In compliance with Ontario Regulation 191/11 under the Accessibility for Ontarians with Disabilities Act, 2005 (“AODA”), this accessibility plan outlines the policies and actions that Duplium Corp. will put in place to improve opportunities for people with disabilities. 

Statement of Commitment

Duplium Corp. strives to treat all employees in a manner that allows them to maintain their dignity and independence. Duplium Corp. promotes integration and equal opportunity and is committed to meeting the needs of people with disabilities in a timely manner. Duplium Corp. will seek to achieve this by preventing and removing barriers to accessibility and by meeting accessibility requirements under the AODA. This Accessibility Plan sets out Duplium Corp.’s policy on how it will achieve accessibility generally, as well as in employment, information and communications.

1. Workplace Emergency Response Information

Where Duplium Corp. is aware that an Employee has a disability and that there is a need for accommodation, individualized workplace emergency response information will be provided to the Employee as soon as practicable if such information is necessary given the nature of the Employee’s disability.

Such measures could include:
• individualized workplace emergency response information developed for Employees with disabilities, as required;
• individualized emergency plan to be communicated to the Employee’s respective manager on an ‘as needed’ basis;
• on an ongoing and regular basis, and as per the applicable terms of the IASR, Duplium Corp. will review and assess individualized emergency plans to ensure accessibility issues are addressed.

General Definitions

Accessible Formats: include, but are not limited to accessible electronic formats, Braille, text transcripts, large print, recorded audio, and other formats accessible to people with disabilities.
Barrier: as defined by the Ontarians with Disabilities Act, 2001, anything that prevents a person with a disability from fully participating in all aspects of society because of his/her disability. This includes:

• a physical barrier,
• an architectural barrier,
• an informational or communications barrier,
• an attitudinal barrier,
• a policy, practice and procedure barrier.

Communication Supports: include but are not limited to sign language, plain language and other communication supports that facilitate effective communications.
Disability: a key feature of the AODA is its definition of “disability”. Under the AODA, the definition of “disability” is the same as the definition in the Ontario Human Rights Code [2]:
Any degree of physical disability, infirmity, malformation or disfigurement including, but not limited to:

• 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 Accessibility Policy and Multi-Year Accessibility Plan
• Physical reliance of 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 a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language.
• A mental disorder.
• An injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety & Insurance Act, 1997.

The definition includes disabilities of different severity, visible as well as non-visible disabilities, and disabilities that effects of which may come and go. This is a broad definition, and one that must be considered closely when educating our employees in the appropriate response to our customers.

2. Training

Duplium Corp. will provide training to employees, volunteers and other staff members on the requirements of the accessibility standards referred to in the IASR and on the Ontario Human Rights Code, as it relates to people with disabilities.

In accordance with the IASR, Duplium Corp. will:

• determine and ensure that appropriate training on the requirements of the IASR and on the Ontario Human Rights Code as it relates to people with disabilities, is provided to Employees and agents who provide services on Duplium Corp.’s behalf, and people participating in the development and approval of Duplium Corp.’s policies;
• ensure that the training is provided to people referenced above as soon as practicable;
• keep and maintain a record of the training provided, including the dates that the training was provided and the number of employees to whom it was provided;
• ensure that training is provided on any changes to Duplium Corp.’s policies on an ongoing basis.

Planned Action by: January 1, 2015

3. Information and Communication

Duplium Corp. is committed to making company information and communications accessible to people with disabilities. Duplium Corp. will incorporate new accessibility requirements to ensure that its information and communications are accessible and are provided, upon request, in accessible formats that meet the needs of people with disabilities.

i. Feedback, Accessible Formats and Communication Supports In accordance with the IASR, Duplium Corp. will:

• ensure that processes for receiving and responding to feedback are accessible to people with disabilities by providing or arranging for the provision of accessible formats and communication supports, upon request and in a timely manner;
• consult with the person making the request to determine the suitability of the accessible format or communication support;
• provide or arrange for the provision of accessible formats and communication supports in a timely manner that takes into account the person’s accessibility needs due to disability;
• notify the public about the availability of accessible formats and communication supports;
• review and determine current offerings of accessible formats and communications supports and engage in identifying additional accessible formats and communications supports on an ongoing basis.

Planned Action by: January 1, 2015 – feedback; January 1, 2016 – accessible formats and communication supports.

ii. Accessible Websites and Web Content

In accordance with the IASR, Duplium Corp. will work toward making its websites and web content conform with the Web Content Accessibility Guidelines (WCAG 2.0) Level AA.

Planned Action by: January 1, 2014: WCAG 2.0 Level A – for new Internet websites and significant web

Content changes; January 1, 2021: WCG 2.0 Level AA – all Internet websites and web content, as required by the IASR.

4. Employment

i. Recruitment

Duplium Corp. is committed to fair and accessible employment recruiting practices. In accordance with the IASR, Duplium Corp. will do the following:

(a) Recruitment General

Duplium Corp. will notify its employees and external applicants of the availability of accommodation for applicants with disabilities in the recruitment process. This will include:

• review and, as necessary, modification of existing recruitment policies, procedures and processes;
• specify that accommodation is available upon request for applicants with disabilities, on Duplium Corp.’s website and job postings.

(b) Recruitment, assessment and selection

Duplium Corp. will notify job applicants, when they are individually selected to participate in an assessment or selection process and inform them that accommodations are available upon request in relation to the materials or processes to be used in the assessment/selection process. This will include:

• a consultation with the applicant, if selected and arrangement for provision of suitable accommodations in a manner that takes into account the applicant’s accessibility needs due to the disability.

(c) Notice to Successful Applicants

When making offers of employment, Duplium Corp. will, where applicable, notify the successful applicant of its policies for accommodating Employees with disabilities. This will include:

• inclusion of notification of Duplium Corp.’s policies on accommodating Employees with disabilities in offer of employment letters.

Planned Action by: January 1, 2016

ii. Informing Employees of Supports and General Provision of Accessible Formats and Communications Supports

In accordance with the IASR, Duplium Corp. will inform its Employees of policies that support Employees with disabilities. This will include:

• informing current Employees and new hires of Duplium Corp.’s policies supporting Employees with disabilities;
• providing information as soon as practicable after the new Employee begins employment, specifically in the orientation process;
• keeping Employees up to date on changes to existing policies on job accommodations with respect to disabilities;
• where an Employee with a disability requests it, Duplium Corp. will provide or arrange for provision of suitable accessible formats and communications supports for:

1. information that is needed in order to perform the Employee’s job;
2. information that is generally available to Employees in the workplace; and Accessibility Policy and Multi-Year Accessibility Plan

• in meeting the obligations to provide the information that is set out above, Duplium Corp. will consult with the requesting Employee in determining the suitability of an accessible format or communication support.

Planned Action by: January 1, 2016

iii. Documented Employee Accommodation Plans/Return to Work Process

In accordance with the provisions of the IASR, Duplium Corp. will ensure that the process for the development of documented employee accommodation plans includes the following elements:

• information regarding the manner in which Duplium Corp. can request an evaluation by an outside medical or other expert to assist Duplium Corp. in determining if and how accommodation can be achieved;
• steps to protect the privacy of the Employee’s personal information;
• information regarding the frequency with which employee accommodation plans will be reviewed and updated and the manner in which this will be done;
• the reasons for a denial if an employee accommodation plan is denied;
• information regarding the means of providing the employee accommodation plan in a format that takes into account the Employee’s accessibility needs;
• any individualized workplace emergency response information that is required;
• any information regarding accessible formats and communication supports that have been provided for or arranged, in order to provide the Employee with:

1. information that is needed in order to perform the Employee’s job;
2. information that is generally available to Employees in the workplace; and
3. identify any other accommodation that is to be provided to the Employee.

Duplium Corp. will ensure that the return to work process as set out in its policies outlines:

• the steps it will take to facilitate the Employee’s return to work after a disability-related absence;
• the development of a written individualized return to work plan for such Employees; and
• the use of employee accommodation plans, as discussed above, in the return to work process.

Planned Action by: January 1, 2016

iv. Performance Management, Career Development and Advancement and Redeployment

Duplium Corp. will take into account the accessibility needs of Employees with disabilities, as well as individual accommodation plans:

• when conducting performance management reviews in respect to Employees with disabilities;
• when providing career development and advancement to Employees with disabilities; and
• when redeploying Employees with disabilities.

In accordance with the IASR, Duplium Corp. will:

• review, assess and, as necessary, modify existing policies, procedures and practices to ensure compliance with the IASR;
• take the accessibility needs of Employees with disabilities and, as applicable, their individualized accommodation plans, into account when:

1.  assessing performance;
2. managing career development and advancement; and
3. redeployment is required.

• take into account the accessibility needs of Employees with disabilities when providing career development and advancement to its Employees with disabilities, including notification of the ability to provide accommodations on internal job postings; and
• take into account the accessibility needs of Employees with disabilities when redeploying Employees, including review and, as necessary, modification of Employee transfer checklist.

Planned Action by: January 1, 2016

Information and Feedback

For more information on this Accessibility Plan or for accessible formats of the Accessibility Plan, please contact: Duplium Corp.’s Human Resources Department, by email at hr@duplium.com or by phone at 905.709.9930 ext.3506.