Accessibility

“Where Extraordinary People achieve Exceptional Results”

Accessibility Policies and Multi-Year Accessibility Plan
2011-2021

Table of Contents

Accessibility Policies and Multi-Year Accessibility Plan

  1. Statement of Commitment 
  2. Multi-Year Accessibility Plan Overview 
  3. Accessible Emergency Information and Workplace Emergency Response 
  4. Training 
  5. Kiosks 
  6. Information and Communications 
  7. Accessible Websites and Web Content 
  8. Feedback Process 
  9. Employment 
  10. Individual Associate Accommodation Plan and Return to Work Policy 
  11. Performance Management, Career Development and Redeployment 
  12. Other Accessibility Barriers 
  13. Design of Public Spaces 
  14. Feedback Process and Request for Information 
  15. Definitions 
  16. Accessibility Policies and Multi-Year Accessibility Plan Revision History

SmartCentres’ Multi-Year Accessibility Plan for 2011-2021 outlines the policies and initiatives that will be implemented to improve opportunities for people with disabilities.

1. Statement of Commitment

SmartCentres is committed to providing equitable access and high-quality facilities and/or services by meeting the needs of our diverse and valued Associates and customers. To this end, SmartCentres will ensure that it is compliant with the Accessibility for Ontarians with Disabilities Act (AODA), 2005, which aims to remove barriers that impact individuals with a disability. Through compliance, SmartCentres will endeavour to provide all individuals with equal access to our facilities and/or services while allowing individuals with a disability to maintain their independence, dignity, and integration.

2. Multi-Year Accessibility Plan Overview

SmartCentres has developed a strong foundation of accessibility planning in order to remove barriers and ensure real and effective change for people with disabilities, and is eager to carry this commitment forward with the implementation of our Multi-Year Accessibility Plan.

Our Multi-Year Accessibility Plan provides the opportunity to demonstrate our current achievements and establish an implementation framework and future priority initiatives. Objectives identified within the Plan are both long term and short-term; many are ongoing actions or could require implementation over several years. Regular monitoring is necessary to ensure that initiatives are included in the Plan and that progress is identified. The Multi-Year Accessibility Plan’s progress will be reviewed and reported annually and a comprehensive review will be conducted every five years (2019).

3. Accessible Emergency Information and Workplace Emergency Response

SmartCentres is committed to providing our customers and our Associates with publicly available emergency information in accessible formats upon request.

Upon request, Human Resources and Corporate Services will work together with the Associates to develop an individualized emergency response information/plan that will meet their needs in an emergency situation.

Project Title Description Department Responsibility Start Date Completion Date
Employment Initiatives – Emergency Procedures Individualized workplace emergency response information will be provided upon request in an accessible format when the need is communicated. The individualized workplace emergency response information will be reviewed when:

  •  the Associate moves to a different location within the Company;
  • the Associate’s overall accommodation needs or plans are reviewed;
  • SmartCentres reviews general emergency response policies.
Human Resources, Corporate Services Dec 2011 Jan 2012
Employment Initiatives – Emergency Procedures Create a standard template document to be used to develop individual workplace emergency response plans taking into consideration individual accommodation needs. Human Resources, Corporate Services Jan 2014 May 2014

4. Training

SmartCentres will provide training to all Ontario Associates on the Ontario’s accessibility laws and on the Human Rights Code as it relates to persons with disabilities. Training will be tailored to Associate’s responsibilities and duties and it will be provided in a format that best suits the Associate. The training will also be provided to every Ontario Associate who participates in developing SmartCentres’ policies.

SmartCentres will take the following steps to ensure Associates are provided with the training needed to meet Ontario’s accessible laws by January 1, 2015.

Project Title Description Department Responsibility Start Date Completion Date
Training Initiatives Develop Accessibility Standards for Customer Service Policy and training in various formats for all Ontario Associates. Human Resources Sep 2011 Training completed for current Associates.
Training Initiatives Continue to conduct, access and review accessible customer service training for all Ontario Associates. Human Resources Aug 2011 Completed research in Sep 2012.

Ongoing

Training Initiatives Conduct and review Human Rights Code and the Accessibility for Ontarians with Disabilities Act training for all Ontario Associates.

Updated the Quiz in July 2016

Human Resources November 2014

 

Training completed for current Associates.
Training Initiatives Provide training to all new Ontario Associates within 6 months of hire. Human Resources Aug 2011 Ongoing
Training Initiatives Provide periodic training in connection with changes to this Multi-Year Plan and its related practices and procedures. Human Resources May 2014 Ongoing
Training Initiatives Research and provide training for Ontario’s accessibility laws and Human Rights Code training in multiple formats. Human Resources Jan 2014

 

Ongoing

5. Kiosks

SmartCentres does not currently own or operate any kiosks at this time. However, if this should change, SmartCentres will take every step necessary to ensure that available kiosks meet the requirements as outlined by AODA, 2005.

6. Information and Communications

SmartCentres is committed to meeting the communication needs of persons with disabilities. We will consult with persons with disabilities to determine their information and communication needs and accommodate where possible. SmartCentres will take the following steps to ensure that all publicly available information in Ontario is made accessible upon request by 2016.

Project Title Description Department Responsibility Start Date Completion Date
Information & Communication Initiatives AODA statement of commitment sign has been posted at the front reception of SmartCentres’ Home Office.

AODA- Customer Service Policy is made available in large font at Reception.

Human Resources Dec 2012 Jan 2013
Information & Communication Initiatives Provide all tenants with a letter advising them of their responsibilities under the AODA- Customer Service Standard.

This letter is included in the tenant welcome kit.

Operations

Property Management

 

Mar 2012 Apr 2012

and ongoing

Information & Communication Initiatives Continued implementation of a communication campaign to increase awareness of accessibility issues and to inform Associates about issues related to persons with disabilities.

Ongoing ideas to be implemented such as intranet information, information in Town Halls.

Human Resources Marketing June 2012 Ongoing
Information & Communication Initiatives Provide information and communications in accessible formats and with communication supports to people with disabilities upon request. This will be provided in a timely manner and at a cost that is no more than the regular cost charged to other people. Human Resources Marketing Sep 2015

 

Ongoing

7. Accessible Websites and Web Content

SmartCentres will take the following steps to make our websites and content conform to the Web Content Accessibility Guidelines (WCAG) 2.0 Level AA Standards, by January 1, 2021.

Project Title Description Department Responsibility Start Date Completion Date
Information & Communication Initiatives External website to be compliant with WCAG 2.0 Level A Standards. IT, Marketing, Human Resources Nov 2013 Aug 2016

Ongoing monitoring

Information & Communication Initiatives Prepare a list of vendors who have the necessary tools to convert our material into accessible formats in a timely manner. IT, Marketing, Human Resources Jan 2015

To be completed by Jan 2021

Information & Communication Initiatives Establish budget to hire outside consultants to assist in meeting the new standard if we are unable to do so internally.

 

IT, Marketing, Human Resources Jan 2020

To be completed by Jan 2021

Information & Communication Initiatives Work closely with internal Information Technology and Marketing teams to ensure full understanding and compliance with WCAG 2.0 Level AA Standards. IT, Marketing, Human Resources Jan 2020

To be completed by Jan 2021

8. Feedback Process

SmartCentres will take the following steps to ensure that our existing feedback process is accessible to persons with disabilities upon request by January 1, 2015.

Project Title Description Department Responsibility Start Date Completion Date
Feedback Mechanisms Review & continue use of accessible and alternative feedback methods for general and accessibility related feedback. Human Resources Nov 2011 June 2012

and ongoing

Feedback Process Monitor current feedback mechanisms and review opportunities to increase feedback & engagement with persons with disabilities. Human Resources Jun 2012 Ongoing
Feedback Process Continue responding in a timely manner to all accessibility related feedback and/or concerns. Human Resources Jun 2012 Ongoing
Feedback Process Respond to accessibility related feedback and/or concerns in requested format. Human Resources Jun 2012 Ongoing

9. Employment

SmartCentres is committed to fair and accessible employment practices.

By January 2016, SmartCentres will take the following steps to notify the public and our Associates that we will accommodate people with disabilities during the recruitment and assessment process and when candidates are hired.

Project Title Description Department Responsibility Start Date Completion Date
Employment Initiatives- Post accessibility policies on our website addressing our commitment to accommodate people with disabilities. Human Resources Jan 2015

 

Jan 2014
Employment Initiatives Review and revise policy and work processes for recruitment, screening & selection process, to provide accommodations. Human Resources Jan 2015

 

Jan 2016
Employment Initiatives Include a statement on our job posting that persons with disabilities will be accommodated throughout the recruitment and selection process and for the duration of their employment with SmartCentres. Human Resources Jan 2015 Jan 2016

 

Employment Initiatives Successful candidates will be notified of our policies for accommodating employees with disability when the offer of employment is made. Human Resources Jan 2016 Aug 2016 and ongoing

10. Individual Associate Accommodation Plan and Return to Work Policy

SmartCentres has established and implemented a Return to Work Policy and Procedure for developing individual accommodation plans for Associates that have been absent due to a disability.

Project Title Description Department Responsibility Start Date Completion Date
Employment Initiatives

Disability Management

Review and revise Return to Work policy and process with related applicable accommodations in place. Human Resources Jan 2012 Oct 2016
Employment Initiatives

Disability Management

Develop a standard template for the development of Individual Accommodation Plan and Return to Work Plan. Human Resources Jan 2015

 

Oct 2016
Employment Initiatives

Disability Management

Develop training for HR staff on the changes to the policy and process. Human Resources Jan 2012

 

Oct 2016 and ongoing
Employment Initiatives

Disability Management

Communicate Return to Work Policy and procedure to Associates on an as needed basis. Human Resources Jun 2014 Ongoing

11. Performance Management, Career Development and Redeployment

By January 2016, we will take the following steps to ensure the accessibility needs of our Associates with disabilities are taken into account for our performance management, career development and redeployment processes.

Project Title Description Department Responsibility Start Date Completion Date
Employment Initiatives

Performance Management

Review and revise if necessary performance management (PDR), career development (ICD), & Associate redeployment policies.

Added an accommodation statement to the Growth and Development section of the Associate Handbook.

Human Resources, Executive Team Jan 2015

To be completed by Jan 2016

Oct 2016
Employment Initiatives

Performance Management

Develop target training for HR staff, on the changes to the policies and process. Human Resources Jan 2015

 

Apr 2016 and ongoing
Employment Initiatives

Performance Management

Create an individual accommodation plan in consultation with the Associate with disability. This plan will include consideration for performance management, career development and redeployment processes. Human Resources Jan 2015

 

Oct 2016 and ongoing
Employment Initiatives

Performance Management

Communicate revised policies to all Associates. Human Resources Jan 2015

To be completed by Dec 2017

12. Other Accessibility Barriers

SmartCentres will take the following steps to prevent and remove other accessibility barriers identified.

Project Title Description Department Responsibility Start Date Completion Date
Other Accessibility Barriers Continue to remove attitudinal barriers based on continued education & promotion of inclusive work environment. Human Resources Sep 2011 Dec 2012

Ongoing

Other Accessibility Barriers Address any instances where a barrier might exist and determine a course of action to remove the barrier in a timely manner. Human Resources Sep 2011 Sep 2012

Ongoing

13. Design of Public Spaces

By January 2017, SmartCentres will meet the Accessibility Standards for the Design of Public Spaces when building or making major modifications to public spaces in Ontario. Public spaces include:

  • Outdoor public eating areas
  • Outdoor play spaces
  • Outdoor paths of travel, like sidewalks, ramps, stairs, curb ramps, rest areas and accessible pedestrian signals
  • Accessible to off street parking
  • Any other space that the SmartCentres deems necessary

SmartCentres will put procedures in place to prevent service disruptions to its accessible parts of its public spaces.

In the event of a service disruption to the accessible parts of public spaces, we will notify the public of the service disruption and alternatives available.

14. Feedback Process and Request for Information

Any individual who requires additional information regarding SmartCentres’ Accessibility Policies and/or our Multi-Year Accessibility Plan can do so in person, by e-mail, or in writing or by any other means, as required. Accessible formats of our Accessibility Policies and our Multi-Year Accessibility Plan will be made available free upon request. SmartCentres commits to responding to all requests for information in a timely manner.

Please direct any Accessibility related enquiries to:

Fernando C. Vescio, SVP, Human Resources and Corporate Services
700 Applewood Crescent
Vaughan, Ontario, L4K 5X3

Email:  fvescio@smartcentres.com
Phone:  905-326-6400 x 7211
Fax:  905-760-6207

15. Definitions

Associate: employees of SmartCentres
Customer: a member of the public
Disability: defined by the Accessibility for Ontarians with Disabilities Act, 2005, and the Ontario Human Rights Code, refers to the following:

  • 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;
  • A condition of mental impairment or other remedial appliance or device;
  • A learning disability, or dysfunction in one of more of the processes involved in understanding or using symbols or spoken language;
  • A mental disorder; or
  • an injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997.

16. Accessibility Policies and Multi-Year Accessibility Plan Revision History

Revision # Section Header Summary of Changes Date of Change Originator Approved by
A Initial Release Sep 2014 Kateryna Jones Shelley Phillippe
B Page 1-14 Inserted SmartREIT Name, Logo and Contact Number Jun 2015 Michelle Verbruggen Shelley Phillippe
B Page 5 Training Updated Training Initiative Dates Jun 2015 Michelle Verbruggen Shelley Phillippe
C Page 9 Employment Updated Dates Jan 2016 Michelle Verbruggen Shelley Phillippe
D Page 5 Training Added Human Rights and AODA training initiative Oct 2016 Kateryna Jones Shelley Phillippe
D Page 6 Information and Communications Changed completion date to “Ongoing” Oct 2016 Kateryna Jones Shelley Phillippe
D Page 7 Accessible Websites and Web Content Updated completion date for our compliance with WCAG 2.0 Level A Standard Oct 2016 Kateryna Jones Shelley Phillippe
D Page 9 Employment Updated completion date and removed the word “verbal” from the notification of our accommodation policies for successful candidates description Oct 2016 Kateryna Jones Shelley Phillippe
D Page 10 Individual Associate Accommodation Plan and Return to Work Policy Updated completion dates and added a Return to Work Plan to the development of templates description Oct 2016 Kateryna Jones Shelley Phillippe
D Page 11 Performance Management, Career Development and Redeployment Updated completion dates and added to the description that an accommodation statement is now included in the Associate Handbook Oct 2016 Kateryna Jones Shelley Phillippe
D Multiple Changed company name from SmartREIT to SmartCentres Oct 2017 Kateryna Jones Shelley Phillippe