Ontario AODA/Accessibility Policy

PURPOSE
This Multi-Year Accessibility Plan (“Accessibility Plan”) outlines the short and long-term strategies of Insight Global (the “Company”) to prevent and remove barriers, improve opportunities for people with disabilities, and otherwise meet the requirements of the Accessibility for Ontarians with Disabilities Act, 2005 (“AODA”). This Accessibility Plan was most recently updated/implemented as of March 2023.

STATEMENT OF COMMITMENT
Our Company is committed to treating all people in a way that allows them to maintain their dignity and independence. Our Company believes in integration and equal opportunity. We are committed to meeting the needs of people with disabilities in a timely manner and will do so by preventing and removing barriers to accessibility and meeting accessibility requirements under the AODA. The Company has appointed an Accessibility Coordinator with the mandate of ensuring compliance with the Company’s obligations under the AODA. However, the Company also relies on all of its consultants, employees, volunteers and partners to assist with maximizing accessibility within the Company by:
• Identifying potential barriers to accessibility and proposing ways to remove them
• Participating in training
• Learning how to interact with persons with disabilities, including those who require the use of a support person or service animal
• Learning how to use existing accessibility devices

COMPLIANCE
By no later than December 31st of each calendar year, the Accessibility Coordinator (including their designates), will review the AODA, Regulations and Accessibility Standards to identify upcoming compliance obligations and establish a schedule for achieving and/or maintaining compliance within any requisite timelines. The Accessibility Coordinator (including their designates), in conjunction with management, human resources, health and safety, compliance, and other business partners, will regularly but no fewer than once per year:
• Review the AODA, regulations and accessibility standards with a view to ensuring ongoing compliance;
• Review existing policies and strategies and evaluate their effectiveness at removing barriers to accessibility, making changes as needed;
• Identify new barriers to accessibility and develop and implement removal strategies;
• Evaluate the physical accessibility to all premises owned or operated by the Company in Ontario in which the Company does business to ensure barrier-free accessibility and prepare and remit to the Company a report detailing potential barriers to accessibility along with recommended strategies for minimizing or eliminating such barriers;
• Evaluate communication methods as well as the manner in which goods and services are provided to the public and other third parties to ensure barrier-free accessibility;
• Ensure all required documents required by the AODA, regulations and standards are posted in appropriate locations and otherwise made available in accessible formats;
• Prepare and file any required accessibility compliance report(s).

SELF-SERVICE KIOSKS
The Company will have regard to the accessibility needs of persons with disabilities if and when designing, procuring or acquiring self-service kiosks.

EMPLOYMENT
The Company is committed to fair and accessible employment practices which are inclusive of persons with disabilities. To this end, the Accessibility Coordinator (including their designates) shall, by no later than December 31, 2023, and no less than once per year thereafter:
• Review the Company’s recruitment, selection, hiring and onboarding processes to ensure compliance with the requirements of the Employment Standards;
• Review the Company’s performance management, career development and advancement, and redeployment practices to ensure that the accessibility needs of employees are appropriate taken into account throughout when the Company is engaged in these processes;
• Review the Company’s processes for preparing and providing individualized workplace emergency response information and documented individual accommodation plans to ensure AODA compliance;
• Consult with management, human resources, and other business partners, as appropriate, to ensure that all employees with disabilities who have requested such support have been provided with accessible formats and communication supports for any information that is needed for the employee to perform their job and that is otherwise generally made available in the workplace; and
• Arrange for and/or provide necessary training on the AODA and the Human Rights Code as it pertains to persons with disabilities, and ensure appropriate records are kept.

TRAINING
In accordance with the AODA, the Company will provide training to consultants, employees, volunteers and other staff on Ontario’s accessibility laws and on the Human Rights Code as it relates to people with disabilities. Training will be provided in a way that best suits the duties of the consultants, employees, volunteers and other staff.

This training will include instruction on the following:
• Purposes and requirements of the AODA, including the Integrated Accessibility Standards Regulation (Regulation 191/11) and all five (5) Accessibility Standards
• Requirements of the Human Rights Code as it pertains to persons with disabilities
• How to interact and communication with persons with various types of disabilities as well as those who use an assistive devices, or require the assistance of a service animal or support person
• How to use equipment or devices available from the Company that may help with the provision of goods or services to a person with a disability
• What to do if a person with a particular type of disabilities is having difficulty accessing our goods or services

The Company will take the following steps to ensure that it has a standardized training program in place to ensure consultants, employees, volunteers and other staff are provided with the training needed to meet Ontario’s accessible laws:
• Develop training materials on the AODA, the Integrated Accessibility Standards and the Human Rights Code;
• Develop a process to maintain records of who has received training and the dates on which accessibility training took place;
• Develop a process whereby new consultants and employees will receive training as soon as practicable at the start of their employment; and
• Provide the established training to all consultants, employees, volunteers and other staff that is appropriate to the duties of each person.

Notwithstanding the timelines set out above, training will take place as soon as practicable for all current affected consultants, employees, volunteers, and other staff of the Company.

WEBSITE / COMMUNICATIONS
By no later than December 31, 2023, the Accessibility Coordinator (including their designates) will consult with its information technology and website support partners to ensure that all websites that are directly control by the organization (directly or through a contractual relationship that allows for modification) and content on those sites posted after January 1, 2012 conform with WCAG 2.0, Level AA, to the extent required by the AODA.

By no later than December 31, 2023, the Accessibility Coordinator (including their designates), will also consult with the Company’s human resources, legal, information technology and website support partners to ensure that:
• Existing feedback processes are accessible to persons with disabilities upon request;
• Any emergency procedures, plans and public safety information prepared by the Company which is made available to the public shall be provided in an accessible format, upon request; and
• All other publicly available information required by the AODA shall also be provided in an accessible format, upon request.

DESIGN OF PUBLIC SPACES
The Company will ensure that all public spaces owned or operated by the Company that are newly constructed or redeveloped comply with the Design of Public Spaces Standards as set out in the Integrated Accessibility Standard, including standards relating to (but not necessarily limited to) the following elements:
• Exterior paths of travel (outdoor sidewalks, walkways, ramps, stairs and curbs)
• Parking (number and type of accessible spaces, aisles and signage)
• Services (service counters, queuing guides and waiting areas)

The Company will also develop procedures for preventative and emergency maintenance of the accessible elements in public spaces, as well as dealing with temporary disruptions when accessible elements in public spaces are not in working order.

In respect of any construction, renovation or redevelopment project entered into on or after January 1, 2013, the project lead or other appropriately responsible party shall certify, using the attached form, that the construction, renovation or redevelopment project has or will be designed and executed in compliance with the accessibility requirements of the AODA, including the Design of Public Spaces Standards. Such certification shall be provided to the Accessibility Coordinator:
• Prior to receiving final approval to commence any construction, renovation or redevelopment project affecting a public space in Ontario;
• Upon completion of any construction, renovation or redevelopment project affecting a public space in Ontario; and/or
• At any other time when requested by the Accessibility Coordinator (including their designate).

AVAILABILITY OF ACCESSIBILITY PLAN
This Accessibility Plan will be included in the Consultant and Internal Employee Handbook and will be provided in an accessible format, upon request. This Accessibility Plan will be reviewed and updated regularly, but no less than once every five (5) years.

FEEDBACK PROCESSES
By December 31, 2023, the Company will review its internal and external feedback processes (if any) to ensure they are accessible to people with disabilities upon request. The Company will also ensure by December 31, 2023 that all publicly available information is made accessible in a timely manner, if requested.

MORE INFORMATION
For more information on this or any other accessibility policy, or to receive a copy of any of the policies or other documents or records required by the AODA, please contact the Company’s Accessibility Coordinator at:

Name / Position: Kristina Padova, HR Business Partner
Address: 100 King Street West, Suite 5210 | Toronto, ON
Email: [email protected]

This Accessibility Policy will be made publicly available. Accessible formats of this document are available for free, upon request.
Approved: May 2023
Next Review: May 2024

PURPOSE
Insight Global is committed to treating all people in a way that allows them to maintain their dignity and independence. Our Company believes in integration and equal opportunity. We are committed to meeting the needs of people with disabilities in a timely manner and will do so by preventing and removing barriers to accessibility and meeting accessibility requirements under the Accessibility for Ontarians with Disabilities Act, 2005 (“AODA”).

The purpose of this policy is to set out how our Company will meet its commitment to ensuring that our recruitment, advancement, performance management and other employment programs, practices and policies are fair and accessible, are inclusive of persons with disabilities, and are provided to all employees and prospective employees in a manner that is free from discrimination.

RECRUITMENT
When recruiting and assessing potential job applicants, including consultants, internal candidates / lateral hires, the Company will take the following steps to notify the public and staff that, when requested, the Company will accommodate people with disabilities both during the recruitment and assessment processes as well as during employment:
• Information will be included in all job postings about the availability of accommodations for applicants with disabilities in the Company’s recruitment process
• Job applicants who are individually selected for an interview and/or testing shall be notified that accommodations for material to be used in the process are available, upon request
• An applicant requesting accommodation will be consulted about how to best provide accommodation in a manner that takes into account the applicant’s disability, and suitable accommodation will be provided
• Successful applicants will be notified about the Company’s policies for accommodating employees with disabilities as part of their offer of employment
• All consultants will be provided with updated information whenever there is a change to existing policies on the provision of job accommodations that take into account consultant needs due to disability

PERFORMANCE MANAGEMENT / CAREER DEVELOPMENT / REDEPLOYMENT
The Company will take into account the accessibility needs of its consultants with known disabilities as well as any documented individual accommodation plans when engaged in the following processes:
• Performance Management – Involves activities related to assessing and improving consultant performance, productivity and effectiveness, with the goal of facilitating consultant success
• Career Development and Advancement – Includes both (1) the provision of additional responsibilities within a consultant’s current position and (2) the movement of a consultant from one job to another in an organization that may be higher in pay, provide greater responsibility and/or be at a higher level in the organization (or any combination); where the addition of such responsibilities or movement is usually based on merit and/or seniority
• Redeployment – Involves the reassignment of consultants to other departments or jobs within the organization as an alternative to layoff, if a particular job or department has been eliminated by the Company

INFORMATION AND COMMUNICATION SUPPORTS
When developing a consultant’s individual accommodation plan, and on an ongoing basis, as appropriate, we will consult with the consultant with disabilities to:
• Identify categories and types of information and communications that are needed in order for the consultant to perform their job, as well as those which are generally available to consultants in the workplace
• Determine the consultant’s information and communication needs
• Determine the process by which information and communications will be made available in accessible formats and with appropriate communication supports
• Include individualized workplace emergency response information, if required
• Identify any other accommodation that is to be provided, and for how long

If it is determined that information or communications are unconvertible, the Company will, in a timely way, provide the consultant requesting the information or communication with an explanation as to why the information or communications are unconvertible as well as a summary of the unconvertible information or communications.

CONTRAVENTIONS
The Accessibility Coordinator, as well as managers and supervisors of the Company, will monitor existing and new practices and procedures to ensure compliance. A failure by any consultant or employee to comply with this Accessible Recruitment and Employment Policy, or any other policy, practice or procedure related to accessibility issues, the removal of barriers, or the Human Rights Code, may result in disciplinary action, up to and including dismissal.

ACCESSIBLE FORMATS
Accessible formats of this Accessible Recruitment and Employment Policy are available for free, upon request.
Approved: May 2023
Next Review: May 2024

SCOPE
This Policy applies to all employees, managers, consultants, contractors, directors, and officers of our Company who deal with our customers in Ontario, including persons who act as our agents (such as contractors and independent consultants), and to all persons who are responsible for developing and updating policies about how we deal with our customers in Ontario.

PURPOSE
It is the objective of the Company to create and maintain a climate of mutual respect in which all persons who access our services, goods and facilities will be able to do so irrespective of any disability they may have. This Policy is created in accordance with the Accessibility for Ontarians with Disabilities Act (the “AODA”) and specifically the Customer Service Standards.

Our business practices and policies will strive to ensure that all of our policies, practices and procedures are consistent with the core principles as outlined in the AODA, which include:

Dignity: Goods and services and access to our facilities are to be provided to all persons with disabilities in a manner that is respectful to the person and all such persons shall be treated as valued customers deserving of service.
Equality of Opportunity: All persons with disabilities are entitled to be given an opportunity to obtain, use and benefit from our goods, services and facilities equal to that of any other of our customers.
Integration: All persons with disabilities are entitled to benefit from our goods, services and facilities in the same place and in the same or similar manner as any other customer. This may require a different format and maintaining a flexible approach wherever possible, taking into account the person’s individual needs. The objective is to attempt inclusiveness and full participation to the extent possible.
Independence: Goods and services and access to our facilities shall be provided in a way that respects the independence of persons with disabilities and means respecting the person’s right to do it themselves and to choose how they wish to receive
services. Any assistance offered must be with the express permission of the person.

DEFINITIONS
The following definitions apply for the purposes of this Policy:
“Assistive Device” refers to any tool, technology or other mechanism that enables a person with a disability to maintain their independence in everyday life by performing tasks and activities such as moving, communicating or lifting.
“Customer” refers to anyone who is in receipt of the goods and services we provide, whether the person is a member of the general public, the end-user of our goods or services, a distributor, or a representative of another organization.
“Disability” means the same under the AODA as it does under the Ontario Human Rights Code:
(a) 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 coordination, 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,
(b) A condition of mental impairment or a developmental disability,
(c) A learning disability, or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language,
(d) A mental disorder, or
(e) An injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997
“Employee” refers all consultants, employees, officers, directors, students, volunteers, or contractors of the Company who deal with any of our customers (or potential customers) in Ontario, whether working on a full-time or part-time basis.

COMMUNICATION AND ASSISTIVE DEVICES
In order to promote understanding of the content and intent of the communication, all communication with people with disabilities will be done in a manner that takes into account the disability. To that end, persons using Assistive Devices will be permitted – where possible and permitted by law – to use those devices while on any part of our premises which are open to the public. It is understood, however, that the use and safety of any personal Assistive Devices is the responsibility of the person with the disability.

Where the use of an Assistive Devices cannot be used because of some barrier, attempts will be made to remove the barrier or the person with the disability will be asked how he or she can be accommodated and / or what alternative methods may be available to assist the person in accessing our goods, services or facilities. Some of the Assistive Devices which are currently available internally which may assist with communication issues include: telephones, email, video conferencing system, pen & paper. Other assistive devices which may assist with removing other barriers to accessibility might include: elevators, ramps, wheelchair accessible washrooms, automatic doors, and low-height counters.

All consultants will be trained on how to communicate with persons with disabilities as well as on how to use each of the above assistive devices, as appropriate for their position.

SERVICE ANIMALS
For the purpose of this policy, an animal is a service animal for a person with a disability if:
(1) It is readily apparent that the animal is used by a person with a disability for reasons relating to his or her disability; or
(2) The person provides a letter from a physician or nurse confirming the need for the animal for reasons relating to a disability.

This includes any animal used by a person with a disability for reasons relating to the disability, such as guide dogs, hearing alert animals (alerts owner to sounds), seizure alert animals (alerts owner to oncoming seizure; steers owner from danger during seizure), and psychiatric service animals (retrieves and prompts owner to take medicine; leads owner out of crowds; retrieves or activates medical alerts).

A person with a disability who is accompanied by a service animal is permitted access to all parts of the Company’s premises that are open to the public, provided that the animal is not otherwise excluded by law. If for some reason the service animal is excluded by law, we will attempt to find an alternate means within a reasonable time frame to provide the person with the disability access.

If it is not readily apparent that the animal is a service animal, the Company reserves the right to ask the person with the disability to provide a letter from an appropriate medical professional confirming that the person requires the animal for reasons relating to his or her disability. However, the decision about whether to request such a letter shall be made by the general manager of each facility. Staff will receive training on how to interact with a person with a disability who is accompanied by a service animal.

SUPPORT PERSONS
For the purposes of this policy, a support person is any person who accompanies a person with a disability in order to assist that person with their disability, such as providing assistance with mobility issues, communication, personal or medical needs, or with accessing goods or services. A person with a disability who is accompanied by a support person will be allowed to have that person accompany him or her on our premises. To preserve confidentiality, consent forms may have to be signed by both the customer as well as the support person which authorizes us to discuss confidential information in the presence of the support person.

Staff will receive training on how to interact with persons with disabilities who are accompanied by a support person, including:
• Communicating directly with the customer, rather than the support person
• Addressing potential issues of confidentiality

NOTICE OF TEMPORARY DISRUPTION
In the event of a planned or unexpected disruption to our services or facilities, such as access to our building, we will notify customers promptly of any such planned or unexpected disruption as follows:
• Where a meeting is scheduled with a customer, the customer shall be notified of the temporary disruption by email in advance of the meeting so that appropriate alternative arrangements can be made
• The information will be posted in a conspicuous place on the website
• A copy of the notice will be posted at the entrance of all affected buildings operated by the Company to which public have access

Where possible, the notice will be posted a minimum of one (1) week in advance of any planned or expected shutdowns.

The posted notice will include information about:
• The date, time and location of the disruption
• The reason for the disruption
• The anticipated length of time, and
• A description of alternative facilities or services available, if any

TRAINING FOR STAFF
Training will be provided to everyone covered by this Policy, and will include ongoing training when changes are made to this Policy or any related change to other policies, practices or procedures. This training will be provided to all new consultants and employees as soon as possible following hiring, but no later than one month post-hiring. Records of this training will be kept on file.

Training will include:
• An overview of the AODA
• The specific requirements of the Customer Service Standard
• A review of this Policy
• How to interact and communicate with people with various disabilities and with those who use assistive devices or require the assistance of a service animal or support person
• How to use the assistive devices we already have
• What to do if a person with a disability is having difficulty accessing our goods, services or facilities

FEEDBACK PROCESS
Customers, other members of the public as well as employees are all invited to provide feedback about the way in which we provide our goods and services to people with disabilities. This may include areas that require changes or improvements.
All feedback can be provided via email or in writing and directed to the Company’s Accessibility Coordinator:
Name / Position: Kristina Padova, HR Business Partner
Address: 100 King Street West, Suite 5210 | Toronto, ON
Email: [email protected]

If a person’s disability prevents them from providing feedback by email or in writing, alternative arrangements will be made which take into account the person’s disability. All feedback relating to accessibility of our services will be directed to the Accessibility Coordinator. We will attempt to respond in the same format as the feedback is received. When complaints or concerns are received, every effort will be made to respond within two (2) weeks of the receipt of the complaint or concern, or earlier where circumstances dictate.

MODIFICATIONS TO THIS OR OTHER POLICIES
All of our policies, practices and procedures will be reviewed on an ongoing basis to ensure compliance with the AODA. Any policy, practice or procedure that does not comply with and promote the dignity and independence of people with disabilities will be modified or removed.

ACCESSIBILITY OF DOCUMENTS
This Policy and all other documents required by the AODA pertaining to our policies, practices and procedures on the provision of services to persons with disabilities can also be obtained by contacting the Accessibility Coordinator using the contact information set out above. Upon request, reasonable attempts will be made to provide these documents to clients with disabilities in a format that takes into account the person’s disability. Notice of availability of these documents will be posted on our website and posted in a conspicuous place at each of the Company’s locations where this Policy applies.

Approved: May 2023
Next review: May 2024