Accessibility

Integrated Accessibility Standards Regulation Policy and Procedure

Providing Goods and Services to People with Disabilities

Purpose

The Accessibility for Ontarians with Disabilities Act (AODA), Ontario Regulation191/11, entitled “Integrated Accessibility Standards Regulation” (“The Regulation”), came into force July 1, 2011. “The Regulation” establishes accessibility standards for customer service, information and communications, employment, transportation, and design of public spaces. Eyereturn Marketing is committed to working towards being compliant with all the standards that apply to Eyereturn Marketing under the AODA.

The purpose of this Policy and Procedure is to provide a framework within which accessibility plans and initiatives are to be created in order to move the organization towards the goal of improved accessibility for people with disabilities. Eyereturn Marketing endeavours to provide accessibility and accommodation as prescribed in the AODA.

Commitment

Eyereturn Marketing is committed to the principles of independence, dignity, integration and equality of opportunity described in the AODA and to meeting the needs of people with disabilities in a timely manner, through the implementation of this policy.

Eyereturn Marketing is committed to establishing, maintaining and implementing policies as well as associated practices and procedures in “The Regulation”, specifically in the areas of customer service, information and communications, and employment, and to meet the accessibility needs of people with disabilities in a timely manner.

Eyereturn Marketing is committed to ongoing improvements to accessibility in its premises and facilities as required by law, as well as to the services offered to customers, employees, volunteers and members of the general public.

Eyereturn Marketing is committed to the establishment, implementation, maintenance and documentation of a multi-year accessibility plan which outlines the organization’s strategy to prevent and remove barriers and meet its requirements under “The Regulation”.

Training

Eyereturn Marketing is committed to the training of all employees, volunteers, persons who deal with customers and the public on behalf of Eyereturn Marketing, and persons participating in the development and approval of Eyereturn Marketing policies, practices and procedures on the requirements under “The Regulation” and the Human Rights Code, as it pertains to persons with disabilities.

Responsibility

This policy applies to Eyereturn Marketing:
- Customers
- Employees
- Volunteers
- Visitors
- Applicants for employment
- Independent Contractors and other persons who provide goods or services on behalf of EyereturnMarketing
- Service Contractors and Sub-contractors

Managers, immediate supervisors and department heads are responsible for ensuring that all employees follow the guidelines set out in this Policy.Each manager, immediate supervisor and department head is responsible to ensure all employees are trained under the Accessibility Regulations and Standards under the AODA, the Human Rights Code and all related policies, practices and procedures.As legislation and compliance requirements are updated, appropriate ongoing training will be provided.

All employees, volunteers, contractors and subcontractors, any other person acting on behalf of Eyereturn Marketing and persons involved in the creation of Eyereturn Marketing policies are responsible for adhering to, and following the commitments set out in this policy.

CUSTOMER SERVICE STANDARD

Refer to Eyereturn Marketing Accessible Customer Service Policy and Procedure

INFORMATION AND COMMUNICATIONS STANDARD Feedback

Eyereturn Marketing is committed to providing high quality goods and services to all of its customers. Feedback from customers and/or third parties is welcomed as it may identify areas that require change and encourage continuous improvement.

Feedback from a member of the public about the delivery of goods and services to persons with disabilities may be provided by telephone, in person, in writing, in electronic format or through other methods. Feedback related to issues regarding accessibility for people with disabilities should be directed to Eyereturn Marketing through our Accessibility Officer by phone 905.281.5650, by email, accessibility@torontostar.com or other appropriate methods.

If anyone wishes to be contacted about their feedback, they must provide their name and contact information.

Complaints will be addressed according to the procedure already established in Eyereturn Marketing complaint management process.

Accessible Formats and Communication Supports

Eyereturn Marketing is committed to meeting alternative format requests in a timely fashion that responds appropriately to any situation.

Eyereturn Marketing will provide, or make arrangements for, accessible formats and information, and communication supports when a person with disabilities requests them.

Emergency Procedures and Plans

Eyereturn Marketing will ensure that emergency procedures and plans or safety information meet the needs of persons with disabilities and will provide this information in an accessible format or with communications supports, on request.

Accessible Websites and Web Content

Eyereturn Marketing will conform to the World Wide Web Consortium’s Web Content Accessibility Guidelines as outlined in “The Regulation” (WCAG) 2.0 Level AA as outlined in the Information and Communications Standard.

ACCESSIBILITY EMPLOYMENT STANDARDS Recruitment, Assessment and Selection Process

Eyereturn Marketing is committed to ensuring that people with disabilities have the same opportunity of access to employment opportunities as all prospective employees and employees. The company will ensure that in its recruitment practices the public is made aware that it will provide accommodation for applicants with disabilities in its recruitment, assessment and selection processes.

When Eyereturn Marketing selects job applicants during a job selection process, we will make applicants aware that, upon request, they have access to accommodation in relation to materials and processes that will be used for applicant selection and that take into account their accessibility needs due to a disability.

When Eyereturn Marketing makes an offer of employment, we will notify the successful applicant of our policy of accommodating employees with disabilities.

Accessible Formats and Communication Supports for Employees

Where an employee with a disability so requests, Eyereturn Marketing will consult with the employee to provide or arrange for accessible formats and communication supports, in relation to information that is generally available to employees and that the employee needs to perform their job.

Workplace Emergency Response Information

Eyereturn Marketing will ensure that individualized workplace emergency response information is provided to employees who have a disability, provided that the disability is such that individualized information is necessary and Eyereturn Marketing have been made aware of the need for accommodation due to disability. Eyereturn Marketing will provide the necessary information as soon as is practicable after becoming aware of the need for accommodation.

If an employee who receives individualized workplace emergency response information requires assistance, Eyereturn Marketing will, with the consent of the employee, provide such information to the person designated to provide assistance to the employee.

Eyereturn Marketing will review individualized workplace emergency response information when:
a) The employee moves to a different location in Eyereturn Marketing.
b) The employee’s accommodation needs or plans are reviewed.
c) When the site where the employee is working reviews its general emergency response procedures.

Individual Accommodation Plans

Eyereturn Marketing will have a process in place for the development of individual accommodation plans for employees with disabilities. The process will address:
- How an employee requesting the accommodation can participate in the process.
- The means by which the employee is assessed on an individual basis.
- How the company can request an evaluation by a medical or other expert in determining if and how accommodation can be achieved.
- How the employee can be represented.
- Steps taken to protect the privacy of personal information.
- The frequency with which the accommodation plan will be reviewed and updated.
- How the reasons for denying an individual accommodation plan will be provided to an employee if the accommodation is denied.
- How Eyereturn Marketing will ensure that the individual accommodation plan is provided in a format that takes into account the employee’s accessibility needs due to the disability.

Return to Work Process

Eyereturn Marketing will follow its established Early and Safe Return to Work Procedure.

Performance Management Process

In administering performance management processes with respect to employees with disabilities, Eyereturn Marketing will take into account the accessibility needs of employees with disabilities as well as individual accommodation plans.

Career Development and Advancement

Eyereturn Marketing will take into account the accessibility needs of employees with disabilities as well as individual accommodation plans.

Redeployment

Eyereturn Marketing will take into account the accessibility needs of employees with disabilities as well as individual accommodation plans during the redeployment process.

DESIGN OF PUBLIC SPACES STANDARD

Parking

The building of new company owned parking spaces and redevelopment of any existing parking spaces will be built and maintained as legislated.

Service Counters and Waiting Areas

The building, redevelopment or major changes to new service counters and waiting areas will be built and maintained as legislated.

RECORD KEEPING

Eyereturn Marketing will maintain accurate records of training delivered to employees and make these records available for inspection as may be required.

Updated: January 2021

Accessible Customer Service Policy and Procedure

Providing Goods and Services to People with Disabilities

1. Purpose

The intent of the Accessible Customer Service Policy (the “Policy”) is to ensure accessibility for persons with disabilities by identifying, removing, and preventing barriers that might interfere with the ability to obtain the goods and services provided by Eyereturn Marketing.

2. Commitment

Eyereturn Marketing strives at all times to provide its goods and services in a way that respects the dignity and independence of people with disabilities. Eyereturn Marketing is also committed to giving people with disabilities the same opportunity to access our goods and services and allowing them to benefit from the same services, in the same place and in a similar way as other customers.

3. Application

The Policy shall apply to every person who deals with members of the public or other third parties on behalf of Eyereturn Marketing, whether that person does so as an employee, independent contractor, agent, volunteer, or otherwise. The Policy shall also apply to every person involved in the development of policies, procedures and practices pertaining to the provision of goods and services by Eyereturn Marketing.

4. Procedures for Providing Goods and Services to People with Disabilities

Eyereturn Marketing is committed to excellence in serving all customers including people with disabilities by removing barriers that might arise in the course of doing business as follows:

(a) CommunicationWe will communicate with people with disabilities in ways that take into account their disability as made known to us.

We are committed to providing fully accessible telephone services to our customers. We will train employees to communicate with customers over the telephone in clear and plain language and to speak clearly and slowly.

In addition, we will offer to communicate with customers by email if telephone communication is not suitable to their communication needs or is not available.

(b) Assistive devices

A person with a disability may provide their own assistive device for the purpose of obtaining, using, and benefiting from Eyereturn Marketing goods and services. Exceptions may occur in situations where Eyereturn Marketing has determined that the assistive device may pose a risk to the health and safety of a person with a disability or others on the premises. In such situations, and others, Eyereturn Marketing may offer a person with a disability other reasonable measures to assist in obtaining, using, and benefitting from Eyereturn Marketing goods and services, where other measures are available.

It is the responsibility of the person with a disability to ensure that the assistive device is operated in a safe and controlled manner at all times.

(c) Service animals

A person with a disability may enter premises owned and/or operated by Eyereturn Marketing accompanied by a service animal and keep the animal with them if the public has access to such premises and the animal is not otherwise excluded by law. If a service animal is excluded by law, Eyereturn Marketing will ensure that alternate means are available to enable the person with a disability to obtain, use and benefit from Eyereturn Marketing goods and services.

It should be noted that it is the responsibility of the person with a disability to ensure that the service animal is kept in control at all times.

(d) Support persons

A person with a disability may enter premises owned and/or operated by Eyereturn Marketing with a support person and have access to the support person while on the premises.

In addition, Eyereturn Marketing may require a person with a disability to be accompanied by a support person while on the premises in situations where it is necessary to protect the health and safety of the person with a disability or of others on the premises.

(e) Notice of temporary disruption

Eyereturn Marketing will make reasonable efforts to provide prior notice of disruptions, if possible, recognizing that in some circumstances such as in the situation of unplanned temporary disruptions, advance notice will not be possible. In all cases, Eyereturn Marketing will notify customers promptly by posting a notice that includes information about the reason for the disruption, its anticipated duration and a description of alternate facilities or services that may be available. The notice will be posted in reasonable places. When possible, disruptions that are known in advance will be posted online.

5. Training

Eyereturn Marketing will provide training to all employees. Where required Eyereturn Marketing will ensure that independent contractors, contractors, agents, volunteers, and others who deal with the public or other third parties on behalf of Eyereturn Marketing receive appropriate instruction. In addition, Eyereturn Marketing will provide training to persons involved in the development of policies, procedures and practices pertaining to the provision of goods and services.

The format of training given will be general for all employees with additional training tailored to suit each person’s interactions with the public or third parties or involvement in the development of policies, procedures and practices, as applicable.

The content of the training will include:
• An overview of the purposes of the Accessibility for Ontarians with Disabilities Act, 2005;
• An overview of the requirements of the customer service standard;
• Instruction on Eyereturn Marketing policies, procedures and practices pertaining to the provision of goods and services to persons with disabilities;
• How to communicate with persons with various types of disabilities;
• How to interact with persons with disabilities who use assistive devices or who require the assistance of a service animal or support person;
• How to use equipment or devices that are provided which may help people with disabilities access goods and services provided by Eyereturn Marketing, such as TTY telephones, elevators, etc.; and
• What to do if a person with a particular type of disability is having difficulty accessing Eyereturn Marketing goods or services.

Training will be provided to each person as soon as practical after being assigned the applicable duties. Training will also be provided on an ongoing basis in connection with changes to the policies, practices and procedures governing the provision of goods and services to persons with disabilities.

6. Feedback process

Eyereturn Marketing is committed to providing high quality goods and services to all of its customers. Feedback from customers and/or third parties is welcomed as it may identify areas that require change and encourage continuous service improvements.

Feedback from a member of the public about the delivery of goods and services to persons with disabilities may be provided by telephone, in person, in writing, in electronic format, or through other methods. All feedback should be directed to Eyereturn Marketing. If they wish to be contacted about their feedback, persons must provide their name and contact information.

Complaints will be addressed according to the procedure already established in Eyereturn Marketing complaint management procedures and can be directed to our Accessibility Officer by phone 905 281 5650 or email accessibility@torontostar.com or other appropriate methods.

Updated: January 2021

Statement of Commitment to Accessibility

At Eyereturn Marketing, we are committed to ensuring accessibility for persons with disabilities by identifying, removing and preventing barriers to promote the rights of all persons and to build and create an inclusive and accessible working environment. Eyereturn Marketing supports the intent of the Accessibility for Ontarians with Disabilities Act and its goal of achieving accessibility for Ontarians with disabilities with respect to customer service, information communication and employment.

Our web pages may direct you to various other third-party websites. Please note that when you select a link from our web pages which directs you to such third- party managed websites, you are no longer on our website. Eyereturn Marketing is not responsible for the accessibility procedures or compliance of any third-party website and cannot guarantee that their website will comply with the Web Content Accessibility Guidelines (WCAG).

January 2021