ACCESSIBILITY
“Where Extraordinary People achieve Exceptional Results” ACCESSIBILITY POLICIES AND MULTI-YEAR ACCESSIBILITY PLAN 2011-2021
TABLE OF CONTENTS
Accessibility Policies and Multi-Year Accessibility Plan
- Statement of Commitment
- Multi-Year Accessibility Plan Overview
- Accessible Emergency Information and Workplace Emergency Response
- Training
- Kiosks
- Information and Communications
- Accessible Websites and Web Content
- Feedback Process
- Employment
- Individual Associate Accommodation Plan and Return to Work Policy
- Performance Management, Career Development and Redeployment
- Other Accessibility Barriers
- Design of Public Spaces
- Feedback Process and Request for Information
- Definitions
- Accessibility Policies and Multi-Year Accessibility Plan Revision History
SmartCentres’ Multi-Year Accessibility Plan for 2011-2021 outlines the policies and initiatives that will be implemented to improve opportunities for people with disabilities.
1. STATEMENT OF COMMITMENT
SmartCentres is committed to providing equitable access and high-quality facilities and/or services by meeting the needs of our diverse and valued Associates and customers. To this end, SmartCentres will ensure that it is compliant with the Accessibility for Ontarians with Disabilities Act (AODA), 2005, which aims to remove barriers that impact individuals with a disability. Through compliance, SmartCentres will endeavour to provide all individuals with equal access to our facilities and/or services while allowing individuals with a disability to maintain their independence, dignity, and integration.
2. MULTI-YEAR ACCESSIBILITY PLAN OVERVIEW
SmartCentres has developed a strong foundation of accessibility planning in order to remove barriers and ensure real and effective change for people with disabilities, and is eager to carry this commitment forward with the implementation of our Multi-Year Accessibility Plan.
Our Multi-Year Accessibility Plan provides the opportunity to demonstrate our current achievements and establish an implementation framework and future priority initiatives. Objectives identified within the Plan are both long term and short-term; many are ongoing actions or could require implementation over several years. Regular monitoring is necessary to ensure that initiatives are included in the Plan and that progress is identified. The Multi-Year Accessibility Plan’s progress will be reviewed and reported annually and a comprehensive review will be conducted every five years (2019).
3. ACCESSIBLE EMERGENCY INFORMATION AND WORKPLACE EMERGENCY RESPONSE
SmartCentres is committed to providing our customers and our Associates with publicly available emergency information in accessible formats upon request.
Upon request, Human Resources and Corporate Services will work together with the Associates to develop an individualized emergency response information/plan that will meet their needs in an emergency situation.
| Project Title | Description | Department Responsibility | Start Date | Completion Date |
|---|---|---|---|---|
| Employment Initiatives – Emergency Procedures | Individualized workplace emergency response information will be provided upon request in an accessible format when the need is communicated. The individualized workplace emergency response information will be reviewed when:
| Human Resources, Corporate Services | Dec 2011 | Jan 2012 |
| Employment Initiatives – Emergency Procedures | Create a standard template document to be used to develop individual workplace emergency response plans taking into consideration individual accommodation needs. | Human Resources, Corporate Services | Jan 2014 | May 2014 |
4. TRAINING
SmartCentres will provide training to all Ontario Associates on the Ontario’s accessibility laws and on the Human Rights Code as it relates to persons with disabilities. Training will be tailored to Associate’s responsibilities and duties and it will be provided in a format that best suits the Associate. The training will also be provided to every Ontario Associate who participates in developing SmartCentres’ policies.
SmartCentres will take the following steps to ensure Associates are provided with the training needed to meet Ontario’s accessible laws by January 1, 2015.
| Project Title | Description | Department Responsibility | Start Date | Completion Date |
| Training Initiatives | Develop Accessibility Standards for Customer Service Policy and training in various formats for all Ontario Associates. | Human Resources | Sep 2011 | Training completed for current Associates. |
| Training Initiatives | Continue to conduct, access and review accessible customer service training for all Ontario Associates. | Human Resources | Aug 2011 | Completed research in Sep 2012.Ongoing |
| Training Initiatives | Conduct and review Human Rights Code and the Accessibility for Ontarians with Disabilities Act training for all Ontario Associates.Updated the Quiz in July 2016 | Human Resources | November 2014 | Training completed for current Associates. |
| Training Initiatives | Provide training to all new Ontario Associates within 6 months of hire. | Human Resources | Aug 2011 | Ongoing |
| Training Initiatives | Provide periodic training in connection with changes to this Multi-Year Plan and its related practices and procedures. | Human Resources | May 2014 | Ongoing |
| Training Initiatives | Research and provide training for Ontario’s accessibility laws and Human Rights Code training in multiple formats. | Human Resources | Jan 2014 | Ongoing |
5. KIOSKS
SmartCentres does not currently own or operate any kiosks at this time. However, if this should change, SmartCentres will take every step necessary to ensure that available kiosks meet the requirements as outlined by AODA, 2005.
6. INFORMATION AND COMMUNICATIONS
SmartCentres is committed to meeting the communication needs of persons with disabilities. We will consult with persons with disabilities to determine their information and communication needs and accommodate where possible. SmartCentres will take the following steps to ensure that all publicly available information in Ontario is made accessible upon request by 2016.
| Project Title | Description | Department Responsibility | Start Date | Completion Date |
| Information & Communication Initiatives | AODA statement of commitment sign has been posted at the front reception of SmartCentres’ Home Office.AODA- Customer Service Policy is made available in large font at Reception. | Human Resources | Dec 2012 | Jan 2013 |
| Information & Communication Initiatives | Provide all tenants with a letter advising them of their responsibilities under the AODA- Customer Service Standard.This letter is included in the tenant welcome kit. | OperationsProperty Management | Mar 2012 | Apr 2012and ongoing |
| Information & Communication Initiatives | Continued implementation of a communication campaign to increase awareness of accessibility issues and to inform Associates about issues related to persons with disabilities.Ongoing ideas to be implemented such as intranet information, information in Town Halls. | Human Resources Marketing | June 2012 | Ongoing |
| Information & Communication Initiatives | Provide information and communications in accessible formats and with communication supports to people with disabilities upon request. This will be provided in a timely manner and at a cost that is no more than the regular cost charged to other people. | Human Resources Marketing | Sep 2015 | Ongoing |
7. ACCESSIBLE WEBSITES AND WEB CONTENT
SmartCentres will take the following steps to make our websites and content conform to the Web Content Accessibility Guidelines (WCAG) 2.0 Level AA Standards, by January 1, 2021.
| Project Title | Description | Department Responsibility | Start Date | Completion Date |
| Information & Communication Initiatives | External website to be compliant with WCAG 2.0 Level A Standards. | IT, Marketing, Human Resources | Nov 2013 | Aug 2016Ongoing monitoring |
| Information & Communication Initiatives | Prepare a list of vendors who have the necessary tools to convert our material into accessible formats in a timely manner. | IT, Marketing, Human Resources | Jan 2015To be completed by Jan 2021 | |
| Information & Communication Initiatives | Establish budget to hire outside consultants to assist in meeting the new standard if we are unable to do so internally. | IT, Marketing, Human Resources | Jan 2020To be completed by Jan 2021 | |
| Information & Communication Initiatives | Work closely with internal Information Technology and Marketing teams to ensure full understanding and compliance with WCAG 2.0 Level AA Standards. | IT, Marketing, Human Resources | Jan 2020To be completed by Jan 2021 |
8. FEEDBACK PROCESS
SmartCentres will take the following steps to ensure that our existing feedback process is accessible to persons with disabilities upon request by January 1, 2015.
| Project Title | Description | Department Responsibility | Start Date | Completion Date |
| Feedback Mechanisms | Review & continue use of accessible and alternative feedback methods for general and accessibility related feedback. | Human Resources | Nov 2011 | June 2012and ongoing |
| Feedback Process | Monitor current feedback mechanisms and review opportunities to increase feedback & engagement with persons with disabilities. | Human Resources | Jun 2012 | Ongoing |
| Feedback Process | Continue responding in a timely manner to all accessibility related feedback and/or concerns. | Human Resources | Jun 2012 | Ongoing |
| Feedback Process | Respond to accessibility related feedback and/or concerns in requested format. | Human Resources | Jun 2012 | Ongoing |
9. EMPLOYMENT
SmartCentres is committed to fair and accessible employment practices.
By January 2016, SmartCentres will take the following steps to notify the public and our Associates that we will accommodate people with disabilities during the recruitment and assessment process and when candidates are hired.
| Project Title | Description | Department Responsibility | Start Date | Completion Date |
| Employment Initiatives- | Post accessibility policies on our website addressing our commitment to accommodate people with disabilities. | Human Resources | Jan 2015 | Jan 2014 |
| Employment Initiatives | Review and revise policy and work processes for recruitment, screening & selection process, to provide accommodations. | Human Resources | Jan 2015 | Jan 2016 |
| Employment Initiatives | Include a statement on our job posting that persons with disabilities will be accommodated throughout the recruitment and selection process and for the duration of their employment with SmartCentres. | Human Resources | Jan 2015 | Jan 2016 |
| Employment Initiatives | Successful candidates will be notified of our policies for accommodating employees with disability when the offer of employment is made. | Human Resources | Jan 2016 | Aug 2016 and ongoing |
10. INDIVIDUAL ASSOCIATE ACCOMMODATION PLAN AND RETURN TO WORK POLICY
SmartCentres has established and implemented a Return to Work Policy and Procedure for developing individual accommodation plans for Associates that have been absent due to a disability.
| Project Title | Description | Department Responsibility | Start Date | Completion Date |
| Employment InitiativesDisability Management | Review and revise Return to Work policy and process with related applicable accommodations in place. | Human Resources | Jan 2012 | Oct 2016 |
| Employment InitiativesDisability Management | Develop a standard template for the development of Individual Accommodation Plan and Return to Work Plan. | Human Resources | Jan 2015 | Oct 2016 |
| Employment InitiativesDisability Management | Develop training for HR staff on the changes to the policy and process. | Human Resources | Jan 2012 | Oct 2016 and ongoing |
| Employment InitiativesDisability Management | Communicate Return to Work Policy and procedure to Associates on an as needed basis. | Human Resources | Jun 2014 | Ongoing |
11. PERFORMANCE MANAGEMENT, CAREER DEVELOPMENT AND REDEPLOYMENT
By January 2016, we will take the following steps to ensure the accessibility needs of our Associates with disabilities are taken into account for our performance management, career development and redeployment processes.
| Project Title | Description | Department Responsibility | Start Date | Completion Date |
| Employment InitiativesPerformance Management | Review and revise if necessary performance management (PDR), career development (ICD), & Associate redeployment policies.Added an accommodation statement to the Growth and Development section of the Associate Handbook. | Human Resources, Executive Team | Jan 2015To be completed by Jan 2016 | Oct 2016 |
| Employment InitiativesPerformance Management | Develop target training for HR staff, on the changes to the policies and process. | Human Resources | Jan 2015 | Apr 2016 and ongoing |
| Employment InitiativesPerformance Management | Create an individual accommodation plan in consultation with the Associate with disability. This plan will include consideration for performance management, career development and redeployment processes. | Human Resources | Jan 2015 | Oct 2016 and ongoing |
| Employment InitiativesPerformance Management | Communicate revised policies to all Associates. | Human Resources | Jan 2015To be completed by Dec 2017 |
12. OTHER ACCESSIBILITY BARRIERS
SmartCentres will take the following steps to prevent and remove other accessibility barriers identified.
| Project Title | Description | Department Responsibility | Start Date | Completion Date |
| Other Accessibility Barriers | Continue to remove attitudinal barriers based on continued education & promotion of inclusive work environment. | Human Resources | Sep 2011 | Dec 2012Ongoing |
| Other Accessibility Barriers | Address any instances where a barrier might exist and determine a course of action to remove the barrier in a timely manner. | Human Resources | Sep 2011 | Sep 2012Ongoing |
13. DESIGN OF PUBLIC SPACES
By January 2017, SmartCentres will meet the Accessibility Standards for the Design of Public Spaces when building or making major modifications to public spaces in Ontario. Public spaces include:
- Outdoor public eating areas
- Outdoor play spaces
- Outdoor paths of travel, like sidewalks, ramps, stairs, curb ramps, rest areas and accessible pedestrian signals
- Accessible to off street parking
- Any other space that the SmartCentres deems necessary
SmartCentres will put procedures in place to prevent service disruptions to its accessible parts of its public spaces.
In the event of a service disruption to the accessible parts of public spaces, we will notify the public of the service disruption and alternatives available.
14. FEEDBACK PROCESS AND REQUEST FOR INFORMATION
Any individual who requires additional information regarding SmartCentres’ Accessibility Policies and/or our Multi-Year Accessibility Plan can do so in person, by e-mail, or in writing or by any other means, as required. Accessible formats of our Accessibility Policies and our Multi-Year Accessibility Plan will be made available free upon request. SmartCentres commits to responding to all requests for information in a timely manner.
Please direct any Accessibility related enquiries to:
Fernando C. Vescio, SVP, Human Resources and Corporate Services
700 Applewood Crescent
Vaughan, Ontario, L4K 5X3
Email: fvescio@smartcentres.com
Phone: 905-326-6400 x 7211
Fax: 905-760-6207
15. DEFINITIONS
Associate: employees of SmartCentres
Customer: a member of the public
Disability: defined by the Accessibility for Ontarians with Disabilities Act, 2005, and the Ontario Human Rights Code, refers to the following:
- Any degree of physical disability, infirmity, malformation or disfigurement that is caused by bodily injury, birth defect or illness and, without limiting the generality of the foregoing, includes diabetes mellitus, epilepsy, a brain injury, any degree of paralysis, amputation, lack of physical co-ordination, blindness or visual impediment, deafness or hearing impediment, muteness or speech impediment, or physical reliance on a guide dog or other animal or on a wheelchair or other remedial appliance or device;
- A condition of mental impairment or other remedial appliance or device;
- A learning disability, or dysfunction in one of more of the processes involved in understanding or using symbols or spoken language;
- A mental disorder; or
- an injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997.
16. ACCESSIBILITY POLICIES AND MULTI-YEAR ACCESSIBILITY PLAN REVISION HISTORY
| Revision # | Section | Header | Summary of Changes | Date of Change | Originator | Approved by |
| A | Initial Release | Sep 2014 | Kateryna Jones | Shelley Phillippe | ||
| B | Page 1-14 | Inserted SmartREIT Name, Logo and Contact Number | Jun 2015 | Michelle Verbruggen | Shelley Phillippe | |
| B | Page 5 | Training | Updated Training Initiative Dates | Jun 2015 | Michelle Verbruggen | Shelley Phillippe |
| C | Page 9 | Employment | Updated Dates | Jan 2016 | Michelle Verbruggen | Shelley Phillippe |
| D | Page 5 | Training | Added Human Rights and AODA training initiative | Oct 2016 | Kateryna Jones | Shelley Phillippe |
| D | Page 6 | Information and Communications | Changed completion date to “Ongoing” | Oct 2016 | Kateryna Jones | Shelley Phillippe |
| D | Page 7 | Accessible Websites and Web Content | Updated completion date for our compliance with WCAG 2.0 Level A Standard | Oct 2016 | Kateryna Jones | Shelley Phillippe |
| D | Page 9 | Employment | Updated completion date and removed the word “verbal” from the notification of our accommodation policies for successful candidates description | Oct 2016 | Kateryna Jones | Shelley Phillippe |
| D | Page 10 | Individual Associate Accommodation Plan and Return to Work Policy | Updated completion dates and added a Return to Work Plan to the development of templates description | Oct 2016 | Kateryna Jones | Shelley Phillippe |
| D | Page 11 | Performance Management, Career Development and Redeployment | Updated completion dates and added to the description that an accommodation statement is now included in the Associate Handbook | Oct 2016 | Kateryna Jones | Shelley Phillippe |
| D | Multiple | Changed company name from SmartREIT to SmartCentres | Oct 2017 | Kateryna Jones | Shelley Phillippe |
