Accessibility Policy

Introduction and Statement of Commitment
BrandActive International Inc (“BrandActive”) is committed to ensuring accessibility and equality of rights for all team members and customers. On an ongoing basis, we will make reasonable efforts to ensure that policies, practices and procedures are consistent with the principles of dignity, independence, integration and equal opportunity. BrandActive is committed to meeting the accessibility needs of persons with disabilities in a timely manner, and will do so by preventing and removing barriers to accessibility. BrandActive is also committed to training staff on Ontario’s accessibility laws. Training will be provided in a way that best suits the duties and requirements of team members. The following also meets the company’s requirements under the Accessibility for Ontarians with Disabilities Act (AODA).

BrandActive will provide clients, team members, prospective employees, and members of the public with information in an accessible format upon request. BrandActive will respond to such requests as soon as practicable.

Definition of terms
Accessibility — The term accessibility means giving people of all abilities opportunities to participate fully in everyday life. It is used to describe how widely a service, product, device, or environment is available to as many people as possible. Accessibility can be seen as the ability to access and benefit from a system, service, product or environment.

Barrier — Barriers are obstacles that limit access and prevent people with disabilities from fully participating in society. Most barriers are not intentional. Barriers usually arise because the needs of people with disabilities are not considered from the beginning.

Disability — Ontario’s accessibility law adopts the definition for disability that is in the Ontario Human Rights Code. It defines disability broadly:

  1. “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 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,
  2. a condition of mental impairment or a developmental disability,
  3. a learning disability, or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language,
  4. a mental disorder, or
  5. an injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997.”

Working at BrandActive
Accommodations
BrandActive will fairly assess and address eligible accommodation needs of team members in a timely manner as defined under the various Human Rights Codes, including but not limited to those related to disability and/or medical conditions. Accommodations are defined as modifying a role, schedule, or the way in which a role is done.

The most appropriate accommodation to the point of undue hardship to the company will be provided for team members who request accommodation, provide information related to the request and cooperate in the accommodation process. The determination to support or not support a request will be based on the operational requirements of the business, and the eligible needs as defined under the various Human Rights Codes. Successful accommodations require a cooperation and consultative approach by the leadership team, team member requesting the accommodation, HR and third party service providers (as applicable).

Accommodations are managed using the following process:

  • Request accommodation: This can be done through team members requesting an accommodation through their people leader or HR, or through an identification of a need for an accommodation by a team member’s people leader.
  • Gather relevant information and assess needs: HR will provide a set of forms for the team member to complete. This may include medical forms to be completed by the team member’s medical practitioner or an independent medical examination. HR will review the completed forms and follow up if any additional information is required.
  • Discuss potential accommodation options: Once needs are confirmed, HR, the team member and people leader will collaborate to determine the most appropriate accommodation. In the event a temporary leave is a part of the accommodation plan, a return to work plan will be developed. In these circumstances, the team member may return to their original position, return with an accommodation or to an alternate position.
  • Document the decision and plan: The accommodation details will be documented in a formal plan.
  • Implement, monitor and review accommodation plan: Team members and people leaders will monitor the plan to ensure that it is meeting the need. Accommodation plans are reviewed at least every 12 months, or if work location, position or personal situation changes. During our performance review period, including decisions for career development and redeployment, any accommodation plans or needs will be considered. In the event an accommodation requires a reduced working arrangement, BrandActive will provide a benefit of 70% of a team member’s hourly earnings for time not worked for a period of up to six weeks per calendar year. As an example, if a team member is working 80% of their regular hours, they will be paid at 100% of their hourly earnings for the time worked and then at 70% of their hourly earnings for time not worked. After six weeks, team members will only be paid for the time worked. As an example, if a team member is working at 80% of their regular hours, they will be paid at 80% of their regular earnings. The six week entitlement is provided once per calendar year and cannot be reused, transferred or carried over into the following year. Any vacation, statutory holidays, or office closure days taken throughout the duration of an accommodation plan will continue to be paid out at 100% of a team member’s compensation and you will continue to accrue vacation as usual.

Workplace emergency response plan
BrandActive will establish a workplace emergency response plan for any team member who is a person with a disability who may require additional assistance in the event of a workplace emergency. Team members who require assistance of this nature should make their needs known to their supervisor as soon as possible.

BrandActive will also ensure that when team members working in Ontario join the organization, we will confirm whether they require assistance under this plan by integrating it into our onboarding process.

Employment
BrandActive will notify employees, potential hires and the public that accommodations for disabilities can be made during recruitment and hiring. BrandActive will, when requested, accommodate disabilities during recruitment and selection processes and then after an individual has been hired. All applicants will be notified of the ability to provide accommodations on the job description. Prospective applicants will be advised of the ability of accommodations by the HR representative. If a selected applicant requests an accommodation, BrandActive will consult with the applicant and provide a suitable accommodation in a manner that takes into account the applicant’s accessibility needs due to disability.

Customer service
Information and communication
BrandActive is committed to meeting the communication needs of people with disabilities. BrandActive will consult with people with disabilities to determine their information requirements and when asked, we will provide information and communications materials in accessible formats or with communication supports. This includes publicly available information about our goods, services and facilities. BrandActive will also meet internationally-recognized Web Content Accessibility Guidelines (WCAG) 2.0 Level AA website requirements in accordance with Ontario’s accessibility laws.

BrandActive will notify the public that our documents related to accessible customer service are available upon request by posting a notice on BrandActive’s public website (https://brandactive.com/). Upon request, we will also provide these documents, in a timely manner, in alternate formats that take into account the person’s disability.

Support to customers with disabilities

  • Assistive devices: BrandActive will ensure that our team members are familiar with various assistive devices or techniques that may be used by customers with disabilities while accessing our goods or services.
  • Service animals: BrandActive welcomes people with disabilities and their service animals. Service animals are allowed on the parts of our premises that are open to the public.
  • Support persons: A person with a disability who is accompanied by a support person will be allowed to have that person accompany them on our premises. Fees will not be charged for support persons.
  • Self-service kiosks: BrandActive does not currently have any self-service kiosks; however, in the event these are incorporated, we will incorporate accessibility features/consider accessibility for people with disabilities when designing, procuring or acquiring self-service kiosks.

Training
BrandActive is committed to providing training to all team members; including employees, volunteers, independent contractors and others who perform work on behalf of BrandActive and may deal with the public or any other third parties, in Ontario’s accessibility laws and aspects of the Ontario Human Rights Code that relate to persons with disabilities. We will train our team members on accessibility as it relates to their specific roles.. Training will also be provided to people involved in BrandActive’s development of policies, plans, practices and procedures related to the provision of our goods and services. Team members will also be trained in the event there are any modifications to any of the below items.

New team members will be trained within one month of their hire date as part of their team member orientation. Training will include:

  • An overview of the Ontario Human Rights Code, Accessibility for Ontarians with Disabilities Act, 2005 and the requirements of the Customer Service Standard
  • BrandActive’s policy and plan related to accessibility and the Customer Service Standard
  • Awareness on best ways to interact and communicate with people with various types of disabilities
  • BrandActive’s approach to working with people with disabilities who use an assistive device or require the assistance of a service animal or a support person
  • What to do if a person with a disability is having difficulty in accessing BrandActive’s goods and services
  • How to use the wheelchair lifts, etc., available on-site or otherwise that may help providing goods or services to people with disabilities

BrandActive will keep records regarding the training provided, including the dates on which training was provided and the individuals who completed the training.

Notice of temporary disruption
In the event of a planned or unexpected disruption to services or facilities for customers with disabilities, BrandActive will notify customers promptly as appropriate. This will include information about:

  • The facility or service that is unavailable
  • The reason for the disruption
  • The anticipated length of time for the disruption
  • A description of alternative facilities or services, if available.

Feedback process
Customers who wish to provide feedback on the way BrandActive provides goods and services to people with disabilities can provide feedback by telephone, in person, in writing, in electronic format (e.g. email) or through other relevant methods. We will post a statement on BrandActive’s website (https://brandactive.com/) to this effect.

All feedback, including complaints, will be directed to the Director, Human Resources who can be reached at:

Mail: 400 University Ave., Suite 2101 Toronto ON M5G 1S5 T
Phone: 416 595 1511
Email: Via the Contact form on our website (link)

Customers can expect to hear back in 30 working days.

Modifications to this or other policies
Any policy, practice or procedure of BrandActive that does not respect and promote the principles of dignity, independence, integration and equal opportunity for people with disabilities will be modified or removed. No changes will be made to this policy before considering the impact on people with disabilities. Any policy of BrandActive that does not respect and promote the dignity and independence of people with disabilities will be modified or removed.  We have reviewed our current policies and are satisfied that no such modification or removal is required at the present time.

Multi-Year Accessibility Plan

I. Introduction and Statement of Commitment

As stated in our Accessibility policy, BrandActive is committed to ensuring accessibility and equality of rights for all team members and customers. On an ongoing basis, we will make reasonable efforts to ensure that policies, practices and procedures are consistent with the principles of dignity, independence, integration and equal opportunity. BrandActive is committed to meeting the accessibility needs of persons with disabilities in a timely manner, and will do so by preventing and removing barriers to accessibility. BrandActive is also committed to training staff on Ontario’s accessibility laws. Training will be provided in a way that best suits the duties and requirements of team members. The following also meets the company’s requirements under the Accessibility for Ontarians with Disabilities Act (AODA).

As part of BrandActive’s commitment to meeting its obligations under the AODA, BrandActive has developed a multi-year plan which outlines BrandActive’s strategy to prevent and remove barriers and meet its requirements under the AODA.

BrandActive’s Multi-Year Accessibility Plan will be reviewed and updated by BrandActive at least once every five (5) years, and as required.

II. Establishment of Accessibility Policies and Plans

BrandActive has:

  • Developed, implemented and maintained a corporate policy or policies governing how the organization will achieve accessibility;
  • Established, implemented and maintained a Multi-Year Accessibility Plan;
  • Included within its Multi-Year Accessibility Plan a statement of commitment to meet the accessibility needs of persons with disabilities in a timely manner; and
  • Made the corporate policy(ies) and Multi-Year Accessibility Plan available to the public and available in accessible formats upon request.

III. Training

BrandActive:

  • Provides training on the requirements of the IASR and on disability-related obligations under Ontario Human Rights legislation, as well as similar legislative provisions across the country, to the following individuals: associates, volunteers, and any others who may be acting on BrandActive’s behalf in dealing with the public or any other third parties. Training will also be provided to all people who are involved in the development of BrandActive’s policies; and
  • Maintains records of the dates when training is completed and the individuals who completed the training.

IV. Information and Communications Standards

A. Accessible Websites and Web Content

BrandActive has:

  • Made BrandActive’s new internet websites and new content on such websites conform with World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0 Level A.

BrandActive will by January 1, 2021:

  • Make BrandActive’s internet websites and web content conform with WCAG 2.0 Level AA, except for exclusions set out in the IASR.

B. Feedback, Accessible Formats and Communication Supports

BrandActive has:

  • Put a statement on its websites about the availability of accessible formats and communication supports and, upon request, provide or arrange for the provision of accessible formats in a timely manner; and
  • Ensured that the processes for receiving and responding to feedback are accessible to persons with disabilities by providing or arranging for the provision of accessible formats and communications supports, upon request.

V. Employment Standards

A. Recruitment

BrandActive:

  • On its job postings, specifies that accommodations are available for applicants with disabilities;
  • Informs applicants selected to participate in an assessment or selection process that accommodations are available during the recruitment process, upon request, in relation to materials and processes to be used;
  • Upon request, consults with the applicant and arrange for suitable accommodation; and
  • Notifies the successful applicant, when making offers of employment, of its policies for accommodating associates with disabilities.

B. Informing Team Members of Supports

BrandActive:

  • Informs team members and new hires (as soon as practicable) of BrandActive’s policies to support associates with disabilities and keep team members up to date on changes to these policies; and
  • Upon request from an associate with a disability, and further to consultation with the associate, provides for suitable accessible formats and communication supports for: information needed by the team member to perform their job, and information that is generally available to team members.

C. Documented Individual Accommodation Plans / Return to Work Process

BrandActive:

  • Develops a written process for the development of individual accommodation plans; and
  • Develops and document a return to work process for associates who have been absent due to a disability; the process shall outline the steps BrandActive will take to facilitate the team member’s return to work and use the team member’s individual accommodation plan as part of that process.

D. Performance Management, Career Development and Redeployment

BrandActive:

  • Takes into account the accessibility needs of associates with disabilities and individual accommodation plans when utilizing BrandActive’s performance management processes, considering career development and advancement opportunities and redeployment of its associates with disabilities.

E. Workplace Emergency Response Information

BrandActive:

  • Creates individualized workplace emergency response information procedures for team members with disabilities, as required;
  • Prepares Workplace Emergency Response Information forms for team members who have disclosed a disability and who are being accommodated according to their disabilities;
  • Where required, provides assistance to specific disabled team members, with the disabled team member’s prior consent, to help them evacuate the workplace in case of an emergency or disaster. These plans for providing assistance have been set out in individualized emergency plans for the team member;
  • Communicates these individualized emergency plans to the employees’ respective managers and Safety personnel, on an ‘as needed’ basis;
  • On an ongoing and regular basis, and as per the applicable terms of the IASR, reviews and assesses general workplace emergency response procedures and individualized emergency plans to ensure accessibility issues are addressed.

VI. Sections that do not apply

There are several sections that do not apply to BrandActive:

  • Design of public spaces
  • Procurement
  • Self service kiosks
  • Public safety

The above information is accurate and complete as of 17 October, 2023.

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