Accessibility Policy

PURPOSE

Investment Management Corporation of Ontario (“IMCO”) is committed to providing a barrier-free environment for clients and customers and to providing our goods and services in a manner that respects the dignity and independence of people with disabilities. The objective of this policy is to ensure that IMCO is compliant with the customer service requirements of the Accessibility for Ontarians with Disabilities Act, 2005 (the “AODA”).

The purpose of this policy is to outline responsibilities of Covered Persons who deal with the public or other third parties on behalf of IMCO in providing services to people with disabilities in compliance with the AODA.

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

Providing Services to Persons with Disabilities

Principles

IMCO will ensure that this policy and any related practices or procedures are consistent with the following core principles:

1. Dignity: people with disabilities should be treated as valued clients and customers who are as deserving of effective and full service as other clients and customers.
2. Independence: services must be provided without the control or influence of others, and the freedom of people with disabilities to make their own decisions must be respected.
3. Integration: people with disabilities must be able to benefit from services or products in the same place and the same or similar manner as other clients and customers, whenever possible.
4. Equality of Opportunity: people with disabilities must be given an opportunity equal to that given to others to obtain, use and benefit from services

Policy

IMCO is committed to excellence in serving all of its clients and customers, including those with disabilities, and will do so in the following ways:

1. Communications: We communicate with people with disabilities in ways that take into account their disability. IMCO currently employs the following mediums of accessible communication: telephone, online/virtual communication, and email.
2. Telephone services: We will train Covered Persons to communicate with customers over the telephone in clear and plain language and to speak clearly and slowly. We offer to communicate with customers by e-mail.
3. Assistive devices: We are committed to serving people with disabilities who use assistive devices to obtain, use or benefit from our services. We will ensure that Covered Persons are trained and familiar with various assistive devices that may be used by customers with disabilities while accessing our services. The following assistive devices are available on our premises for our customers: accessible washrooms and automatic doors.
4. Use of service animals and support persons: We are committed to welcoming people with disabilities who are accompanied by a service animal on the parts of our premises that are open to the public and other third parties. We will also ensure that all Covered Persons dealing with the public are properly trained in how to interact with people with disabilities who are accompanied by a service animal. Every attempt will be made to ensure that any offsite event venues are compliant with IMCO’s commitment regarding service animals.
   We are committed to welcoming people with disabilities who are accompanied by a support person. They will be allowed to enter IMCO’s premises or offsite event venues with his or her support person. At no time will a person with a disability who is accompanied by a support person be prevented from having access to his or her support person while on our premises or premises operated by IMCO for event purposes.
5. Notice of Temporary Disruption: IMCO will provide customers with notice in the event of a planned or unexpected disruption in the facilities or services usually used by people with disabilities. This notice will include information about the reason for the disruption, its anticipated duration, and a description of alternative facilities or services, if available.
6. Training and Record Keeping: IMCO will ensure that all Covered Persons, and all those who are involved in the development of IMCO’s policies, practices and procedures, are trained.
   The training will be provided as soon as possible after hiring or engagement, on commencement of new or additional duties that require training, and on an ongoing basis when changes are made to the applicable policy, practices or procedures. Training will include the following:
   1. a review of the purpose of the AODA and the requirements of the Customer Service Standard;
   2. a review of this policy;
   3. how to interact and communicate with persons with various types of disabilities;
   4. how to interact with persons with a disability who use an assistive device or require the assistance of a service animal or support person;
   5. how to use assistive devices provided by IMCO; and
   6. how to assist a person with a disability that is experiencing difficulty accessing IMCO’s premises, or services.

   IMCO will ensure that accurate and up-to-date training records are kept. These records shall include the dates of the training and the number of Covered Persons to whom the training was provided.

7. Feedback Process:
   We welcome feedback from the public regarding this policy and its implementation. Feedback regarding the way IMCO provides services to people with disabilities can be made:
   • In person at 16 York Street, Suite 2400, Toronto, Ontario M5J 0E6;
   • By telephone at 416-408-4626;
   • In writing to IMCO, 16 York Street, Suite 2400, Toronto, Ontario M5J 0E6; or
   • Electronically to communications@imcoinvest.com.
8. Documentation:
   Documentation will be made available to members of the public upon request, and in a format that takes into account a person’s disability, in a timely manner, and at a cost that is no more than the regular cost charged to other persons who request the same information. We will consult with the person making the request in order to determine the suitability of an accessible format or communication support.
9. Modifications:
   We are committed to developing customer service policies that respect and promote the dignity and independence of people with disabilities. Therefore, no changes will be made to this AODA policy before considering the impact of such changes on people with disabilities. Any policy of IMCO that does not respect and promote the dignity of people with disabilities will be modified or terminated.

Integrated Accessibility Standards; Statement of Commitment, Policy and Plan

This policy and plan formalize IMCO’s commitment to accessibility and outlines those steps that IMCO will take to remove barriers and improve opportunities for people with disabilities through compliance with the Integrated Accessibility Standards Regulation (the “Integrated Standard”). This policy and plan will be posted on IMCO’s website and will be provided in an accessible format upon request. The policy and plan will be reviewed and updated as necessary at least once every three (3) years. Further, IMCO will file an accessibility compliance report every three (3) years following the initial report, with the next report due to be filed on December 31, 2020.

Statement of Commitment

IMCO is committed to treating all people in a way that allows them to maintain their dignity and independence. IMCO believes in integration and equal opportunity, is 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 the accessibility requirements under the AODA.

Policy and Plan

1. General
   IMCO will provide training on the requirements of the Integrated Standard and on the Human Rights Code (Ontario) as it relates to people with disabilities. IMCO will ensure that training is provided to all Covered Persons and those persons who develop our policies and provide goods, services or facilities on our behalf by:
   
   1. developing and consolidating training materials that address the requirements of the Integrated Standard, including information about achieving accessibility by 2021 and on the disability-related regulations obligations under the Human Rights Code;
   2. reviewing the duties of those Covered Persons that require training, and tailoring the training to be appropriate for such duties;
   3. delivering the training via a method that is appropriate for the audience and the needs of IMCO;
   4. keeping a record detailing those Covered Persons that were trained and when; and
   5. ensuring that new Covered Persons are trained as soon as practicable after being hired and when IMCO’s accessibility policies change.

   At this time, IMCO does not utilize kiosks. However, should the use of kiosks become a part of IMCO’s business in the future, we will ensure that Covered Persons consider the needs of people with disabilities when designing, procuring or acquiring self-service kiosks.

2. Information and Communication
   IMCO is committed to meeting the communication needs of people with disabilities.
   IMCO will ensure that our existing processes for receiving and responding to feedback are accessible to people with disabilities upon request by:
   1. providing multiple methods for feedback, such as in writing or via email, online/virtual communication, telephone or in person; and
   2. considering and implementing those accessible formats or communication supports required elsewhere in the Integrated Standard.

   IMCO will ensure that, upon request, we will provide or arrange for the provision of publicly available information that is in respect of our goods, services or facilities in an accessible format and at a cost that is not more than that charged to others by:
   

   1. consulting with the person making the request to determine the most appropriate accessible format or communication support, given the needs of the person, whether the content is convertible and IMCO’s capability;
   2. providing the accessible format or communication support in a timely manner and at no additional cost; and
   3. notifying the public about the availability of accessible formats and communication supports.

   IMCO will enact a process to provide its customers and clients with publicly available emergency procedures, plans or public safety information in an accessible way, as soon as practicable upon request.
   
   IMCO is committed to meeting the communication needs of people with disabilities, and will ensure that all of its websites and content on those sites conform with WCAG 2.0, Level A.
   
   IMCO will ensure that all websites and content conform with WCAG 2.0, Level AA by January 1, 2021, by:
   

   1. liaising with our Communications, and Information Technology departments to determine whether the website is compliant; and
   2. determining whether the Communications, and Information Technology departments can upgrade the website and content internally, or if third party assistance is required.
3. Employment
   IMCO is committed to fair and accessible employment practices. We will:
   1. notify the public and our staff that we will accommodate people with disabilities during the recruitment process, either through our website, via a Human Resources representative or the applicable job posting, as applicable;
   2. 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 utilized;
   3. consult with job applicants who request accommodation to support them through the recruitment, selection and/or assessment process and take into account their needs, so that the accommodations provided are effective; and
   4. notify the successful applicant of IMCO’s policies for accommodating our employees with disabilities.

   IMCO will inform our Covered Persons of the policies used to support Covered Persons with disabilities, including, but not limited to, policies on the provision of job accommodations that take into account a Covered Person’s accessibility needs due to disability, by:

   1. consulting with Covered Persons with disabilities to determine those accessible formats or communication supports that may be of assistance, and how such accommodation may be provided; and
   2. providing the information as soon as practicable after commencement of employment, and updates whenever there is a change to the policies.

   IMCO has provided individualized workplace emergency response information to Covered Persons with disabilities, if the disability is such that the individualized information is necessary and IMCO is aware of the need for accommodation. Personalized emergency response information is to be reviewed whenever the Covered Persons with disabilities moves to a new work location, when the overall accommodation information is reviewed or altered, or whenever IMCO reviews its general emergency response policies.
   
   IMCO shall put in place a process for the creation of individual accommodation plans for those Covered Persons that have a disability. This process shall be implemented by:

   1. considering how Covered Persons with disabilities will participate in the development of their accommodation plan and what the plans may include;
   2. establishing the means by which the Covered Person is to be assessed, and the manner in which IMCO can request an evaluation by an outside medical or other expert;
   3. establishing where the plans will be stored and what steps will be taken to protect the privacy of Covered Person information; and
   4. determining when and how the individual accommodation plans will be reviewed and updated.
   5. providing the individual accommodation plan, and the reasons for any denial of the individual accommodation plan, in a format that takes into account the Covered Person’s accessibility needs due to disability.

   IMCO shall develop and put in place a documented return to work process for those Covered Persons that have been absent from work due to a disability and require disability-related accommodation in order to return to work. This process shall outline the steps that IMCO will take to facilitate the return to work of the applicable Covered Persons and the use of individual documented accommodation plans.
   
   IMCO will ensure that it takes into account the accessibility needs of Covered Persons with disabilities (as well as their individual accommodation plans) when implementing its performance management process. This will be achieved by:

   1. reviewing an individual’s accommodation plan to understand their needs and determine whether it should be adjusted to improve job performance;
   2. providing performance-management related documents in accessible formats; and
   3. providing informal and formal coaching and feedback in a manner that takes in account an employee’s disability.

   IMCO will take into account the accessibility needs of its Covered Persons with disabilities (as well as their individual accommodation plans) when providing career development, advancement, or redeployment. This may occur through the consideration of what accommodations Covered
   
   Persons with disabilities may need to succeed elsewhere within our organization, to take on new responsibilities in a current role, or when redeployment has become necessary.

4. Design of Public Spaces
   
   At the present time, IMCO does not plan on developing or redeveloping any of its public spaces, as defined in the Design of Public Spaces Standard. However, should it choose to do so, this policy and plan will be revised to include the requirements thereunder and how we will achieve compliance.
5. Future Plan
   
   IMCO will consider accessibility in all aspects of its business and operations and will endeavour to identify and remove accessibility barriers going forward.

POLICY GOVERNANCE

Reviews

The IMCO management owner of this policy for purposes of ensuring that it gets issued, reviewed and updated will be the Chief Human Resource Officer (or such other individual as may be designated from time to time by the CEO) or his/her designate (the “Document Owner”). The Document Owner is also responsible for ensuring relevant IMCO senior executive team members (the “Applicable SET”) have been given a reasonable opportunity to review and comment on this Policy prior to it being reviewed and approved by the Board of Directors of IMCO (the “Board”).

This policy should be reviewed by the Document Owner at least once every three years and the Board.

Non-Material and Material Revisions

For greater certainty, any non-material revisions to this policy can be approved by the Document Owner at any time, following a review of the changes by the General Counsel (GC) or his or her designate. Such non-material revisions may include edits to:

1. cure any ambiguity, clerical or typographical errors;
2. clarify, correct or supplement any provisions which might be defective; or
3. satisfy any legal or regulatory requirement applicable to IMCO.

Any material revisions to this Policy must approved by the Board.

Exceptions

Any request for a non-material exception to this policy must be approved by Chief Human Resource Office and GC.

Any request for a material exception to this policy must be approved by the Board.