
In support of Northleaf’s objective of providing the same or similar services to all clients, Northleaf will endeavour to communicate with people with disabilities in ways that take into account their specific disability and accessibility needs, and will ensure that the premises of Northleaf which are open to the public are accessible to such individuals. This includes (without limitation) taking the following measures, where appropriate:
- offering to communicate with clients and/or answer questions in person, by e-mail or telephone relay services where telephone communication is not appropriate or available;
- permitting clients with disabilities to use assistive devices on Northleaf’s premises;
- making documents prepared by Northleaf, and to which clients are entitled, available in accessible formats upon request, including hard copy, large print, e-mail or other appropriate formats;
- welcoming people who are accompanied by a service animal or a support person in the areas of Northleaf’s premises that are open to the public, and ensuring that staff are properly trained in how to interact with people who are accompanied by a service animal or a support person;
- ensuring that all workplace policies respect and promote the dignity and independence of people with disabilities;
- regularly monitoring its premises to ensure that the premises remain accessible for employees, clients and other third parties. To the extent deemed necessary or prudent, Northleaf will undertake preventative and/or emergency maintenance of accessible elements of Northleaf’s workspace;
- in the event of a planned or unexpected disruption in the facilities usually used by people with disabilities, Northleaf will, in conjunction with building management, provide clients with notice of such disruption. Where known, this notice will include information about the reason for the disruption, its anticipated duration, and a description of alternative facilities, if available, and will be placed at a conspicuous place on Northleaf’s premises, on Northleaf’s website or such other place Northleaf deems reasonable in the circumstances;
- creating and maintaining a feedback process to respond to any questions or comments regarding the manner in which Northleaf provides services to persons with disabilities. Feedback on the accessibility of Northleaf’s services can be provided in a variety of ways, including in person or in writing at 79 Wellington Street West, 6th Floor, Box 120, Toronto, Ontario, M5K 1N9, by e-mail at email@example.com, or by phone at 416-477-6701. In providing information and receiving and responding to feedback, Northleaf will, upon request, provide accessible formats and/or communication supports to any person;
- training all Northleaf employees and each agent or volunteer that deals with members of the public or third parties on Northleaf’s behalf. Northleaf will maintain ongoing training with all employees on an as needed basis to capture new employees, those returning from a leave of absence, or employees that have not had the chance to attend previous training sessions and in connection with changes to the Policy. The content of such training includes the following:
- review of the purposes of the AODA and requirements of ASCS and IAS;
- review of the Human Rights Code (Ontario) as it pertains to persons with disabilities;
- information on how persons with disabilities may communicate/interact, such as sign language, gestures, boards with symbols, computers, etc.;
- information on how to interact with people with disabilities who use assistive devices or require the assistance of a service animal or a support person;
- information on inappropriate ways of interacting with persons with disabilities;
- information on how to use equipment or devices available at Northleaf’s premises that may help people with disabilities access Northleaf’s office, such as elevators, escalators and automatic door openers; and
- instruction on procedures for what to do if a person with a disability is having difficulty accessing Northleaf’s premises.
B. Integrated Accessibility Standards Regulation
Emergency Response Plans
Compliance Deadline: January 1, 2012
Northleaf is committed to providing clients with publicly available emergency information in an accessible format upon request. In addition, where appropriate in light of the nature of the disability, members of Northleaf with disabilities are provided with individualized emergency response plans to ensure they are aware of the processes in place to safely evacuate from Northleaf’s premises during an emergency. These plans will be available to the public upon request. These plans are reviewed and updated as changes occur to ensure the information remains current and accurate.
Compliance Deadline: January 1, 2015
Northleaf provides training to all Northleaf employees and each agent or volunteer that deals with members of the public or third parties on Northleaf’s behalf on Ontario's accessibility laws and on the Human Rights Code (Ontario) as it relates to people with disabilities. Mandatory training is provided to employees on an ongoing basis. In addition, copies of Northleaf’s policies and any relevant training materials are provided to new employees as soon as practicable following the date of employment and to existing employees as soon as practicable following any changes to Northleaf’s policies. Northleaf’s training programs are provided in a way that best suits the specific duties and responsibilities of the employees, agents and volunteers.
Information and Communications
Compliance Deadline: Various – see below
Northleaf is committed to meeting the communication needs of its clients and employees with disabilities. In keeping with this commitment, Northleaf will complete the following items by the deadlines outlined below:
- by January 1, 2015, Northleaf will ensure that any existing feedback processes are accessible to people with disabilities upon request;
- by January 1, 2016, Northleaf will ensure that all publicly available information is made available in an accessible format upon request and will notify the public about the availability of accessible formats; and
- by January 1, 2021, Northleaf’s external website (www.northleafcapital.com) will conform with the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0, Level AA.
Compliance Deadline: January 1, 2016
Northleaf is committed to fair and accessible employment practices, including ensuring equality of opportunity during both the hiring and employment process. Steps will be taken to ensure that employees and members of the public are notified of the availability of accommodations throughout the recruitment process. During a recruitment process, all applicants, when they are selected to participate in an interview process, will be notified that accommodations are available upon request. If an accommodation is requested, Northleaf 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. If an applicant is offered employment with Northleaf, Northleaf will notify the applicant of its policies for accommodating employees with disabilities concurrently with making the offer of employment.
All Northleaf employees will be informed of Northleaf’s policies that support individuals with disabilities, including providing appropriate accommodations, and will ensure that all information that is generally available to employees or required to perform an employee’s job is provided in accessible formats upon request. New employees will be provided with copies such policies promptly following the date of employment and all employees will receive updated information whenever there is a change to existing policies.
Northleaf has created a process for developing written individual accommodation plans for employees with disabilities. Each time Northleaf considers developing a written individual accommodation plan, prior to taking any steps in connection with the creation of an individual accommodation plan, Northleaf will set out for the employee:
- the manner in which the employee requesting accommodation can participate in the development of his/her individual accommodation plan;
- the means by which the employee will be assessed on an individual basis;
- the manner in which Northleaf can request, at Northleaf’s expense, an evaluation by an outside medical or other expert to assist the employer in determining if accommodation can be achieved and, if so, how accommodation can be achieved;
- the manner in which the employee can request the participation of a representative from Northleaf in the development of the accommodation plan;
- the steps taken to protect the privacy of the employee’s personal information;
- the frequency with which the individual accommodation plan will be reviewed and updated and the manner in which it will be done;
- if an individual accommodation plan is denied, the manner in which the reasons for the denial will be provided to the employee; and
- the means of providing the individual accommodation plan in a format that takes into account the employee’s accessibility needs due to disability.
Northleaf will develop and have in place a return to work process for its employees who have been absent from work due to a disability and require disability-related accommodations in order to return to work. Although each return to work process will be individualized, each such process will outline the steps Northleaf will take to facilitate the return to work of such employee and include a documented individual accommodation plan.
Northleaf will also ensure that the accessibility needs of employees with disabilities are taken into account throughout any internal processes, including the performance review process, the provision of career development and advancement opportunities and redeployment of employees.
Prior to undertaking any renovations to the premises, Northleaf will consider and comply with the requirements of AODA.