“Where Extraordinary People achieve Exceptional Results” ACCESSIBILITY POLICIES AND MULTI-YEAR ACCESSIBILITY PLAN 2011-2021


Accessibility Policies and Multi-Year Accessibility Plan

  1. Statement of Commitment 
  2. Multi-Year Accessibility Plan Overview 
  3. Accessible Emergency Information and Workplace Emergency Response 
  4. Training 
  5. Kiosks 
  6. Information and Communications 
  7. Accessible Websites and Web Content 
  8. Feedback Process 
  9. Employment 
  10. Individual Associate Accommodation Plan and Return to Work Policy 
  11. Performance Management, Career Development and Redeployment 
  12. Other Accessibility Barriers 
  13. Design of Public Spaces 
  14. Feedback Process and Request for Information 
  15. Definitions 
  16. 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.


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.


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).


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 TitleDescriptionDepartment ResponsibilityStart DateCompletion 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:

  •  the Associate moves to a different location within the Company;
  • the Associate’s overall accommodation needs or plans are reviewed;
  • SmartCentres reviews general emergency response policies.
Human Resources, Corporate ServicesDec 2011Jan 2012
Employment Initiatives – Emergency ProceduresCreate a standard template document to be used to develop individual workplace emergency response plans taking into consideration individual accommodation needs.Human Resources, Corporate ServicesJan 2014May 2014



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 TitleDescriptionDepartment ResponsibilityStart DateCompletion Date
Training InitiativesDevelop Accessibility Standards for Customer Service Policy and training in various formats for all Ontario Associates.Human ResourcesSep 2011Training completed for current Associates.
Training InitiativesContinue to conduct, access and review accessible customer service training for all Ontario Associates.Human ResourcesAug 2011Completed research in Sep 2012.Ongoing
Training InitiativesConduct and review Human Rights Code and the Accessibility for Ontarians with Disabilities Act training for all Ontario Associates.Updated the Quiz in July 2016Human ResourcesNovember 2014Training completed for current Associates.
Training InitiativesProvide training to all new Ontario Associates within 6 months of hire.Human ResourcesAug 2011Ongoing
Training InitiativesProvide periodic training in connection with changes to this Multi-Year Plan and its related practices and procedures.Human ResourcesMay 2014Ongoing
Training InitiativesResearch and provide training for Ontario’s accessibility laws and Human Rights Code training in multiple formats.Human ResourcesJan 2014Ongoing



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.



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 TitleDescriptionDepartment ResponsibilityStart DateCompletion Date
Information & Communication InitiativesAODA 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 ResourcesDec 2012Jan 2013
Information & Communication InitiativesProvide 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 ManagementMar 2012Apr 2012and ongoing
Information & Communication InitiativesContinued 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 MarketingJune 2012Ongoing
Information & Communication InitiativesProvide 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 MarketingSep 2015Ongoing



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 TitleDescriptionDepartment ResponsibilityStart DateCompletion Date
Information & Communication InitiativesExternal website to be compliant with WCAG 2.0 Level A Standards.IT, Marketing, Human ResourcesNov 2013Aug 2016Ongoing monitoring
Information & Communication InitiativesPrepare a list of vendors who have the necessary tools to convert our material into accessible formats in a timely manner.IT, Marketing, Human ResourcesJan 2015To be completed by Jan 2021 
Information & Communication InitiativesEstablish budget to hire outside consultants to assist in meeting the new standard if we are unable to do so internally.IT, Marketing, Human ResourcesJan 2020To be completed by Jan 2021 
Information & Communication InitiativesWork closely with internal Information Technology and Marketing teams to ensure full understanding and compliance with WCAG 2.0 Level AA Standards.IT, Marketing, Human ResourcesJan 2020To be completed by Jan 2021 



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 TitleDescriptionDepartment ResponsibilityStart DateCompletion Date
Feedback MechanismsReview & continue use of accessible and alternative feedback methods for general and accessibility related feedback.Human ResourcesNov 2011June 2012and ongoing
Feedback ProcessMonitor current feedback mechanisms and review opportunities to increase feedback & engagement with persons with disabilities.Human ResourcesJun 2012Ongoing
Feedback ProcessContinue responding in a timely manner to all accessibility related feedback and/or concerns.Human ResourcesJun 2012Ongoing
Feedback ProcessRespond to accessibility related feedback and/or concerns in requested format.Human ResourcesJun 2012Ongoing



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 TitleDescriptionDepartment ResponsibilityStart DateCompletion Date
Employment Initiatives-Post accessibility policies on our website addressing our commitment to accommodate people with disabilities.Human ResourcesJan 2015Jan 2014
Employment InitiativesReview and revise policy and work processes for recruitment, screening & selection process, to provide accommodations.Human ResourcesJan 2015Jan 2016
Employment InitiativesInclude 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 ResourcesJan 2015Jan 2016
Employment InitiativesSuccessful candidates will be notified of our policies for accommodating employees with disability when the offer of employment is made.Human ResourcesJan 2016Aug 2016 and ongoing



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 TitleDescriptionDepartment ResponsibilityStart DateCompletion Date
Employment InitiativesDisability ManagementReview and revise Return to Work policy and process with related applicable accommodations in place.Human ResourcesJan 2012Oct 2016
Employment InitiativesDisability ManagementDevelop a standard template for the development of Individual Accommodation Plan and Return to Work Plan.Human ResourcesJan 2015Oct 2016
Employment InitiativesDisability ManagementDevelop training for HR staff on the changes to the policy and process.Human ResourcesJan 2012Oct 2016 and ongoing
Employment InitiativesDisability ManagementCommunicate Return to Work Policy and procedure to Associates on an as needed basis.Human ResourcesJun 2014Ongoing



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 TitleDescriptionDepartment ResponsibilityStart DateCompletion Date
Employment InitiativesPerformance ManagementReview 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 TeamJan 2015To be completed by Jan 2016Oct 2016
Employment InitiativesPerformance ManagementDevelop target training for HR staff, on the changes to the policies and process.Human ResourcesJan 2015Apr 2016 and ongoing
Employment InitiativesPerformance ManagementCreate 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 ResourcesJan 2015Oct 2016 and ongoing
Employment InitiativesPerformance ManagementCommunicate revised policies to all Associates.Human ResourcesJan 2015To be completed by Dec 2017 



SmartCentres will take the following steps to prevent and remove other accessibility barriers identified.

Project TitleDescriptionDepartment ResponsibilityStart DateCompletion Date
Other Accessibility BarriersContinue to remove attitudinal barriers based on continued education & promotion of inclusive work environment.Human ResourcesSep 2011Dec 2012Ongoing
Other Accessibility BarriersAddress any instances where a barrier might exist and determine a course of action to remove the barrier in a timely manner.Human ResourcesSep 2011Sep 2012Ongoing



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.



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:  [email protected]
Phone:  905-326-6400 x 7211
Fax:  905-760-6207



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.



Revision #SectionHeaderSummary of ChangesDate of ChangeOriginatorApproved by
A  Initial ReleaseSep 2014Kateryna JonesShelley Phillippe
BPage 1-14 Inserted SmartREIT Name, Logo and Contact NumberJun 2015Michelle VerbruggenShelley Phillippe
BPage 5TrainingUpdated Training Initiative DatesJun 2015Michelle VerbruggenShelley Phillippe
CPage 9EmploymentUpdated DatesJan 2016Michelle VerbruggenShelley Phillippe
DPage 5TrainingAdded Human Rights and AODA training initiativeOct 2016Kateryna JonesShelley Phillippe
DPage 6Information and CommunicationsChanged completion date to “Ongoing”Oct 2016Kateryna JonesShelley Phillippe
DPage 7Accessible Websites and Web ContentUpdated completion date for our compliance with WCAG 2.0 Level A StandardOct 2016Kateryna JonesShelley Phillippe
DPage 9EmploymentUpdated completion date and removed the word “verbal” from the notification of our accommodation policies for successful candidates descriptionOct 2016Kateryna JonesShelley Phillippe
DPage 10Individual Associate Accommodation Plan and Return to Work PolicyUpdated completion dates and added a Return to Work Plan to the development of templates descriptionOct 2016Kateryna JonesShelley Phillippe
DPage 11Performance Management, Career Development and RedeploymentUpdated completion dates and added to the description that an accommodation statement is now included in the Associate HandbookOct 2016Kateryna JonesShelley Phillippe
DMultiple Changed company name from SmartREIT to SmartCentresOct 2017Kateryna JonesShelley Phillippe

Rafaël Rozendaal

New York-based and Dutch-Brazillian by heritage, Rafael is a visual artist who uses the internet as his canvas. He also creates installations, tapestries, lenticulars, books, and lectures. Rafaël’s work has been exhibited across the globe in Times Square, Whiteney Museum, Cassa Franca, Seoul Art Square, and the Stedelijk Museum. Most recently Rafaël sold his digital piece ‘Deep Blue’ on the emerging, high-value NFT market.


Silence is a digital artwork consisting of 3 ambient moving images. The works are almost abstract, but a suggestion of space and movement hints at experiences of landscapes and travel. With minimal elements of colour and rhythm, a maximal experience is created of immersion and contemplation.

PXL Gallery

Rob King

A GTA local, that wanted to grow up to become a scientist, artist, inventor or time traveller. Rob King had the rare fortune of being able to blend his diverse childhood ambitions into a career as a creative technologist; creating work that blends cutting edge technology, data-visualization, real-world phenomena and emergent behaviors. Beyond his artistic practice, Rob is the founder of XZZ Creative Technologies. In this capacity, he has worked along-side artists and brands to create unique, compelling interactive artworks, installations and experiences using technology.

Jim Campbell

San Francisco based artist known for his contemporary, low resolution LED lightworks, Jim Campbell was engaged to consult in with the design and development of PXL Gallery and will be a featured artist for the installation. Throughout the design process, Campbell, alongside the SmartCentres and Diamond Schmitt teams, thoroughly investigated technology and did substantial testing, that will serve as the infrastructure for the display for all artworks commissioned for the PXL Gallery. Holding nearly twenty patents in the field of video image processing, Campbell’s work has also been exhibited internationally in various renowned contemporary art institutions.

Ben Johnston

Known for his custom typography, Ben Johnston is a multi-disciplinary artist and designer using murals, advertising and public art, and consistently pushing the envelope in his field. Receiving numerous awards from the Type Directors Club, Ben was selected as one of the 2019 TDC Ascenders. Raised in Cape Town, South Africa, and currently Toronto-based, he creates large-scale murals for corporate clients and NGOs in city centres globally including San Francisco, Serbia, Hawaii and India. Whether executing a mural in a remote part of India or an animated artwork for an NFT auction, he aims to find a unique approach, drawing on inspirations from his travels.

Follow Ben on Instagram @ben_johnston.

Better Together

The mural refers to the certainty that by uniting as social creatures, we can always achieve more. “I’m trying to invoke to both the citizens of the city of Vaughan and the entire GTA is that now more than ever, we need to band together and create lasting memories, as our voyage on earth is limited by time and space.



Toronto-based multidisciplinary artist Jerry Rugg – aka birdO- is primarily known for his large-scale mural work on walls and buildings globally. Jerry’s long passion for the arts, storied experience working in film, and skills acquired as an award-winning graphic designer, have all contributed to his approach, which focuses on an acute awareness of the surface and studious preparation with regard to local culture and surroundings.

Follow birdO on Instagram @jerryrugg.

Birds of Feather

Created for those whose eye is drawn to the surreal. As the site becomes an official destination in Ontario, the mural is a tip of the cap to the people in our communities who are curious and eccentric art lovers, who seek out unique places to gather and share memories. The Kingfisher birds are a subtle homage to those of us with a bright feather that tends to flock together!

Ricardo Cavolo

Based out of sunny Madrid, Ricardo Cavolo’s eclectic international style is based on relationships with comic, cartoon, outsider art and tribal arts. Cavolo’s art is all about stories, characters, and their experiences across time. Utilizing art as a complex narrative, Cavolo often focuses on portraiture. These depictions propel protagonists to champion their unique tales. Referencing religious and historical fiction illustrations, his use of symbolism connected to a modern and playful audience. Cavolo’s portfolio features public murals and art exhibitions across the globe from Paris to Moscow and Mexico City to Hong Kong. Notably, Cavolo’s body of work includes illustrations, publications, fashion collaborations and a wide variety of commissioned works.

Follow Ricardo on Instagram @ricardocavolo


“I always like to give a deep message with my art, usually something positive and optimistic. Especially during these times, I think we need to create a sort of the net between all of us giving us light and good vibes to get out from this dark moment. We need to bring our inner suns and share that light with the rest of the world.”


Jeremy Shantz

Born in British Columbia, Canadian artist, Jeremy Shantz, studied classical painting, sculpture, film and creative electronics. Graduating with honors from UBC-Okanagan, Jeremy now lives and works in Montreal, as well as exhibiting internationally. With a diverse practice of painting on canvas, drawing, sculpture, mural, photography, graphics and video, his art can be described as an exploration infused with West Coast culture, mixing pop and surrealist references with themes of fluidity, the unknown, melange potential and materialistic illusions.

Follow Jeremy on Instagram @jshantzart

An exploration of our timespace. A reverberation of our endless transformation.

Depicting a figurative character separated into multiple pieces and elements, detached and floating in space. This imagery represents the many facets that must come together to create a singular item that is diverse and strong conceptually and esthetically. This piece represents our creative communities, the many unique ideas, perspectives, and skills that are necessary for us to grow together, become stronger, and create more impactful public works of art. The process to complete the smart centre mural is the perfect example of this as I had the pleasure of designing something that my peers created on my behalf, the results of this collaborative effort realized something completely unique that I could never have accomplished alone.