PALLETT VALO LLP – 77 City Centre Drive, Suite 300 West Tower Mississauga, ON L5B 1M5
ACCESSIBILITY FOR ONTARIANS WITH DISABILITIES ACT, 2005
INTEGRATED ACCESSIBILITY STANDARDS – MULTI YEAR PLAN – Updated September, 2019
Part I – GENERAL REQUIREMENTS
|3||Establishment of Accessibility Policies||3.(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.||Customer Service and IAS policies in place for compliance||Completed||January 1, 2014|
|Install a process to regularly review these policies with all firm members||Completed||January 1, 2016|
|Ensure communication is in place during onboarding||Completed||January 1, 2016|
|4||Accessibility Plans||4.(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.
|Develop the plan and seek approval||Completed||January 1, 2014|
|Work with website provider to ensure plan is posted within compliance timeframe||Completed|
|Pallett Valo LLP has chosen to review its plan every three years and is just completing its first review||Completed||September 12, 2017|
|6||Self-Serve Kiosks||6.(2) Large organizations and small organizations shall have regard to the accessibility for persons with disabilities when designing, procuring or acquiring self-service kiosks.||Pallett Valo does not own the parking kiosk. It is owned by the Landlord, however Pallett Valo LLP will advise landlord of the issue with the parking kiosk and remind them of their obligation under this legislation.||Completed||January 1, 2014|
|7||Training||7.(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.
|Training was developed in-house by our Employment and Labour Group.||Completed||January 1, 2015|
|Power-points and videos of the training are housed on our intranet.||Completed|
|Establish an AODA Committee||Completed||January, 2017|
|Install an annual review process of the training material and policies||Completed||June, 2017|
|Review documentation method of keeping track of training||Completed||January, 2017|
|Review requirements with all appropriate vendors||Completed||November, 2017|
|Develop an training plan on not just the legislation but also inclusivity and understanding disabilities.
Unconscious Bias training has been conducted and an Inclusivity Committee has been formed.
PART II – INFORMATION AND COMMUNICATIONS STANDARDS
|11||Feedback||11.(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.||Identify all feedback methods being used, and discuss options for accessible formats to ensure we are prepared should we receive a request||Completed||January 1, 2015|
|Put onus on the vendors we use to develop these formats to create them in an accessible format, rather than waiting for a request for accessible formats – most have been spoken to but consider sending a letter to all vendors||Completed||January, 2017|
|Conduct a review of all of our feedback forms and processes.
Next review 2020.
|12||Accessible Formats & Communication Supports||12.(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.
|All firm members must be made aware that requests can be made for alternative format of communication and PV must be able to provide it within a reasonable timeframe.||Completed||January 1, 2016|
|Establish AODA Document Creation Team||In Progress||December, 2020|
|Review with team document creation standards for creating accessible documents||In Progress||December, 2020|
|Decide on best approach: Superusers for creating accessible documents or installing changes so that our Document Creation Policy is changed to say that all documents are to be created in an accessible format based on Microsoft guidelines||In Progress||December, 2020|
|Develop a training library that explores accessibility options for various forms of disability, so that all firm members understand the various options that could be considered with respect to accessible formats and communication supports||In Progress||December, 2020|
|12||12.(2) The obligated organization shall consult with the person making the request in determining the suitability of an accessible format or communication support.||Communicate to staff and management that we can offer the following formats that are readily available.||Completed||January 1, 2016|
|Develop a formal process/protocol for situations where requests are made.
Reminder protocol to be put in place.
|12||12.(3) Every obligated organization shall notify the public about the availability of accessible formats and communication supports.||Post on Website in our Statement of Commitment on Accessibility||Completed||January 1, 2016|
|Notification posted in reception area||Completed||December, 2017|
|Consider adding comment to email signatures (if you require this information in an alternative format please let us know)||Completed||January, 2017|
|Arrange for notation on all relevant marketing materials produced from January 1, 2016.
Review to be conducted.
|13||Emergency Procedures, Plans or Public Safety Info||13.(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.||Pallett Valo LLP is governed by the emergency procedures set out by our landlord, and as such is not in control of this aspect.||N/A||January 1, 2012|
|Consider all internal emergency procedures being created under our business continuity planning and how accessibility issues are integrated.||Completed||June, 2017|
|Meet with JHSC to discuss the implications of having guests in the firm that have a disability and emergency evacuation plans we should have in place in addition to those by the landlord.||Completed||January, 2017|
|Install a processto help us better handle an emergency situation.||Completed||January, 2017|
|14||Accessible Websites & Web Content||14.(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.||Website redesign was completed with written assurances from vendor that it conforms with WCAG 2.0 Level A.||Completed||January 1, 2014
New internet websites and web content on those sites must conform with WCAG 2.0 Level A.
|Independent audits on colour contrast and some accessibility testing done at that time||Completed||January 1, 2021
All internet websites and web content must conform with WCAG 2.0 Level AA
|Vendors advised that materials created for our website must be done so in an accessible format.||Completed|
|Extensive website and its content review is being completed by an independent expert who will advise us of any issues with our Website as it relates to accessibility. We will install a plan to correct any issues identified.
Review again (December, 2020).
|Completed (June, 2018)|
|Training Materials General||While Pallett Valo LLP is not an educational institution we believe that to the degree we do conduct seminars we should abide by this section therefore:||
|All seminar and newsletter material will be developed in an accessible format and/or have notification on the materials that the information is available in an accessible format.||Completed|
|Invitations to our seminars will include wording whereby we will ask participants if they need an accommodation to participate in the seminar.
Review to be conducted.
PART III – EMPLOYMENT STANDARD
|22||Recruitment – General||22. Every employer shall notify its employees and the public about the availability of accommodation for applicants with disabilities in its recruitment processes.||Install notification process including the development of standard wording on all job postings with notification to recruiting firms used.||Completed||January 1, 2016
|Review website to make sure notification is clear in the careers section and implement any website related changes required from audit||Completed|
|23||Recruitment, Assessment or Selection Process||23.(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 and selection activities must include human resources.||Completed||January 1, 2016
|Human resources will ensure that notification takes place and is involved in the provision of suitable accommodation||Completed|
|Conduct a full review of all recruitment policies and process in this regard||In progress|
|Utilize resources being developed to understand accommodation methods for various disabilities better to see if our processes and testing methods can be made more accessible at design||In Progress|
|24||Notice to Successful Applicants||24. Every employer shall, when making offers of employment, notify the successful applicant of its policies for accommodating employees with disabilities.||Notification is installed in our precedent system for offer letters at all levels||Completed||January 1, 2016|
|25||Informing 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.||All training, policies, multiyear plan, resources library information is housed in the firm’s intranet system under AODA.||Completed||January 1, 2016|
|Install system whereby all employees are notified of any changes to this section of the internet and prompted to review the information||Completed||January, 2017|
|25||25.(2) Employers shall provide the information required under this section to new employees as soon as practicable after they begin their employment.||A full review of the AODA section of the intranet which includes what is posted on the website in terms of our Statement of Commitment and our Multi-Year plan is incorporated in our onboarding process and checklists||Completed||January 1, 2016|
|25||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.||Employees informed in the same was as 25 (1) – see above||Completed||January 1, 2016|
|Currently done by email but exploring an automatic electronic notification via our intranet.|
|26||Accessible Formats & Communication Supports for Employees||26.1 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) Informationthatisgenerallyavailableto employees in the workplace.
|Regularly job descriptions are reviewed by the employee and his/her supervisor. Install into the system a method for self- identification in a confidential manner.||In Progress||January 1, 2016|
|Educate management and practice group head on various methods of accommodation and a better understanding of various disabilities. This would be helpful in general with an aging workforce.||In Progress|
|26||26.2. The employer shall consult with the employee making the request in determining the suitability of an accessible format or communication support.||Formalize current processes and place on firm intranet.||In Process||January 1, 2016|
|27||Workplace Emergency Response Information||27.(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.||Process in place||Completed||January 1, 2012|
|Ensure there is a formalized process that encourages self-identification in this regard, in a confidential manner, that is integrated into the business continuity plans currently being developed||Completed||January, 2017|
|27||(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.||Process in place||Completed||January 1, 2012|
|27||(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.||Process in place||Completed||January 1, 2012|
|27||(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.
|Process in place||Completed||January 1, 2012|
|28||Documented Individual Accommodation Plans||28.(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.||Formalize process in written format||Completed||December, 2017|
|28||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.
|Formalize process in written format||Completed||December, 2017|
|29||Return to Work Process||29.(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.
|Formalize process in written format||Completed||December, 2017|
|29||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||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.||This language to be included in the formalized process||Completed||December, 2016|
|30||Performance 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.||This language has been included in our performance management policy||Completed||January 1, 2016|
|31||Career 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.||This language has been included in our career development and advancement policies||Completed||January 1, 2016|
|32||Redeployment||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.||Include language in policies where applicable.||Completed||January 1, 2016|