Last Reviewed: May 14, 2026
Barton Malow Canada Ltd. is committed to ensuring equal access and participation for people with disabilities. This page provides our Statement of Commitment, our Accessibility Policy under the Accessibility for Ontarians with Disabilities Act (AODA), and our Multi-Year Accessibility Plan for 2026–2030. If you would like any of this information in an accessible format, or if you have feedback on accessibility at Barton Malow Canada, please use the contact details below.
Jump To:
Statement of Commitment
Barton Malow Canada Ltd. (BMCL) is committed to treating all people in a way that allows them to maintain their dignity and independence. BMCL believes in integration and equal opportunity and is committed to meeting the accessibility needs of persons with disabilities in a timely manner.
BMCL is committed to identifying, preventing and removing barriers to accessibility and to meeting its obligations under the Accessibility for Ontarians with Disabilities Act, 2005 (AODA) and Ontario Regulation 191/11 (Integrated Accessibility Standards Regulation) (IASR), as amended, as well as the accessibility requirements under the Ontario Human Rights Code.
Request an Accessible Format or Provide Feedback
Requests for accessible formats, communication supports, or accessibility feedback may be directed to:
- Email: HRCanada@bartonmalow.com
- Phone: 519-740-1090
- Mail: Barton Malow Canada Ltd.
560 Sheldon Drive
Cambridge, ON N1T 0A4
Barton Malow Canada will respond to requests in a timely manner and in accordance with applicable accessibility requirements.
Accessibility Policy (AODA)
Reviewed: April 2026
Purpose
Barton Malow Canada Ltd. (BMCL) is committed to ensuring equal access and participation for people with disabilities.
We are committed to treating people with disabilities in a way that allows them to maintain their dignity and independence. We believe in integration and we are committed to meeting the needs of people with disabilities in a timely manner. We will do so by removing and preventing barriers to accessibility and meeting our accessibility requirements under the Accessibility for Ontarians with Disabilities Act and Ontario’s accessibility laws.
BMCL is also committed to meeting its current and ongoing obligations under the Ontario Human Rights Code respecting non-discrimination and BMCL understands that obligations under the Accessibility for Ontarians with Disabilities Act, 2005 (AODA) and its accessibility standards do not substitute or limit its obligations under the Ontario Human Rights Code or obligations to people with disabilities under any other law.
BMCL is also committed to excellence in serving and providing goods, services or facilities to all customers including people with disabilities.
This policy ensures Barton Malow Canada provides services and employment practices that follow the principles of dignity, independence, integration, and equal opportunity.
Definitions
Accessible format: Includes large print, recorded audio and electronic formats, braille, and other formats usable by persons with disabilities.
Communication support: Includes captioning, alternative and augmentative communication supports, plain language, sign language, and other supports that facilitate effective communication.
Information: Includes data, facts, and knowledge that exists in any format, including text, audio, digital, or images, and conveys meaning.
Career development and advancement: Additional responsibilities within a BMCL team member’s current position and the movement of a BMCL team member from one job to another in an organization or any combination of them. Both additional responsibilities and BMCL team member movement are usually based on merit, seniority, or a combination of both.
Performance management: Activities related to assessing and improving BMCL team member performance, productivity, and effectiveness with the goal of facilitating BMCL team member success.
Redeployment: The reassignment of BMCL team members to other departments or jobs within the organization as an alternative to layoff, when a particular job or department has been eliminated by the organization.
Support person: In relation to a person with a disability, another person who accompanies a person with a disability in order to help with communication, mobility, personal care, or medical needs, or with access to goods, services, or facilities.
1. AODA — General Requirement Commitment
Establishment of Accessibility Policies and Plans
Barton Malow Canada will develop, implement, and maintain policies as outlined herein governing how it will achieve accessibility through these requirements.
BMCL is committed to meeting the accessibility needs of persons with disabilities in a timely manner. This is reflected in policies which upon request will be made publicly available in an accessible format.
BMCL shall establish, implement, maintain and document a multi-year accessibility plan that outlines BMCL’s strategy to prevent and remove barriers and to meet its requirements under the Accessibility for Ontarians with Disabilities Act, 2005 and Ontario Regulation 191/11 (Integrated Accessibility Standards Regulation), as amended. BMCL shall post the multi-year accessibility plan on its website and shall provide the plan in an accessible format upon request. BMCL shall review and update the multi-year accessibility plan at least once every five (5) years.
Training Requirements
Barton Malow Canada will provide training for its employees and volunteers regarding the IASR and the Ontario Human Rights Code as they pertain to individuals with disabilities. Training will also be provided to individuals who are responsible for developing the companies’ policies, and all other persons who provide goods, services, or facilities on behalf of the BMCL.
Training will be provided as soon as is reasonably practicable. Training will be provided regularly to new BMCL employees and as changes to the companies’ accessibility policies occur.
Barton Malow Canada will maintain records on the training provided, when it was provided, and the number of BMCL employees who were trained.
2. AODA — Employment Standards Policy
Barton Malow Canada (BMCL) is dedicated to providing accessible services and work environment for all employees, prospective employees, and clients and customers. This policy outlines BMCL’s compliance with Parts I and III of the Integrated Accessibility Standards Regulation (IASR) set forth under the Accessibility for Ontarians with Disabilities Act, 2005 (AODA).
Recruitment, Assessment and Selection
Barton Malow Canada will notify employees and the public about the availability of accommodation for job applicants who have disabilities. Applicants will be informed that these accommodations are available, upon request, for the interview process and for other candidate selection methods. Where an accommodation is requested, BMCL will consult with the applicant and provide or arrange for suitable accommodations in a manner that takes into account the applicant’s accessibility needs due to disability.
Successful applicants will be made aware of BMCL’s policies and supports for accommodating people with disabilities.
Accessible Formats and Communication Supports for BMCL Employees
Barton Malow Canada will ensure that employees are aware of policies for employees with disabilities and any changes to these policies as they occur. BMCL will provide the information required to new employees as soon as practicable after they begin their employment.
If an employee with a disability requests it, BMCL will provide or arrange for the provision of accessible formats and communication supports for the following:
- Information needed in order to perform their job; and
- Information that is generally available to all BMCL employees in the workplace.
BMCL will consult with employees making the request to determine the best way to provide the accessible format or communication support.
Workplace Emergency Response Information
Where required, Barton Malow Canada will create individualized workplace emergency response plans for employees with disabilities. This information will be created in consultation with the employee and take into account the unique challenges created by the individual’s disability and the physical nature of the workplace.
This information will be reviewed when:
- The employee moves to a different physical location in the organization;
- The employee’s overall accommodation needs, or plans are reviewed; or
- BMCL reviews general emergency response policies.
Documented Individual Accommodation Plans
Barton Malow Canada will develop and have in place written processes for documenting individual accommodation plans for employees with disabilities. The development process for these plans will include:
- The ways in which the employee can participate in the development of the plan;
- The means by which the employee is assessed individually;
- The ways that an employer can request an evaluation by an outside medical expert, or other experts (at BMCL’s expense) to determine whether accommodation can be achieved, or how it can be achieved;
- The ways that BMCL can request the participation of a representative from the workplace for the creation of the accommodation plan;
- The steps taken to protect the privacy of the employee’s personal information;
- The frequency with which the individual accommodation plan should be reviewed or updated and how it should be done;
- The way in which the reasons for the denial of an individual accommodation plan will be provided to the employee; and
- The means of providing the accommodation plan in an accessible format, based on the employee’s accessibility needs.
The individual accommodation should also include information regarding accessible formats, communication supports (upon request), individualized workplace emergency response information, and any other accommodation provided.
Return to Work
Barton Malow Canada will develop and implement return-to-work processes for employees who are absent from work due to a disability and require disability-related accommodations in order to return to work.
This process will outline the steps BMCL will take to enable a smooth return to work for the employee. All steps and individual accommodation plans will be documented and created in consultation with the employee.
Performance Management and Career Changes
Barton Malow Canada will consider the accessibility needs, including documented individual accommodation plans, of employees with disabilities during the performance management process. These will also be considered in the event of redeployment, or when offering career development or advancement opportunities.
Review
This policy will be reviewed regularly to ensure that it reflects current practices of Barton Malow Canada as well as legislative requirements.
3. AODA — Customer Service Standards Policy
All goods and services provided by Barton Malow Canada will follow the principles of dignity, independence, integration, and equal opportunity.
This policy meets the requirements of the customer service standards included in the Integrated Accessibility Standards Regulation under the Accessibility for Ontarians with Disabilities Act, 2005. It applies to the provision of goods and services to the public or other third parties, not to the goods themselves.
Definitions
Assistive deviceA technical aid, communication device, or other instrument that is used to maintain or improve the functional abilities of people with disabilities. Personal assistive devices are typically devices that clients or customers bring with them, such as a wheelchair, walker, or a personal oxygen tank, and that might assist in hearing, seeing, communicating, moving, breathing, or reading.DisabilityAs defined by the Accessibility for Ontarians with Disabilities Act, 2005, and the Ontario Human Rights Code, refers to:
- Any degree of physical disability, inability, 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 a developmental disability;
- A learning disability, or dysfunction in one or 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.
Guide dogA highly trained working dog that has been trained at one of the facilities listed in Ontario Regulation 58 under the Blind Persons’ Rights Act, to provide mobility, safety, and increased independence for people who are blind.Service animalA service animal for a person with a disability if:
- The animal can be readily identified as one that is being used by the person for reasons relating to the person’s disability, as a result of visual indicators such as the vest or harness worn by the animal; or
- The person provides documentation from an employee of one of the following regulated health professional colleges confirming that the person requires the animal for reasons relating to the disability:
- College of Audiologists and Speech-Language Pathologists of Ontario;
- College of Chiropractors of Ontario;
- College of Nurses of Ontario;
- College of Occupational Therapists of Ontario;
- College of Optometrists of Ontario;
- College of Physicians and Surgeons of Ontario;
- College of Physiotherapists of Ontario;
- College of Psychologists of Ontario; or
- College of Registered Psychotherapists and Registered Mental Health Therapists of Ontario.
Support personIn relation to a person with a disability, another person who accompanies them in order to help with communication, mobility, personal care, medical needs, or access to goods and services.
Guidelines
The Provision of Goods and Services to Persons with Disabilities
Barton Malow Canada will make every reasonable effort to ensure that its policies, practices, and procedures are consistent with the principles of dignity, independence, integration, and equal opportunity by:
- Ensuring that all clients and customers receive the same value and quality;
- Allowing clients and customers with disabilities to do things in their own ways, at their own pace when accessing goods and services, as long as this does not present a health and safety risk;
- Using alternative methods when possible to ensure that clients and customers with disabilities have access to the same services, in the same place and in a similar manner;
- Taking into account individual accommodation needs when providing goods and services; and
- Communicating in a manner that takes into account the client’s disability.
The Use of Assistive Devices
Customer’s Own Assistive Devices. Persons with disabilities may use their own assistive devices as required when accessing goods or services provided by BMCL.
In cases where the assistive device presents a health and safety concern or where accessibility might be an issue, other reasonable measures will be used to ensure the access of goods and services, up to the point of undue hardship.
For example, open flames and oxygen tanks cannot be near one another. Therefore, the accommodation of a customer with an oxygen tank might involve ensuring the customer is in a location that would be considered safe for both the client and business.
Guide Dogs and Service Animals
A customer with a disability who is accompanied by a guide dog or service animal will be allowed access to premises that are open to the public unless otherwise excluded by law. “No pet” policies do not apply to guide dogs or service animals.
Employees may respectfully ask if an animal is a service animal but will not ask the nature of the person’s disability or purpose of the animal.
Applicable Laws. Dog Owners’ Liability Act, 2005: If there is a conflict between a provision of this legislation or of a regulation under this or any other act relating to banned breeds (such as pit bulls) and a provision of a by-law passed by a municipality relating to these breeds, the provision that is more restrictive in relation to controls or bans on these breeds prevails. Employees will respectfully explain that the service animal must be removed from the public area due to a municipal by-law and make alternate arrangements or provide the service outside the public area.
Recognizing a Guide Dog or Service Animal. If it is not readily apparent that the animal is being used by the customer for reasons relating to their disability, Barton Malow Canada may request verification from the customer.
Care and Control of the Animal. The customer who is accompanied by a guide dog or service animal is responsible for maintaining care and control of the animal at all times.
Allergies and Other Health and Safety Concerns. If a health and safety concern presents itself, for example, in the form of a severe allergy to the animal, Barton Malow Canada will make all reasonable efforts to meet the needs of all individuals. Pursuant to BMCL’s obligations under the Human Rights Code and the Occupational Health and Safety Act, each customer’s accommodation needs will be considered on a case-by-case basis, up to the point of undue hardship.
Due diligence needs to be paid to address health and safety requirements. For example, if a person’s health and safety could be seriously affected by the presence of a service animal on the premises, management must fully analyze all options for safely accommodating the service animal. Options could include creating distance between the two individuals to eliminate in-person contact, changing the time the two individuals receive service, or using air purifiers and other measures that could allow the person to use their service animal on the premises.
In exceptional circumstances where a service animal becomes out of control, causing a clear disruption or a threat to the health and safety of others, and the animal’s behaviour is not corrected by the owner, a person with a disability can be asked to remove their service animal from the premises.
As a courtesy, particularly if the person and service animal have been in attendance on the premises for a long time, staff may ask whether the animal requires water, may designate an area in which the service animal can relieve itself, or ask whether the staff can be of assistance pertaining to the service animal.
The Use of Support Persons
If a customer with a disability is accompanied by a support person, Barton Malow Canada will ensure that both persons may enter the premises together and that the customer is not prevented from having access to the support person.
There may be times where seating and availability prevent the customer and support person from sitting beside each other. In these situations, BMCL will make every reasonable attempt to resolve the issue.
In situations where confidential information might be discussed, consent will be obtained from the customer before any potentially confidential information is mentioned.
Notice of Disruptions in Service
Service disruptions may occur for reasons that may or may not be within the control or knowledge of Barton Malow Canada. In the event of any temporary disruptions to facilities or services that customers with disabilities rely on to access or use goods or services, reasonable efforts will be made to provide advance notice. In some circumstances, such as in the situation of unplanned temporary disruptions, advance notice may not be possible. If a notification needs to be posted, the following information will be included unless it is not readily available or known:
- Services that are disrupted or unavailable;
- Reason for the disruption;
- Anticipated duration; and
- A description of alternative services or options.
Notification Options. When disruptions occur, Barton Malow Canada will provide notice by:
- Posting notices in conspicuous places, including at the point of disruption, at the main entrance, and the nearest accessible entrance to the service disruption, or on the BMCL website;
- Contacting customers with appointments;
- Verbally notifying customers when they make an appointment; or
- By any other method that may be reasonable under the circumstances.
Customer Feedback
Barton Malow Canada shall provide customers with the opportunity to provide feedback on the service provided to clients with disabilities. Information about the feedback process will be readily available to all customers and notice of the process will be made available at reception.
Feedback forms, along with alternate methods of providing feedback verbally (in person or by telephone) or written (handwritten, delivered, website, or e-mail), will be available upon request.
Submitting Feedback. Customers can submit feedback in the following ways:
- Feedback at our head office or various sites.
- By telephone at 519-740-1090 or by fax at 519-740-8776.
- In writing to “Human Resources” at 560 Sheldon Drive, Cambridge, Ontario N1R 0A4.
- By email to HRCanada@bartonmalow.com.
Customers who wish to provide feedback onsite or verbally can do so by asking to speak with the Human Resources Manager.
Customers who provide formal feedback will receive acknowledgement of their feedback, along with any resulting actions based on concerns or complaints that were submitted.
Training
Training will be provided to:
- Every BMCL employee of or a volunteer with Barton Malow Canada;
- Every person who participates in developing the policies of Barton Malow Canada; and
- Every other person who provides services on behalf of Barton Malow Canada.
Training Provisions. Regardless of the format, training will cover the following:
- A review of the purpose of the Accessibility for Ontarians with Disabilities Act, 2005;
- A review of the requirements of the clients service standards;
- Instructions on how to interact and communicate with people with various types of disabilities;
- Instructions on how to interact with people with disabilities who:
- Use assistive devices;
- Require the assistance of a guide dog or other service animal; or
- Require the use of a support person (including the handling of admission fees);
- Instructions on how to use equipment or devices that are available at our premises or that we provide that may help people with disabilities;
- Instructions on what to do if a person with a disability is having difficulty accessing our services; and
- Policies, procedures, and practices of BMCL pertaining to providing accessible clients service to clients with disabilities.
Training Schedule. Barton Malow Canada will provide training as soon as practicable. Training will be provided to new BMCL employees, volunteers, agents, and contractors. Revised training will be provided in the event of changes to legislation, procedures, policies, or practices.
Record of Training. Barton Malow Canada will keep a record of training that includes the dates training was provided and the number of BMCL employees who attended the training.
Notice of Availability and Format of Documents to Customers
Barton Malow Canada shall notify customers that the documents related to the client’s service standards are available upon request and in a format that takes into account the client’s disability. Notification will be given by posting the information in a conspicuous place owned and operated by Barton Malow Canada, the website of Barton Malow Canada, and any other reasonable method.
Administration
If you have any questions or concerns about this policy or its related procedures, please contact the Human Resources Department at HRCanada@bartonmalow.com.
This policy and its related procedures will be reviewed as required in the event of legislative changes or changes to BMCL procedures.
4. AODA — Information and Communications Standards Policy
This policy is intended to meet the requirements of the Integrated Accessibility Standards, Ontario Regulation 191/11 for the Information and Communications Standard set forth under the Accessibility for Ontarians with Disabilities Act, 2005. This policy applies to the provision of information and communications services and materials for people with disabilities.
All information and communications materials and services provided by Barton Malow Canada shall follow the principles of dignity, independence, integration and equal opportunity.
Definitions
Accessible FormatsInclude but are not limited to large print, recorded audio and electronic formats, braille and other formats usable by persons with disabilities.Communication SupportsInclude but are not limited to captioning, alternative and augmentative communication supports, plain language, sign language and other supports that facilitate effective communications.Conversion ReadyAn electronic or digital format that facilitates conversion into an acceptable format.
General Principles
In accordance with the Integrated Accessibility Standards, Ontario Regulation 191/11, this policy addresses the following:
- General Requirements
- Feedback Process
- Accessible Formats and Communication Supports
- Emergency Procedures, Plans or Public Safety Information
- Accessible Websites and Web Content
- Exceptions
- Review
A. General Requirements
General requirements that apply across all applicable AODA standards as it relates to Barton Malow Canada’s business (information and communication, employment and customer service) are outlined as follows.
Establishment of Accessibility Policies and Plans. Barton Malow Canada will develop, implement, and maintain policies governing how it will achieve accessibility through these requirements.
Barton Malow Canada will include a statement of its commitment to meeting the accessibility needs of persons with disabilities in a timely manner in its policies. These documents will be made publicly available in an accessible format, upon request.
Barton Malow Canada will establish, implement, maintain, and document a multi-year accessibility plan outlining its strategy to prevent and remove barriers and meet its requirements under the IASR.
Accessibility plans will be made available in an accessible format, upon request, and will be posted on our website.
Barton Malow Canada will review and update its accessibility plan once every five (5) years and will establish, review, and update our accessibility plans in consultation with persons with disabilities or an advisory committee. Annual status reports will be prepared that will report on the progress of the steps taken to implement Barton Malow Canada’s accessibility plan. This status report will be posted on our website. If requested, the report shall be created in an accessible format.
Procuring or Acquiring Goods and Services, or Facilities. Barton Malow Canada will incorporate accessibility criteria and features when procuring or acquiring goods, services or facilities. The only exception is in cases where it is impracticable to do so.
Training Requirements. Barton Malow Canada will provide training for its BMCL employees and volunteers regarding the IASR and the Ontario Human Rights Code as they pertain to individuals with disabilities. Training will also be provided to individuals who are responsible for developing Barton Malow Canada’s policies, and all other persons who provide goods, services, or facilities on behalf of Barton Malow Canada.
Training will be provided as soon as is reasonably practicable. Training will be provided on an ongoing basis to new BMCL employees and as changes to Barton Malow Canada’s accessibility policies occur.
Records. Barton Malow Canada will maintain records on the training provided, when it was provided and the number of BMCL employees that were trained.
B. Feedback Process
Barton Malow Canada will ensure that all feedback processes (both internal and external) are made accessible to customers or BMCL employees, upon request.
In accordance with the customer service standards, Barton Malow Canada will make known the availability of accessible feedback formats.
C. Accessible Formats and Communication Supports
Unless deemed unconvertible, Barton Malow Canada will provide or arrange for the provision of accessible formats and communication supports for persons with disabilities, upon request. Accessible formats and communication supports will be provided in a timely manner and at no additional cost to the individual.
Barton Malow Canada will take into account the person’s accessibility needs when customizing individual requests and shall consult with the individual making the request to ensure suitability.
Barton Malow Canada will make the availability of accessible formats and communication supports publicly known.
D. Accessible Websites and Web Content
Barton Malow Canada will ensure that our website, and where applicable web content, conforms to the Web Content Accessibility Guidelines (WCAG) as outlined in the IASR, and will refer to the legislation for specific compliance deadlines and requirements.
E. Exceptions
The Information and Communications Standard does not apply to:
- Products and product labels;
- Unconvertible information or communications; or
- Information that the organization does not control either directly or indirectly through a contractual relationship.
Unconvertible Information or Communications. If it is determined, in consultation with the requesting party, that information or communications are unconvertible, Barton Malow Canada will ensure that the individual who made the request is provided with an explanation and a summary of the information.
Barton Malow Canada will classify information or communications as unconvertible where:
- It is not technically practicable to convert; or
- The technology required to make the conversion is not readily available.
F. Review
This policy will be reviewed regularly to ensure that it is reflective of Barton Malow Canada’s current practices and legislative requirements.
Multi-Year Accessibility Plan, 2026–2030
Plan Period: 2026–2030
Effective Date: April 1, 2026
Next Review Date: April 1, 2029
Approved By: Rob Frasca, Vice President
1. Statement of Commitment
Barton Malow Canada Ltd. (BMCL) is committed to treating all people in a way that allows them to maintain their dignity and independence. BMCL believes in integration and equal opportunity and is committed to meeting the accessibility needs of persons with disabilities in a timely manner.
BMCL is committed to identifying, preventing and removing barriers to accessibility and to meeting its obligations under the Accessibility for Ontarians with Disabilities Act, 2005 (AODA) and Ontario Regulation 191/11 (Integrated Accessibility Standards Regulation) (IASR), as amended, as well as the accessibility requirements under the Ontario Human Rights Code.
2. Purpose
This Multi-Year Accessibility Plan outlines BMCL’s strategy and ongoing actions to prevent and remove barriers and to improve accessibility for persons with disabilities, in accordance with the AODA and the IASR.
This Plan is intended to support BMCL’s accessibility policies and related practices across the organization.
3. Scope
This Plan applies to BMCL’s operations in Ontario and to all employees, applicants, contractors, and members of the public who interact with BMCL’s goods, services, facilities, communications, and employment processes, as applicable.
This Plan addresses accessibility requirements applicable to BMCL, including (as relevant to BMCL’s operations):
- General Requirements
- Customer Service
- Information and Communications
- Employment
4. Availability of the Plan
BMCL will:
- maintain and document this Multi-Year Accessibility Plan;
- post the Plan on its website (if any); and
- provide the Plan in an accessible format upon request.
BMCL will review and update this Plan at least once every five (5) years, and sooner if required to reflect legislative or operational changes.
5. Roles and Responsibilities
5.1 Leadership / Management
BMCL leadership is responsible for:
- supporting accessibility compliance and implementation across departments;
- allocating appropriate resources to accessibility initiatives; and
- promoting an accessible and inclusive workplace and service environment.
5.2 Human Resources / People Operations
Responsible for:
- accessible recruitment, accommodation, return to work and workplace accommodation processes;
- employee accessibility-related communications and training coordination; and
- maintaining related documentation and records.
5.3 Managers and Supervisors
Responsible for:
- applying BMCL accessibility policies and practices in day-to-day operations;
- responding appropriately to accommodation requests;
- supporting individualized accommodation and return-to-work processes; and
- ensuring accessibility considerations are integrated into workplace practices.
5.4 Employees and Contractors
Responsible for:
- participating in required training;
- complying with BMCL accessibility policies and procedures; and
- reporting accessibility barriers or concerns.
6. Accessibility Policies and Training (General Requirements)
BMCL maintains accessibility policies and practices describing how BMCL achieves or will achieve accessibility in accordance with the IASR and related accessibility standards.
BMCL will continue to:
- review and update accessibility-related policies and practices as needed;
- provide training on accessibility standards and the Ontario Human Rights Code as it relates to persons with disabilities, appropriate to roles and responsibilities;
- provide training to new employees and others covered by the IASR requirements as soon as practicable; and
- provide updated training when there are changes to BMCL’s accessibility policies; and
- maintain records of training, including dates and number of participants, where required.
7. Multi-Year Accessibility Initiatives and Action Plan
The following initiatives set out BMCL’s accessibility strategy for the plan period. Timelines may be adjusted as needed based on operational requirements, legal changes, and identified priorities.
7.1 Customer Service Accessibility
Objective: Ensure persons with disabilities can access BMCL’s goods, services, and facilities in a manner that respects dignity, independence, integration, and equal opportunity.
BMCL will:
- maintain accessible customer service practices and policies;
- support communication with persons with disabilities in ways that take into account their disability;
- permit the use of assistive devices, service animals and support persons, as required by law;
- provide notice of temporary disruptions affecting accessible services or facilities, where applicable; and
- provide and document customer service training for employees and others who interact with the public or third parties on BMCL’s behalf.
Timeline: Ongoing during the Plan period
Responsibility: Facilities Department / Managers / Leadership
7.2 Information and Communications
Objective: Make information and communications accessible to persons with disabilities, upon request and in accordance with applicable legal requirements.
BMCL will:
- provide accessible formats and communication supports for persons with disabilities upon request, in a timely manner, taking into account the person’s accessibility needs and at a cost no more than the regular cost charged to others (if any);
- consult with the requesting person, where appropriate, to determine suitability of an accessible format or communication support;
- ensure public emergency procedures, plans or public safety information made publicly available by BMCL are provided in an accessible format or with appropriate communication supports, upon request;
- maintain an accessible feedback process and make information about the process available in accessible formats upon request; and
- continue to review BMCL’s website and web content for accessibility requirements applicable to BMCL under the IASR (including WCAG conformance requirements, as applicable to BMCL).
Timeline: Ongoing; website reviews annually
Responsibility: Marketing & Communications
7.3 Employment Accessibility
Objective: Maintain accessible employment practices across the employment lifecycle and support accommodation in the workplace.
Recruitment, Assessment and Selection
BMCL will:
- notify employees and the public that accommodations are available for applicants with disabilities in BMCL’s recruitment processes;
- notify job applicants 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;
- consult with applicants who request accommodation and provide or arrange for suitable accommodation, where required; and
- notify successful applicants of BMCL’s policies for accommodating employees with disabilities.
Informing Employees of Supports
BMCL will:
- inform employees of BMCL’s policies used to support employees with disabilities, including policies on job accommodations that take into account an employee’s accessibility needs due to disability;
- provide updated information to employees whenever there is a change to those policies.
Accessible Formats and Communication Supports for Employees
BMCL will:
- where an employee with a disability requests it, consult with the employee to provide or arrange for accessible formats and communication supports for:
- information needed to perform the employee’s job; and
- information generally available to employees in the workplace.
Workplace Emergency Response Information
BMCL will:
- provide individualized workplace emergency response information to employees with disabilities, where necessary and where BMCL is aware of the need for accommodation due to disability;
- with the employee’s consent, provide the information to a person designated to assist the employee;
- review the information when the employee moves to a different location, when accommodation needs or plans are reviewed, and when BMCL reviews its general emergency response policies.
Documented Individual Accommodation Plans
BMCL will:
- maintain a written process for developing and documenting individual accommodation plans for employees with disabilities, as required by the IASR;
- ensure the process includes participation of the employee, assessment of individual needs, and review/update mechanisms.
Return to Work Process
BMCL will:
- maintain a documented return to work process for employees absent due to disability who require disability-related accommodations to return to work;
- outline the steps BMCL will take to facilitate return to work and use documented individual accommodation plans where appropriate.
Performance Management, Career Development, Advancement and Redeployment
BMCL will:
- take into account the accessibility needs of employees with disabilities, and individual accommodation plans, when using performance management processes, providing career development and advancement opportunities, and considering redeployment.
Timeline: Ongoing during the Plan period
Responsibility: Human Resources / Managers / Leadership
8. Reporting, Monitoring and Review
BMCL will monitor progress on the initiatives set out in this Plan and update internal stakeholders as appropriate.
BMCL will review and update this Multi-Year Accessibility Plan at least once every five (5) years, or sooner if needed due to legislative changes, organizational changes, or identified accessibility priorities.