Accessibility Accessibility policy ACL Steel Ltd. is committed to excellence in serving all customers including people with disabilities. Assistive devices We will ensure that our staff are trained and familiar with various assistive devices we have on site or that we provide that may be used by customers with disabilities while accessing our goods or services. Communication We will communicate with people with disabilities in ways that take into account their disability. Service animals We welcome people with disabilities and their service animals. Service animals are allowed on the parts of our premises that are open to the public. Support persons A person with a disability who is accompanied by a support person will be allowed to have that person accompany them on our premises. Notice of temporary disruption In the event of a planned or unexpected disruption to services or facilities for customers with disabilities, ACL Steel Ltd. will notify customers promptly. This clearly posted notice will include information about the reason for the disruption, its anticipated length of time, and a description of alternative facilities or services, if available. The notice will be placed on the front entrance door of ACL Steel Ltd. Training ACL Steel Ltd. will provide training to employees, who deal with the public or other third parties on our behalf. This training will be provided to staff upon hiring. Staff will also be trained when changes are made to your accessible customer service plan. Training will include: An overview of the Accessibility for Ontarians with Disabilities Act, 2005 and the requirements of the customer service standard. ACL Steel Ltd.’s plan related to the customer service standard. How to interact and communicate with people with various types of disabilities. How to interact with people with disabilities who use an assistive device or require the assistance of a service animal or a support person. What to do if a person with a disability is having difficulty in accessing ACL Steel Ltd.’s goods and services. Feedback process: Customers who wish to provide feedback on the way ACL Steel Ltd. provides goods and services to people with disabilities can email firstname.lastname@example.org or speak with the Human Resource Manager. All feedback, including complaints, will be directed to the Human Resource Manager. Customers can expect to hear back in 48 hours. Multi-Year Accessibility Plan: 2020 – 2025 Accessible Customer Service – Training and Policy Status Deadline Responsibility Owner 1. Develop and implement an Accessible Customer Service Policy addressing all requirements under the regulation. Complete Ongoing January 1, 2014 HR Actions:ACL Steel Ltd. has an Accessible Customer Service Policy available on the website and posted on google drive available to all employees. 2. Develop and deliver training to all staff, and individuals completing work on behalf of ACL Steel Ltd. that may assist to the public (or ensure that they have completed similar training). Provide training to all new staff. Complete Ongoing January 1, 2015 HR Actions: Online training as well as a refresher course have been developed and delivered to all current staff using resources primarily from the access forward web portal. All new shop workers are required to complete training within their first 30 days of employment with the company as part of AODA Training. Records of completed training are found in individual employee files and summarized ACL Steel Ltd.’s General Training Matrix. All employees with moderate to high level interaction with customers and outside stakeholders are required to participate in a more in-depth accessible customer service training course. The course uses materials from Access Forward’s Customer Service Module, augmented with an experiential exercise and scenario training applicable specific to ACL Steel Ltd. General Requirements Status Deadline Responsibility Owner 1. Create and make public a statement of commitment. Complete January 1, 2015 Executive Team/ HR Actions:ACL Steel Ltd. has created and made public a statement of commitment. The statement of commitment is located on the company's website and in the reception area of our office. 2. Develop and implement company-specific accessibility policies. Complete Ongoing January 1, 2015 Executive Team/ HR Actions: Review ACL Steel Ltd.' policies and procedures to identify current and future accessibility barriers. Remove identified barriers change deficient policies. Produce an Accommodation Policy for internal use to communicate how ACL Steel Ltd. will meet its requirements under the IASR, and to address employee responsibilities and expectations. Provide Accommodation Policy to all current employees as part of regular toolbox talk meetings, and to all new hires as part of their orientation package and as part of our AODA training program. Alternative formats of the policy will be made available upon request. Multi-Year Accessibility Plan Status Deadline Responsibility Owner 1. Create and make public a multi-year accessibility plan. Complete January 1, 2014 HR All applicable IASR requirements have been reviewed to develop a living Accessibility Plan. The roles of internal stakeholders have been reviewed to determine how each will be affected by requirements. The Accessibility Plan has been created to include training, procedures and policy development to ensure the identification and removal of barriers. The plan has been approved and is available to the public. 2. Provide the plan in accessible formats upon request. Complete January 1, 2014 HR Requests for accessible formats of this document will be directed to the Human Resource Generalist who will work with the individual to determine the most suitable format. 3. Review the plan every five (5) years. Complete Ongoing June 1, 2014 Executive Team/ HR This plan will be amended as required and will be reviewed fully by June 1, 2020 and every five (5) years thereafter. Training Status Deadline Responsibility Owner Train all employees, including contract and unpaid coop students on applicable IASR requirements and the organization's responsibilities under the Human Rights Code (as it pertains to persons with disabilities). Complete Ongoing January 1, 2015 HR Training will be provided by the HR department to all new hires using Access Forwards’ training module downloadable presentations: General Requirements, Accessible Customer Service, and Employment Standard. The information in these slideshows will be combined and augmented with additional Human Rights Code Requirements and applicable scenarios ACL Steel Ltd. Employees are likely to encounter. ACL Steel Ltd. will provide a best practice guide for assisting persons with disabilities which will be available to all employees as it will be in the lunchroom and the location and contents of the guide will be reviewed during our onboarding and refresher AODA training courses. ACL Steel Ltd. will administer an assessment of learning after the training course to ensure understanding and document course completion. Supervisors and Managers will receive additional training on best practices for accommodating and working with persons with disabilities as part of a general Human Rights training course that reviews the duties, purpose, and content of the Ontario Human Rights code. Training materials will be made available via alternative formats upon request. Information and Communication Standard Status Deadline Responsibility Owner 1. Ensure website and web content published after January 1, 2021 conform to the World Wide Web Consortium Web Content Accessibility Guidelines 2.0, level AC. Ongoing January 1, 2021 Executive Team Actions: ACL Steel Ltd.’s public website and its content meet all requirements under the WCAG 2.0 level AA. ACL Steel Ltd.’s IT contractors are aware of WCAG requirements and will ensure all new content and/or any substantial refreshes to the site conform to established guidelines. 2. Be able to receive and respond to feedback from clients, individuals inquiring about ACL Steel Ltd., our employees and members of the public who have a disability upon request. Complete January 1, 2015 Executive Team Actions: A process for receiving and responding to accessible feedback requests has been developed and communicated to all relevant employees. Receiving and responding to feedback will be included in all new hire orientations where the position frequently receives and responds to requests. All other employees will be notified as to the contact person to whom they should direct any accessible feedback requests. Provide and inform stakeholders of available accessible formats and communication supports to individuals with disabilities. Complete January 1, 2016 Executive Team Actions: Develop processes for responding to accessible format requests. Train employees on guidelines/processes and ensure they are aware that requests that cannot be met immediately must be forwarded to the HR Coordinator who will arrange for a suitable and alternative format/communication support. Make public ACL Steel Ltd.s' ability to provide of accessible formats and communication supports by posting a statement on the company website. Where a communication support or accessible format cannot be provided immediately, consult with the client to arrange for a suitable format as soon as possible. Complete January 1, 2016 Executive Team/ HR Employment Standard A. Accessibility Planning Status Deadline Responsibility Owner Create and implement individualized plans to assist employees with disabilities during an emergency. Complete January 1, 2012 HR/ Department Managers Actions: Recognize that disabilities can be invisible or episodic and therefore we should not assume employee needs. Allow employees to identify emergency planning requirements on New Employee Information Form. Include emergency planning information and directions in ACL Steel Ltd.’s Accommodation Policy, provided and communicated to all current employees and provided to all new hires as a part of their orientation package. Obtain consent from employees with individualized plans to disclose emergency response or evacuations plans to the person responsible for assisting the employee in situations where the plan requires the assistance of a colleague. Emergency information available in accessible formats upon request. Review the individualized plan/information: when the employee changes work location, during the periodic review of accommodation plans, upon review of ACL Steel Ltd.’s general emergency response policies. Develop and implement documented individual accommodation plans for employees with disabilities. Complete January 1, 2016 HR/ Department Managers Actions:ACL Steel Ltd. will develop and implement a written process for the development of documented individual accommodation plans for employees with disabilities. As per IASR requirements, the plan will include the following elements: The way an employee requesting accommodation can participate in the development of the individual accommodation plan. The means by which the employee is assessed on an individual basis. The way the employer can request an evaluation by an outside medical or other expert, at the employer’s expense, to assist the employer in determining if accommodation can be provided and, if so, how accommodation can be achieved. The steps taken to protect the privacy of the employee’s personal information. The frequency with which the individual accommodation plan will be reviewed and updated and the way it will be done. If an individual accommodation plan is denied, the reason for the denial will be provided to the employee. The means of providing the individual accommodation plan in a format that considers the employee’s accessibility needs due to disability. Include any information regarding accessible formats and communications supports provided. If required, include individualized workplace emergency response information. B. Recruitment, Assessment and Selection Status Deadline Responsibility Owner ACL Steel Ltd. will notify its employees and the public about the availability of accommodation for applicants with disabilities in its recruitment processes. Complete January 1, 2016 HR Actions:ACL Steel Ltd. will include an accessibility statement on all job postings, so all potential applicants are aware of available supports. During a recruitment process, 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 Complete January 1, 2016 HR Actions: Successful applicants will be informed of the availability of accommodations during the selection/assessment process upon initial contact from the hiring manager or HR Coordinator; Assessment methods used by the company will be reviewed and barriers identified so alternatives can be developed to facilitate accessibility requests. When currently available alternate formats do not satisfy any accommodation request ACL Steel Ltd. will work with the applicant to develop an acceptable alternative. If a selected applicant requests an accommodation, the employer will 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. Complete January 1, 2016 HR Actions: When scheduling interviews, the company will include a statement in all E-mail confirmations informing the applicant that accommodations are available and ask the applicant to inform HR of any necessary accommodations. When making offers of employment, ACL Steel Ltd. will inform successful applicants of its policies for accommodating employees with disabilities. Complete January 1, 2016 HR Actions: ACL Steel Ltd.’s Accommodation Policy will be provided to all new hires as part of their orientation package. This policy describes the process ACL Steel Ltd. will use to support employees with disabilities. The policy outlines how the company will work with the employee to gather relevant information as well as the process to develop, implement and monitor individual accommodation plans. Emergency planning, accessible formats and communication supports will be detailed. Alternative formats of the policy will be made available upon request. C. Supports For Employees Status Deadline Responsibility Owner Work with individual employees to provide suitable accessible formats and communication supports for information that is needed to perform their job and information generally available to employees in the workplace. Complete January 1, 2016 HR Actions: Availability of accessible formats and communication supports have been communicated to all employees through the ACL Steel Ltd.’s Accommodation Policy and periodic AODA review training sessions. New employees are informed of supports available by being provided with the policy within the new hire orientation package. Employees are invited to request accessible formats and communication supports regularly by training employees and supervisors during the training process and while on the job. Information that is generally available in the workplace will be provided in a variety of formats upon request including hardcopy or electronically. Prior to providing the information needed to perform one's job or information generally available in the workplace, employees requiring accessible formats or communication supports will be requested to notify the HR department so that alternate arrangements may be made. When a request is received the employee, HR and any other facilitating parties will work together to determine and provide the appropriate accessible formats or communication supports with the obtained consent of the employee. Employees will be informed of any changes to ACL Steel Ltd.’s Accommodation policy upon effective date. Augment organization's current performance management and career development processes to address accessibility needs of employees to reduce barriers and ensure processes are inclusive. Complete Ongoing January 1, 2016 HR Actions:Review current performance management and career development processes to identify barriers. Develop processes to ensure that applicable processes are accessible. ACL Steel Ltd.’s Accommodation Policy will outline the means of accessible performance management to ensure consistent and clear application and communication to employees. Recognize the accessibility needs and accommodation plans of employees who are reassigned to an alternate department or position with the company as an alternative to a layoff. Complete January 1, 2016 HR Actions: When an employee changes department or position HR will integrate the accessibility needs and accommodation plans of that employee. Confidentiality will be prioritized when determining who is to be involved with and informed of any accessibility plans and/ or accommodation requirements. D. Return to Work and Related Accommodations Status Deadline Responsibility Owner Put in place a process for return to work for employees who have been off work because of disability including accommodation planning, tracking and structured communication. Complete January 1, 2016 HR Actions:Create accommodation and return to work forms meet all IASR requirements. Consistent use of these forms will ensure that all accommodation and RTW plans are documented and stored. Employees will be provided with a return-to-work package including the RTW and Accommodation form and policy/ process documents at the onset of absence from work.