Accessibility in Ontario

Ontario Integrated Accessibility Standards Policy

Commitment/Policy Statement

Bennett Jones LLP is committed and guided by the four core principles of Dignity, Independence, Integration, and Equal Opportunity and supports the full inclusion of persons as set out in the Accessibility for Ontarians with Disabilities Act, 2005 (the "AODA"). Bennett Jones LLP shall use every effort to ensure that we meet the needs of persons with disabilities in a timely manner, through the implementation of this policy.

This policy will be implemented in accordance with the time frames established by the Regulation.

Information Guidelines

Under the AODA all public and private sector organizations must meet the requirements of accessibility standards established by regulation. This policy establishes the Integrated Accessibility Standards Regulation in the areas of Information and Communications and Employment for Bennett Jones LLP in accordance with Ontario Regulation 191/11 (the "Regulation") under the AODA. These standards are developed to break down barriers and increase accessibility for persons with disabilities in the areas of information and communications and employment. This policy has been drafted in accordance with the Regulation and addresses how Bennett Jones LLP achieves accessibility through meeting the Regulation's requirements. It provides the overall strategic direction that we will follow to provide accessibility supports to Ontarians with disabilities.

Bennett Jones LLP is governed by this policy as well as the Accessibility Standards for Customer Service Policy and the AODA in meeting the accessibility needs of persons with disabilities.

Multi-Year Accessibility Plan

Bennett Jones LLP's Multi-Year Accessibility Plan (the "Accessibility Plan") outlines a phased-in strategy to prevent and remove barriers from its workplace to improve opportunities for persons with disabilities, and address the current and future requirements of the AODA.

Bennett Jones LLP will report annually on the progress and implementation of the Accessibility Plan, post the information on our website and will provide it in alternative formats upon request. The Accessibility Plan will be reviewed and updated at least once every five years.

Training Employees and Volunteers

Bennett Jones LLP will ensure that training is provided on the requirements of the accessibility standards referred to in the Regulation and continue to provide training regarding the Ontario Human Rights Code as it pertains to persons with disabilities, to:

• all its employees and volunteers;
• all persons who participate in developing Bennett Jones LLP's policies; and,
• all other persons who provide goods, services or facilities on behalf of Bennett Jones LLP.

The training will be appropriate to the duties of the employees, volunteers and other persons.

Training will be provided as soon as practicable. If any changes are made to this policy or the requirements, then training will be provided.

Bennett Jones LLP will keep a record of the training it provides.

Information and Communications Standards

Bennett Jones LLP will create, provide and receive information and communications in ways that are accessible to people with disabilities.

If Bennett Jones LLP determines that it is not technically feasible to convert the information or communications, or the technology to convert the information or communications is not readily available, Bennett Jones LLP will provide the person that requires the information with an explanation as to why the information or communications are unconvertible; and a summary of the unconvertible information or communications.

Emergency Information

If Bennett Jones LLP prepares emergency procedures, plans or public safety information and makes the information available to the public, we shall provide the information in an accessible format or with appropriate communication supports, as soon as practicable, upon request.

Feedback

Bennett Jones LLP has a process in place for receiving and responding to feedback and will ensure that those processes are provided in accessible formats and with communication supports upon request.

Accessible Formats and Communication Supports

Upon request, Bennett Jones LLP 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. Bennett Jones LLP will consult with the person making the request in determining the suitability of an accessible format or communication support.

Bennett Jones LLP will also notify the public about the availability of accessible formats and communication supports.

Accessible Websites and Web Content

Bennett Jones LLP will ensure that our Internet websites meet the requirements of the AODA standard, including web content, and will conform to the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0, at Level A, except where this is impracticable.

Employment Standards

The Employment Standard builds upon the existing requirements under the Ontario Human Rights Code in relation to how we provide accessibility throughout the entire employment cycle. It applies in respect to employees and does not apply to volunteers and other non-paid individuals.

Recruitment

Bennett Jones LLP will notify its employees and the public about the availability of accommodation for applicants with disabilities for the three situations below:

• During the recruitment process when job applicants are individually selected to participate in an assessment or selection process;
• If a selected applicant requests accommodation, Bennett Jones LLP shall consult with the applicant and provide or arrange for the provision of a suitable accommodation that takes into account the applicant's disability;
• Notify successful applicants of the policies for accommodating employees with disabilities.

Employee Notification

Bennett Jones LLP will inform its employees of its policies (and any updates to those 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. This information will be provided to new employees as soon as practicable after commencing employment.

Accessible Formats and Communication Supports for Employees

In addition and where an employee with a disability requests it, Bennett Jones LLP will consult with the employee to provide or arrange for the provision of accessible formats and communication supports for:

• Information that is needed in order to perform the employee's job;
• Information that is generally available to employees in the workplace; and,
• Consult with the employee making the request in determining the suitability of an accessible format or communication support.

Workplace Emergency Response Information

Bennett Jones LLP 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 Bennett Jones LLP is aware of the need for accommodation due to the employee's disability. Bennett Jones LLP will provide this information as soon as practicable after becoming aware of the need for accommodation due to the employee's disability.

Where the employee requires assistance, Bennett Jones LLP will, with the consent of the employee, provide the workplace emergency response information to the person designated by Bennett Jones LLP to provide assistance to the employee.

Bennett Jones LLP 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.

Documented Individual Accommodation Plans

Bennett Jones LLP will maintain a written process for the development of documented individual accommodation plans for employees with disabilities.

The process for the development of documented individual accommodation plans shall include the following elements:

• The employee's participation in the development of the accommodation plan;
• Assessment on an individual basis;
• Identification of accommodation to be provided;
• Timelines for the provision of accommodation;
• Bennett Jones LLP may request an evaluation by outside medical or other expert, at our expense, to assist with determining accommodation and how to achieve accommodation;
• Employee may request participation of a representative from the workplace in the development of the accommodation plan;
• 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 denied, the reasons for denial are to be provided to the employee;
• A format that takes into account the employee's disability needs;
• If requested, any information regarding accessible formats and communication supports provided;
• Identification of any other accommodation that is to be provided.
• If requested, information regarding accessible formats and communications supports provided will also be included in individual accommodation plans.

In addition, the plans will include individualized workplace emergency response information (where required), and will identify any other accommodation that is to be provided.

Return to Work Process

Bennett Jones LLP maintains 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 to work process outlines the steps Bennett Jones LLP will take to facilitate the return to work and will include documented individual accommodation plans as part of the process.

This return to work process will not replace or override any other return to work process created by or under any other statute (i.e., the Workplace Safety Insurance Act, 1997).

Performance Management, Career Development and Advancement & Redeployment

Bennett Jones LLP 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, and/or when redeploying employees.

Transportation Standard

The Transportation Standard will make it easier for people to travel in Ontario, including persons with disabilities, older Ontarians and families travelling with children with strollers. Bennett Jones LLP is not affected by the Transportation Standard but will ensure that staff is aware of the future changes and positive impact it will have on public transportation.

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 and 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 the:

Human Resources Department

- By Phone: 416-863-1200
- By Fax: 416-863-1716
- By Email: HRDeptTor@bennettjones.com
- In Writing or in Person at the following address:

Bennett Jones
3400 One First Canadian Place
P.O. Box 130
Toronto, Ontario
M5X 1A4

- Or in any other form that takes into account the requester's disability.