Accessibility for Ontarians with Disabilities Act, 2005

Integrated Accessibility Standards – Multi Year Plan

Part I – General Requirements

#

Section # from Act

Initiative

Requirement Outlined in the Act

First National's Actions

Status

Compliance Date

13Establishment of Accessibility Policies3.(1) Every obligated organization shall develop, implement and maintain policies governing how the organization achieves or will achieve accessibility through meeting its requirements under the accessibility standards referred to in this Regulation.  Developed and implemented policy.CompletedJanuary 1, 2014
24Accessibility Plans4.(1) Large organizations shall, 

a) establish, implement, maintain and document a multi-year accessibility plan, which outlines the organization‘s strategy to prevent and remove barriers and meet its requirements under this Regulation; 

b) post the accessibility plan on their website, if any, and provide the plan in an accessible format upon request; and 

c) review and update the accessibility plan at least once every five years.

Completed an accessibility plan by determining barriers that exist at First National.

Posted plan and policy on internal and external website. The plan will be available in accessible format, upon request.

HR reviewed the plan and policy in January 2016 and has committed to reviewing the plan minimally once every 5 years, the next review will occur on January 1st, 2019. 

CompletedJanuary 1, 2014
37Training7.(1) Every obligated organization shall ensure that training is provided on the requirements of the accessibility standards referred to in this Regulation and on the Human Rights Code as it pertains to persons with disabilities to, 
(a) all employees, and volunteers; 
(b) all persons who participate in developing the organization‘s policies; and 
(c) all other persons who provide goods, services or facilities on behalf of the organization.
All existing employee completed training in December 2014 and new employees are required to complete training within 30 days of their start date.CompletedJanuary 1, 2015

Part II - Information and Communications Standards

#

Section # from Act

Initiative

Description

First National's Actions

Status

Compliance Date

413Emergency Procedures, Plans or Public Safety Information13.(1) In addition to its obligations under section 12, if an obligated organization prepares emergency procedures, plans or public safety information and makes the information available to the public, the obligated organization shall provide the information in an accessible format or with appropriate communication supports, as soon as practicable, upon request.First National does not make this information available to the public however we have established internal procedures for emergency related information. 

We have confirmed that our landlord is compliant with providing this information to the public.
Not applicableJanuary 1, 2012
514Accessible Websites & Web Content14.(2) Designated public sector organizations and large organizations shall make their internet websites and web content conform with the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0, initially at Level A and increasing to Level AA, and shall do so in accordance with the schedule set out in this section.

First National has confirmed that our website meets the accessibility requirements (Level A) identified in this act. 

First National will continuously review WCAG guidelines to keep informed of any changes and updates.

First National will ensure any new vendors meet the requirements outlined in the WCAG 2.0.

Completed the January 1st, 2014 requirement.

January 1, 2014
New internet websites and web content on those sites must conform with WCAG 2.0 Level A. 

January 1, 2021 
All internet websites and web content must conform with WCAG 2.0 Level AA, other than, 
• success criteria 1.2.4 Captions (Live)
• success criteria 1.2.5 Audio Descriptions (Pre-recorded). 

 
611Feedback11.(1) Every obligated organization that has processes for receiving and responding to feedback shall ensure that the processes are accessible to persons with disabilities by providing or arranging for accessible formats and communications supports, upon request.

The person making the accommodation request will be consulted prior to arranging any accessible formats and communications support and will meet the criteria as outlined in this section.

CompletedJanuary 1, 2015
712Accessible Formats & Communication Supports12.(1) Except as otherwise provided, every obligated organization shall upon request provide or arrange for the provision of accessible formats and communication supports for persons with disabilities, 
a) in a timely manner that takes into account the person‘s accessibility needs due to disability; and 
b) at a cost that is no more than the regular cost charged to other persons.
The person marking the accommodation request will be consulted prior to arranging any accessible formats and communications support and First National will meet the criteria as outlined in this section.

Completed

January 1, 2016

12.(2) The obligated organization shall consult with the person making the request in determining the suitability of an accessible format or communication support.The person making the accommodation request will be consulted prior to arranging any accessible formats and communications support and First National will meet the criteria as outlined in this section.

Completed

January 1, 2016
   12.(3) Every obligated organization shall notify the public about the availability of accessible formats and communication supports. The availability of accessible formats and communication supports is included in a variety of public places, including but not limited to the company's website, job postings, etc.

Completed

January 1, 2016

Part III - Employment Standard

#

Section # from Act

Initiative

Description

First National's Action

Status

Compliance Date

827Workplace Emergency Response Information27.(1) Every employer shall provide individualized workplace emergency response information to employees who have a disability, if the disability is such that the individualized information is necessary and the employer is aware of the need for accommodation due to the employee‘s disability.

First National sends quarterly email reminders to all of its employees to advise the HR team if they require assistance during a workplace emergency (this includes employees beginning a return to work plan). New employees are also advised during the New Hire Orientation which occurs within one month of their start date.

Employees are required to advise HR when they no longer need assistance.

HR and the employee’s Manager will work with the employee that requires assistance and create a plan based on the type of accommodation required during a workplace emergency. Employees are required to complete the Individualized Employee Emergency Response Information Form.

First National has documented internal procedures referred to as the Fire Safety Evacuation Procedures for each office.
CompletedJanuary 1, 2012
9  (2) If an employee who receives individualized workplace emergency response information requires assistance and with the employee‘s consent, the employer shall provide the workplace emergency response information to the person designated by the employer to provide assistance to the employee. 
First National’s Joint Health and Safety Committee, Health and Safety Coordinator, Management team and the HR team may have access to this information at any given time for the purpose of assisting the employee. Employees are advised of this in the consent section of the Individualized Employee Emergency Response Information Form.CompletedJanuary 1, 2012
   (3) Employers shall provide the information required under this section as soon as practicable after the employer becomes aware of the need for accommodation due to the employee‘s disability. First National has committed to providing this information to the employee as soon as possible.

 CompletedJanuary 1, 2012
   (4) Every employer shall review the individualized workplace emergency response information, 
(a) when the employee moves to a different location in the organization; 
(b) when the employee‘s overall accommodations needs or plans are reviewed; and 
(c) when the employer reviews its general emergency response policies.
First National is committed to reviewing the individualized workplace emergency response information as outlined in this section. First National has in place processes to identify when these situations occur. CompletedJanuary 1, 2012
1022Recruitment - General22. Every employer shall notify its employees and the public about the availability of accommodation for applicants with disabilities in its recruitment processes.All recruitment processes make candidates and employees aware that accommodations are available as outlined in this section i.e. through job postings.CompletedJanuary 1, 2016
1123Recruitment, Assessment or Selection Process23.(1) During a recruitment process, an employer shall notify job applicants, when they are 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. 
(2) If a selected applicant requests an accommodation, the employer shall 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.

All recruitment processes make candidates and employees aware that accommodations are available as outlined in this section at the beginning of the interview process. 

The person making the accommodation request will be consulted prior to arranging any accommodations and will take into account the person's accessibility needs. 

CompletedJanuary 1, 2016
1224Notice to Successful Applicants24. Every employer shall, when making offers of employment, notify the successful applicant of its policies for accommodating employees with disabilities.All recruitment processes make candidates and employees aware that accommidations are available as outlined in this section i.e. at the offer stage.CompletedJanuary 1, 2016
1325Informing Employees of Supports

25.(1) Every employer shall inform its employees of its policies used to support its 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. 

Employees are informed through training that job accommodations are available if and when needed due to disability. 

Employees will be provided with this information within the first week of their start date. 

Employees will be provided with updates 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. First National has in place a process for communicating such changes. 
CompletedJanuary 1, 2016
   25. (2) Employers shall provide the information required under this section to new employees as soon as practicable after they begin their employment.   Completed January 1, 2016
   25. 3) Employers shall provide updated information to its 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.Completed January 1, 2016
1426Accessible Formats & Communication Supports for Employees26.(1) In addition to its obligations under section 12, where an employee with a disability so requests it, every employer shall consult with the employee to provide or arrange for the provision of accessible formats and communication supports for, 

(a) information that is needed in order to perform the employee‘s job; and

(b) information that is generally available to employees in the workplace.
The person making the accommodation request will be consulted prior to arranging any accommodations as outlined in this section. CompletedJanuary 1, 2016
   26.(2) The employer shall consult with the employee making the request in determining the suitability of an accessible format or communication support.CompletedJanuary 1, 2016
1528Documented Individual Accommodation Plans28.(1) Employers, other than employers that are small organizations, shall develop and have in place a written process for the development of documented individual accommodation plans for employees with disabilities.An individual accommodation plan template and process has been established for employees with disabilities. The process requires detailed information regarding the limitations and the accommodation required. 

 
The process for the development of documented individual accommodation plans includes the criteria as outlined in this section. 
CompletedJanuary 1, 2016
   

28.(2) The process for the development of documented individual accommodation plans shall include the following elements: 

1. The manner in which an employee requesting accommodation can participate in the development of the individual accommodation plan.

2. The means by which the employee is assessed on an individual basis. 

3. The manner in which the employer can request an evaluation by an outside medical or other expert, at the employer‘s expense, to determine if and how accommodation can be achieved.

4. The manner in which the employee can request the participation of a representative from their bargaining agent, where the employee is represented by a bargaining agent, or other representative from the workplace, where the employee is not represented by a bargaining agent, in the development of the accommodation plan. 

5. The steps taken to protect the privacy of the employee‘s personal.

6. The frequency with which the individual accommodation plan will be reviewed and updated and the manner in which it will be done.

7. If an individual accommodation plan is denied, the manner in which the reasons for the denial will be provided to the employee.

8. The means of providing the individual accommodation plan in a format that takes into account the employee‘s accessibility needs due to disability.
An individual accommodation plan template and process has been established for employees with disabilities. The process requires detailed information regarding the limitations and the accommodation required. 

 
The process for the development of documented individual accommodation plans includes the criteria as outlined in this section. 
CompletedJanuary 1, 2016
1629Return to Work Process29.(1) Every employer, other than an employer that is a small organization, 

(a) shall 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; and 

(b) shall document the process.
A return to work process exists through the company’s Short Term and Long Term Disability Plans.

The return to work process includes the criteria outlined in this section.

CompletedJanuary 1, 2016
   29.(2) The return to work process shall, 

(a) outline the steps the employer will take to facilitate the return to work of employees who were absent because their disability required them to be away from work; and 
(b) use individual documented accommodation plans, as described in section 28, as part of the process.
   

29.(3) The return to work process referenced in this section does not replace or override any other return to work process created by or under any other statute.

1730Performance Management

30.(1) An employer that uses performance management in respect of its employees shall take into account the accessibility needs of employees with disabilities, as well as individual accommodation plans, when using its performance management process in respect of employees with disabilities.

The company’s performance management processes takes into consideration the employee’s accessibility needs and individual accommodation plans when using performance management processes in respect of employees with disabilities. CompletedJanuary 1, 2016
1831Career Development & Advancement

31.(1) An employer that provides career development and advancement to its employees shall take into account the accessibility needs of its employees with disabilities as well as any individual accommodation plans, when providing career development and advancement to its employees with disabilities.

Any programs related to career development and advancement at First National take into account the accessibility needs of the employee with the disability as well as any individual accommodation plans when providing career development and advancement to its employees. CompletedJanuary 1, 2016
1932Redeployment

32.(1) An employer that uses redeployment shall take into account the accessibility needs of its employees with disabilities, as well as individual accommodation plans, when redeploying employees with disabilities.

Not applicableCompletedJanuary 1, 2016

File Name: Multi Year Plan
Policy Implementation Date: December 2013
Last Revision Date: January 11th, 2016

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