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Accessibility statement

Integrated Accessibility Standard (“IAS”) Policy

Purpose and Policy Statement The goal of the AODA is to create a more accessible Ontario, by identifying and, to the extent possible, preventing and eliminating barriers experienced by a person with a disability.

The Integrated Accessibility Standards Regulation (“IAS”) has been established under the AODA to ensure accessibility for every person with a disability in the areas of (i) information and communication, (ii) employment, (iii) transportation, (iv) design of public space and (v) customer service.

Ledn Inc. (“the Company”) is committed to complying with both the Ontario Human Rights Code and the AODA by eliminating barriers to accessibility and ensuring an accessible environment for employees and members of the public. We are committed to developing, implementing and maintaining policies aimed at meeting the accessibility needs of persons with a disability in a timely manner.

The objective of this policy (the “Policy”) is to identify and document how the Company seeks to achieve compliance with the requirements of the IAS and how it will continue to work toward improving accessibility for persons with a disability.

Nothing in this Policy is intended to replace or negate existing laws related to accessibility for persons with disabilities including but not limited to the Human Rights Code and the Workplace Safety and Insurance Act, 1997.

Scope This policy applies in Ontario to:

  • Every person who is an employee of, or acting as an agent of the Company.
  • Every person who participates in developing the Company’s policies.
  • Every other person who provides goods, services or facilities on behalf of the Company.

Definitions Accessible Format - May include, but is not limited to, large print, recorded audio and electronic format, braille and any other format usable by a person with a disability.

Communication Support - May include, but is not limited to, captioning, alternative and augmentative communication support, plain language, sign language and any other support that facilitates effective communication.

Disability – means:

  • Any degree of physical disability, infirmity, 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 coordination, blindness or visual impediment, deafness or hearing impairment, 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 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 and Insurance Act, 1997.

New Internet Website - means either a website with a new domain name or a website with an existing domain name undergoing a significant refresh.

Performance Management - means an activity related to assessing and improving employee performance, productivity and effectiveness, with the goal of facilitating employee success.

Redeployment - means the reassignment of an employee to another department or job as an alternative to layoff, when a particular job or department has been eliminated.

Self-Service Kiosk – means an interactive electronic terminal, including a point-of-sale device, intended for public use that allows a user to access one or more services or products or both.

Unconvertible Information or Communication – means information or communication that it is not technically feasible to convert, or if it is technically feasible to convert, the technology required to do so is not readily available.

Web Content Accessibility Guidelines (“WCAG”) – means the international standard for making a website and web content accessible to people with a wide-range of disabilities. The IAS requires an organization to become compliant with two levels of the WCAG - Level A and Level AA.

General Accessibility Standards

  • Communication The Company strives to communicate with a person with a disability in a manner that takes into account the individual’s disability.
  • Accessibility Plan The Company has established and implemented an Accessibility Plan to outline the Company’s strategy to prevent and remove barriers for a person with a disability and meet the requirements of the IAS.

The Company will maintain the Accessibility Plan in accordance with the requirements of the IAS and will review and update it at least once every five (5) years.

The Accessibility Plan is posted on the Company’s website and will be made available in an Accessible Format, upon request.

  • Training The Company will provide initial training, and ongoing training as required under the IAS, to all persons to whom this Policy applies.

Training will be provided on: The requirements of the IAS and the Policy. The Company’s obligations under the Ontario Human Rights Code as they relate to a person with a disability.

The Company will ensure training is provided to all persons to whom this Policy applies as soon as practicable after the person is hired or otherwise retained. On-going training will also occur as changes are made to the Policy.

The Company will maintain records of the individuals to whom training is provided and when the training occurred.

  • Self-Service Kiosk The Company will consider the accessibility needs of a person with a disability should it design, procure or acquire a Self-Service Kiosk.

Information and Communication Standards

  • Feedback Procedure The Company will ensure its process for receiving and responding to feedback is accessible to a person with a disability by providing or arranging for the provision of Accessible Formats and Communications Supports, upon request.

The Company will notify the public of the availability of Accessible Formats and Communication Supports for feedback purposes. Feedback can be communicated via email at accessibility@ledn.io.

  • Accessible Formats and Communication Supports Upon request, the Company will provide or arrange for the provision of Accessible Formats and Communication Supports to make its communication or information about its goods, services and/or facilities accessible to a person with a disability. Accessible Formats and Communication Supports will be provided in a timely manner and at a cost no more than the regular cost charged to any other person.

The Company will consult with the person making the request when determining the suitability of an Accessible Format or Communication Support. The Company will also notify the public of the availability of Accessible Formats and Communication Supports.

  • Emergency Plans, Procedures and Public Safety Information The Company will provide any emergency plans, procedures or public safety information that it makes available to the public in an Accessible Format or with appropriate Communication Supports upon request and as soon as practicable.
  • Accessible Websites and Web Content The Company will ensure, where practicable, any New Internet Website and web content on such site(s) conforms with WCAG 2.0 Level A.

By January 1, 2021, the Company will ensure, where practicable, any website or content on that site(s) published after January 1, 2012 conforms with WCAG 2.0 Level AA to the extent required by the IAS.

When determining whether meeting the requirements of this section are practicable the Company will consider the availability of commercial software or tools required to achieve web accessibility; and the impact meeting the requirements of this section will have on any project planned before January 1, 2012.

The commitment to provide an accessible website and web content only applies to a website and web content the Company controls directly or indirectly through a contractual relationship allowing for modification of the website or web content at issue.

Employment Standards The Employment Standards only apply to employees of the Company in Ontario. They do not apply to volunteers or other unpaid individuals or contractors.

  • Recruitment, Selection and Assessment The Company will notify the public and employees of the availability of accommodation during the recruitment process.

The Company will notify job applicants who are individually selected to participate in an assessment or selection process that accommodation is available upon request if the applicant requires accommodation due to a disability.

If an applicant requests accommodation, the Company 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.

  • Notice to Successful Applicants When making an offer of employment, the Company will notify the successful applicant of the Company’s policy on accommodating employees with a disability.
  • Informing Employees of Supports The Company will inform its employees of its policies on supporting an employee with a disability, including, but not limited to, its policy on the provision of job accommodation that takes into account an employee’s accessibility needs due to disability. This information will be provided to a new employee as soon as practicable after commencing employment.

The Company will provide employees with updated information whenever there is a material change to its policies on the provision of job accommodation for an employee with a disability.

  • Accessible Formats and Communication Supports for Employees Upon the request of an employee with a disability, the Company will provide or arrange for the provision of Accessible Formats and Communication Supports to ensure information required by the employee to perform their job and/or information generally available to an employee in the workplace is accessible to the employee with a disability.

The Company will consult with the employee making the request to determine the suitability of any Accessible Format or Communication Support. However, the Company reserves the right to determine the Accessible Format or Communication Support provided.

  • Workplace Emergency Response Information The Company will provide individualized emergency response information to any employee who requires it as a result of a disability. This information will be provided as soon as practicable after the Company becomes aware of the employee’s need for an individualized response.

Where the employee will require assistance in an emergency, and with the employee’s consent, the Company will designate a colleague(s) to provide such individualized assistance and will provide the colleague(s) with the employee’s individualized emergency response information.

The Company will review the individualized workplace emergency response information when (i) the employee moves to a different work location, (ii) the employee’s overall accommodation needs or plans are reviewed, and/or (iii) the Company reviews its general emergency response policies.

  • Individual Accommodation and Return to Work Any individual accommodation plan prepared for an employee will include:
    • Information on Accessible Formats or Communication Supports provided to the employee.
    • Any individualized workplace emergency response plan developed for the employee.
    • Any other forms of accommodation being provided to the employee as a result of their disability.The Company also has a written process for any employee who may be returning to work following a disability-related leave of absence. The process includes the steps taken to facilitate the employee’s return to work and the development of any required individual accommodation plan on return.For more information, please consult the Company’s Return to Work Policy.

Performance Management, Career Development and Advancement and Redeployment The Company will take an employee’s accessibility needs, and any individualized accommodation plan, into account in:

  • Conducting performance management.
  • Providing opportunities for career development and advancement.
  • Making redeployment decisions.

Contact Please contact accessibility@ledn.io if you would like to obtain this document in another format or if you have any questions or concerns about this policy and related procedures.

  1. Multi-year Accessibility Plan, 2022- 2027
  • Summary for multi-year plan: This multi-year accessibility plan (the “Accessibility Plan”) outlines the strategy of Ledn Inc. the “Company”) to prevent and remove barriers for persons with disabilities and to address the current and future requirements of the IAS to ensure the Company may fulfill its commitment as outlined in the Company’s Integrated Accessibility Standards Policy (the “Policy”).]
  • Statement of Commitment Ledn Inc. is committed to complying with both the Ontario Human Rights Code and the Accessibility for Ontarians with Disabilities Act (“AODA”) by eliminating barriers to accessibility and ensuring equal access and participation for people with disabilities. We are committed to meeting the needs of all people with disabilities and treating these individuals in a way that allows for them to maintain their dignity and independence, subject to and in accordance with our legal obligations. This accessibility plan outlines the steps Ledn Inc. is taking to meet those requirements and to improve opportunities for people with disabilities. Our plan shows how Ledn Inc. will play its role in making Ontario an accessible province for all Ontarians.

The AODA has developed a grouping of five standards called the Integrated Accessibility Standards Regulation (“IASR”) to prevent and remove barriers for persons with disabilities. This multi-year accessibility plan (the “Accessibility Plan”) outlines the strategy of Ledn Inc. (the “Company”) to address the current and future requirements of the IASR and the Company’s IASR Policy (the “Policy”).

General Accessibility Standards

Information and Communication Standards

Feedback Process: Ledn has established a process for receiving and responding to feedback about the manner in which the Company provides services to persons with disabilities. This process is accessible to persons with disabilities by providing, or arranging for the provision of, accessible formats and communication supports upon request. This feedback process is available to the public. Status: Compliant

Accessible Formats and Communication Supports: Upon request, Ledn will provide, or arrange for the provision of, Accessible Formats and Communication Supports in order to make communication or information about the services that we offer accessible to persons with disabilities. Ledn commits to provide Accessible Formats and Communication Supports in a timely manner at a cost that is no more than the regular cost charged to other persons and in a manner that takes into account the person’s accessibility needs. Ledn will consult with the person making the request when determining the suitability of an Accessible Format or Communication Support as well as notify the public of the availability of the same. Status: Compliant

Accessible Websites and Web Content: Ensure that, where practicable, a New Internet Website and web content on such site(s) conforms with WCAG 2.0 Level A. By January 1, 2022 ensure that, where practicable, any website or content on that site(s) published after January 1, 2012 conforms with WCAG 2.0 Level AA to the extent required by the IAS. Status: Compliant

Employment Standards

Recruitment: Ledn notifies the public and employees about the availability of accommodation for applicants with disabilities in its recruitment processes. Status: Compliant

Recruitment, assessment or selection process: Ledn notifies 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. Ledn commits to consult with an applicant requesting accommodation to 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. Status: Compliant

Notice to successful applicants: Ledn notifies successful applicants of Ledn’s policies for accommodating employees with disabilities. Status: Compliant

Informing employees of supports: Ledn informs employees of policies used to support employees with disabilities, including policies on the provision of job accommodations that take into account an employee’s accessibility needs as soon as practicable after commencing employment. Ledn provides employees with updated information whenever there is a material change to its policies on the provision of job accommodations for employees with disabilities. Status: Compliant

Accessible Formats and Communication Supports for employees: Upon the request from an employee with a disability, Ledn commits to providing, or arranging for, the provision of Accessible Formats and Communication Supports to ensure that (i) information required by the employee to perform their job; and (ii) information generally available to employees in the workplace, is accessible to the employee with a disability. Ledn commits to consulting with the employee making the request to determine the suitability of any Accessible Format or Communication Support. However where the needs of an employee with a disability may be accommodated in various different ways, Ledn reserves the right to determine the type of Accessible Format or Communication Support that will be provided in the circumstances. Status: Compliant

Workplace emergency response information: If the Company becomes aware of a need for accommodation, for a disability that requires individualized workplace emergency response, the company will work with our building management, the individual and any other necessary third party to provide individualized workplace emergency response information. Ledn will commit to provide this information as soon as practicable after becoming aware of the need for accommodation.

With the consent of the employee, Ledn will provide the workplace emergency response information to the person designated by the Company to provide assistance to the employee when required. Ledn will review individualized workplace emergency response information when the employee moves to a different location in the Company, when the employee’s overall accommodation needs or plans are reviewed and when the Company reviews its general emergency response policies. Status: Compliant

Documented individual accommodation plans: Ledn has in place a written process for the development of documented individual accommodation plans for employees with disabilities. The process includes the following elements:

  • The manner in which 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 manner in which the Company can request an evaluation by an outside medical or other expert, at its own expense, to assist in determining if accommodation can be achieved and, if so, how accommodation can be achieved.
  • The manner in which the employee can request the participation of a representative from the workplace, in the development of the accommodation plan.
  • The steps the Company will take 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 manner in which it will be done.
  • If an individual accommodation plan is denied, the manner in which the reasons for the denial will be provided to the employee.
  • The means of providing the individual accommodation plan in a format that takes into account the employee’s accessibility needs due to disability.

Where requested, an employee’s individual accommodation plan will also include any information regarding the provision of Accessible Formats and Communications Supports. Where required, an employee’s individual accommodation plan will include individualized workplace emergency response information. Status: Compliant

Return to Work (“RTW”) Process: Ledn has in place a documented return to work process for employees who have been absent from work due to a disability and who require disability-related accommodations in order to return to work. The return to work process outlines the steps the Company will take to facilitate the employee’s return to work and will include documented individual accommodation plans as part of the process. Status: Compliant Performance Management: Ledn commits to taking into account the accessibility needs of employees with disabilities, as well as individual accommodation plans, when using its performance management process in respect of employees with disabilities. Status: Compliant Career development and advancement: Ledn commits to taking into account the accessibility needs of employees with disabilities as well as any individual accommodation plans when providing career development and advancement to employees with disabilities. Status: Compliant Redeployment: Ledn commits to taking into account the accessibility needs of employees with disabilities, as well as individual accommodation plans, when redeploying employees with disabilities. Status: Compliant

Customer Service Standard

Customer Service Policy: Ledn has developed, implemented and maintains a Customer Service Policy governing how the Company provides goods, services or accessing facilities to persons with disabilities in compliance with the requirements of the Customer Service Standard. The Customer Service Policy addresses the use of assistive devices or other measures, if available, by persons with disabilities to obtain, use or benefit from the goods, services or facilities. Ledn commits to notifying persons to whom it provides services that the documents are available upon request. Status: Compliant

Service Animals: Ledn commits to allowing a person with a disability to be accompanied by a service animal while on the Company’s premises and to keep the animal with them, unless the animal is otherwise excluded by law. If service animals are excluded by law, Ledn commits to ensuring other measures are available to enable a person with a disability to obtain, use or benefit from the Company’s services. Status: Compliant

Notice of Temporary Disruptions: Ledn commits to providing notice of temporary disruptions in the ability to access our services. The notice of the disruption will include the reason for the disruption, its anticipated duration and a description of alternative services, if any, that are available. Status: Compliant

Training: Ledn commits to ensuring that training on the provision of services to persons with disabilities is provided to everyone who:

  • is an employee
  • provides services on the Company’s behalf;
  • participates in developing Company policies

Ledn commits to ensuring that the training includes the purpose of the AODA, requirements of the Customer Service Standard and instruction on:

  • how to interact and communicate with persons with various types of disabilities
  • how to interact with persons using assistive devices or requiring the assistance of a service animal or support person
  • how to use equipment or devices available on premises or provided by the Company that may help with the provision of goods, services or access to facilities to a person with a disability
  • what to do if a person with a particular type of disability is having difficulty accessing the Company’s goods, services or facilities.

Ledn commits to maintaining records of when and to whom training is provided. Status: Compliant

Accessible Formats & Communication Supports: Ledn commits to providing, or arranging for the provision of, information in document(s) describing policies with respect to the Customer Service Standards in an accessible format or with communication supports, upon request. These requests will be addressed in a timely manner and take into account the person’s accessibility needs, at no additional cost. Ledn will consult with the person to determine suitability of format or support. Status: Compliant

Strategies

2022 and beyond: Ledn will continue to work to update our legacy products and services to ensure they are accessible to all clients.

Ledn is committed to exploring ongoing accessibility awareness and educational opportunities for its employees, contractors and students as well as integrating suggestions submitted to accessibility@ledn.io, where possible.

Ledn will provide regular training on accessibility and customer service.

Ledn will look into developing an internal Accessibility Committee, who will meet regularly with our project teams to ensure all products and services, new or legacy, are on track to be accessible for clients with disabilities.

Contact Please contact accessibility@ledn.io if you would like to obtain this document in another format or if you have any questions or concerns about this plan and related procedures.