AODA – Integrated Accessibility Standards Regulation Employment Policy

Cole-Munro Foods Group Inc. will develop, implement and maintain policies governing how it will achieve accessibility through Training; Recruitment, Assessment and Selection; Accessible Formats and Communication Supports for Employees; Workplace Emergency Response Information; Performance Management, Career Development and Advancement; Redeployment.

Cole-Munro will provide training for its employees and volunteers regarding the IASR and the Ontario Human Rights Code as they pertain to individuals with disabilities. Training will also be provided to individuals who are responsible for developing Cole-Munro’s policies, and all other persons who provide goods, services or facilities on behalf of Cole-Munro. Cole-Munro will notify employees and the public about the availability of accommodation for job applicants who have disabilities. Applicants will be informed that these accommodations are available, upon request, for the interview process and for other candidate selection methods. Where an accommodation is requested, Cole-Munro will consult with the applicant and provide or arrange for suitable accommodation. Cole-Munro will ensure that employees are aware of our policies for employees with disabilities and any changes to these policies as they occur.

If an employee with a disability requests it, Cole-Munro will provide or arrange for the provision of accessible formats and communication supports. Cole-Munro will consult with the employee making the request to determine the best way to provide the accessible format or communication support.

Where required, Cole-Munro will create individual workplace emergency response information for employees with disabilities. This information will consider the unique challenges created by the individual's disability and the physical nature of the workplace and will be created in consultation with the employee.

Cole-Munro will consider the accessibility needs of employees with disabilities when implementing performance management processes, or when offering career development or advancement opportunities. The accessibility needs of employees with disabilities will be considered in the event of redeployment.

Accessibility Standards Policy and Commitment Plan

Intent

Cole-Munro Foods Group Inc. is committed to providing a barrier-free environment for all stakeholders, including clients, employees, job applicants, suppliers, and any visitors who enter the premises, access information provided by the company, or use the company’s goods and services.

The company will work to identify and remove barriers, and prevent new barriers, for persons with disabilities as they relate to employment, communication, the built environment, and transportation at Cole-Munro. This policy outlines the company’s accessibility plan and strategy for identifying, removing, and preventing these barriers.

Definitions

Barrier: Includes any physical, architectural, technological, or attitudinal, anything that is based on information or communications, or anything that is the result of a policy or a practice that hinders the full and equal participation in society of a person with an impairment, including a physical, mental, intellectual, cognitive, learning, communication, or sensory impairment, or a functional limitation.

Disability: Any impairment, including a physical, mental, intellectual, cognitive, learning, communication, and sensory impairment, or functional limitation that is either permanent, temporary, or episodic in nature. It can be evident or not in interaction with a barrier to hinder a person’s full and equal participation in society.

Accessibility Plan

Cole-Munro has developed and will maintain a Multi-Year Accessibility Plan that sets out our strategy to identify and remove barriers, and prevent new barriers, for persons with disabilities. The accessibility plan will include an overview of our policies, programs, practices, and services in relation to the identification and removal of barriers, and the prevention of new barriers. The accessibility plan will be prepared and reviewed every five years following.

The accessibility plan will be developed in consultation with persons with disabilities and indicate the manner in which they were consulted. This process will be followed for the creation of, and any updates made to the plan. Cole-Munro will adhere to all requirements made by regulation in the development and ongoing maintenance of the accessibility plan. If Cole-Munro acquires self-service kiosks in the future, we will have consideration to the accessibility for persons with disabilities to ensure the kiosk have appropriate accessibility features. Cole-Munro welcomes all persons with disabilities who use assistive devices. Persons with disabilities may bring their service animal or support person in order to access the parts of our premises that are open to the public and other third parties. ColeMunro will ensure that all employees are trained on how to interact with people with disabilities and their service animal or support person. Customers and third parties will be notified of planned or unplanned disruptions to any assistive facilities or services used by a person with disabilities. This will include the reason for disruption, duration expected and any alternate facilities or services available.

Training

Cole-Munro will provide training to all of its employees, volunteers, persons who participate in developing Cole-Munro’s policies on the requirements of the accessibility standards referred to in the Regulation and on the Code as it pertains to persons with disabilities. Training will be provided as soon as practicable and will be included alongside with orientation for new hires. Cole-Munro will keep records of its training.

Employment

Recruitment & Assessment or Selection Process: Cole-Munro understands that improving workplace accessibility and ensuring an accessible recruitment and selection process for applicants with disabilities can contribute to a more diverse and welcoming workplace culture. The company will make every effort to identify, remove, and prevent barriers by developing inclusive employment procedures that support persons with disabilities. Where necessary, accommodations will be made during the recruitment, assessment, and selection stages, and throughout the employment life cycle.

Notice to Successful Applicants: When making offers of employment, Cole-Munro will notify successful applicants of its policies for accommodating employees with disabilities, upon request.

Informing Employees of Supports: Cole-Munro will continue to inform their employees of its policies and procedures (and any changes or updates to this policy) used to support employees with disabilities. This information will be provided to new employees as soon as practicable after commencing employment.

Performance Management, Career Development and Advancement: All training and development programs provided will consider employee’s barriers and abilities. ColeMunro will consider 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.

Return to Work Process: Cole-Munro will develop and maintain a documented return to work process for its employees who have been absent from work due to a disability and who require disability-related accommodations in order to return to work. The return-towork process outlines the steps 3M will take to facilitate the return to work and will include documented individual accommodation plans as part of the process.

Accessible Formats and Communication

Upon request, Cole-Munro will provide or arrange for accessible formats and communication supports for employees, applicants, or persons accessing the company’s goods or services. The company will consult with the individual to determine the specific barrier and the best way to provide support. Such accessible formats and communication supports are conversion-ready and will be provided in a timely manner and at no additional cost.

Workplace Emergency Response Information

Cole-Munro will provide individualized workplace emergency response information to employees with disabilities, if the disability is such that the individualized information is necessary and if Cole-Munro is aware of the need of accommodation. This information will be provided as soon as practicable after becoming aware of the need for accommodation. Where an employee requires assistance, Cole-Munro will designate a person to aid and will provide workplace emergency response information to that person with their consent. Cole-Munro will review this information when needed. Cole-Munro will maintain a written process for the development of documented individual accommodation plans for employees with disabilities. If requested, information regarding accessible formats and communications supports provided will also be included in individual accommodation plans.

Built Environment

Cole-Munro will work to ensure that the built environment, including building interiors and exteriors, are designed to facilitate barrier-free access to goods or services. If areas of the built environment are not accessible for certain individuals with disabilities, the company will work with the individual to provide an alternate means of access.

Transportation

Cole-Munro will ensure accessible transportation services are available for necessary individuals with a disability. If an individual cannot use conventional transportation services, the company will provide an alternate accessible method of transportation. Options will take into account the availability of the transportation, the nature of the disability, and any associated safety concerns.

Feedback

Cole-Munro welcomes feedback regarding our accessibility plan and any barriers encountered by persons with disabilities. Feedback forms, along with alternate methods of providing feedback verbally (in person or by telephone) or written (handwritten, delivered, website, or e-mail), will be available upon request. Individuals who provide formal feedback will receive acknowledgement of their feedback, along with any resulting actions based the concerns or complaints that were submitted.

Feedback can be submitted to:
Kandice Cross
Accounting/Human Resources Manager
519-637-6396
175 Edward Street St. Thomas, ON N5P 4A8
accounting@colemunro.com

Multi-Year Accessibility Plan

Standard	Accessibility Requirement	Action Plan	Responsibility	Status
General	Establishment of Accessibility Policies	Create documents to establish accessibility plan Draft written commitment statement and include it in MYAP and policy	Human Resources	Complete
General	Procuring or acquiring goods, services or facilities	Use accessibility criteria when procuring or acquiring goods or services except where it is not practicable to do so	Human Resources	Complete
General	Designing/procuring or acquiring self-serve kiosks	Identify any self-service kiosks (none) Consider including procurement terms in any kiosk purchase contracts to provide for potential accessibility issues.	Human Resources	Complete
General	Training on IASR and the Code	Provide training on the requirements of the accessibility standards referred to in IASR and on the Human Rights Code as they pertain to persons with disabilities to employees, volunteers, persons who participate in developing the organization’s policies, persons who provide goods, services or facilities on behalf of the organization Provide training to all employees, etc., and new employees, etc. as part of orientation Create and maintain online record of training completion. Record future changes in policy and update training accordingly Create online training materials and program. Reviewing training and adjust as appropriate for various levels and duties of employees	Human Resources	Ongoing
General	Accessibility Plans	Draft a MYAP and post it to the website Complete review at least every five years Amend MYAP and repost on website as necessary Provide in an accessible format upon request	Human Resources	Ongoing
Communication	Feedback Process	Ensure that existing and new processes for receiving and responding to feedback are accessible to persons with disabilities by providing or arranging for the provision of accessible formats and communication supports, upon request and in a timely manner Respond to email inquiries or telephone calls from employees, customers and other stakeholders as required. Provide or arrange for accessible formats for giving and receiving feedback upon receiving a request	Human Resources	Complete
Communication	Accessible formats and communication supports	Provide accessible formats and communication supports Consult with the person making the request to determine the suitability of the accessible format or communication support Notify the public about the availability of accessible formats and communication supports	Human Resources	Complete
Communication	Emergency procedures, plans or public safety information	If aware of a need for accommodation, provide individualized workplace emergency procedures and plans to employee who have a disability	Human Resources	Ongoing
Communication	Accessible websites and web content	Ensure that new web content conforms to WCAG 2.0 Level A.	Human Resources	Ongoing
Employment	Recruitment, assessment and selection processes	Review and, as necessary, modify existing recruitment policies Specify that accommodation for persons with disabilities is available on all job postings Include accommodations available prior to scheduling interviews or assessments If a selected applicant requests accommodation, consult with the applicant to arrange a suitable accommodation that meets the needs of their disabilities	Human Resources	Ongoing
Employment	Informing employees of supports	Informing employees and new hires policies on job accommodation Keep employees up to date on changes to the policy with respect to disability Provide suitable accessible formats and communication supports for employees to perform their job Continue to revise and re-issue Employee Handbook at all levels as necessary Re-issue updated policies in Handbook and communicate in employee meetings as necessary Include AODA and disability policies in orientation package(s)	Human Resources	Complete
Employment	Accessible formats and communication supports for employees	Provide all information that is generally available to employees in an accessible manner as required Continue with existing procedures for responding to accommodation/ accessibility requests and determining the suitability of the request Respond to additional accessibility requests on a case by case basis as required	Human Resources	Complete
Employment	Workplace emergency response information	Individualized workplace emergency response information procedures have been developed for employees with disabilities as required Continue to review existing and future accommodation needs and provide individualized information as necessary Employees to notify management in a timely manner when their needs change; respond accordingly	Human Resources	Ongoing
Employment	Documented individual accommodation plans	Refine existing written process for responding to accommodation/accessibility requests and developing accommodation plans	Human Resources	Ongoing
Employment	Return to work process	Include the process of how the employee requesting accommodation can participate in the plan Include process of how the individual is assessed Provide process of how Cole-Munro can request an evaluation of an outside medical expert Ensure steps are in place to protect all individual’s privacy Provide frequency of how often the accommodation plan will be reviewed Provide an employee with reasons for denial if the plan is denied Provide the accommodation plan in a format that considers the employees accessibility needs	Human Resources	Complete
Employment	Performance management process	Review, assess and modify policies to ensure compliance Consider needs of employees with disabilities when using performance management processes Continue using established performance management process; assess accommodation needs on individual basis	Human Resources	Complete
Employment	Career development and advancement	Review, assess and modify policies to ensure compliance Consider needs of employees with disabilities when using career development and advancement processes Continue using established advancement process; assess accommodation needs on individual basis	Human Resources	Complete
Employment	Notice to successful applicants	Review and, as necessary, modify existing recruitment policies Provide notice of policies on accommodation to employees with disabilities upon offer of employment Revise offer of employment templates to include requisite accessibility/ accommodation information	Human Resources	Complete
Customer Service	Use of service animals and support persons	Review, assess and modify policies to ensure compliance	Human Resources	Complete
Customer Service	Provide notice of any temporary disruption to services that may affect persons with disabilities	Advise service areas of requirement and follow-up as required Commitment written into policies Advise all employees that notice is required to all office staff of temporary disruption	Human Resources	Complete
Customer Service	Provide accessible customer service training to all staff	Communicate requirements of training Distribute training program with instructions and deadlines for reporting Deliver training to HR via HRDownloads	Human Resources	Ongoing
Customer Service	Establish a feedback process for providing goods, services, or facilities to persons with disabilities	Communicate and train staff providing persons with disabilities on accessibility Create and maintain database of all feedback received.	Human Resources	Complete
Customer Service	Notice of availability of documents	All policies and other material made publicly available in binders available by request upon entrance	Human Resources	Complete
Customer Service	Format of documents	Respond to employees, customers and other stakeholders as required	Human Resources	Complete