CORPORATE POLICIES AND PROCEDURES MANUAL
It is the policy of GEM Health Care to support the full inclusion of persons with disabilities as set out in the Ontario Human Rights Code (the “Code”), and the Accessibility for Ontarians with Disabilities Act, 2005 (the “AODA”). GEM Health Care will provide equal treatment to people with disabilities with respect to the use and benefit of GEM Health Care services and products in a manner that respects their dignity and independence, and that is equitable in relation to the broader public.
In accordance with the requirements set out in the Integrated Accessibility Standards Requirements (IASR), GEM Health Care has established an Accessibility Plan (2014-2021) which outlines GEM Health Care’s commitment and strategy to improve opportunities for persons with disabilities. This goal will be achieved through the prevention and removal of barriers that address current and future requirements of the AODA. GEM Health Care will review and update this plan in consultation with employees and persons with disabilities at least once every five years.
Statement of Commitment
- GEM Health Care is committed to providing its goods and services in a way that respects the dignity and independence of persons with disabilities. This commitment will be integrated whenever possible and will ensure that persons with disabilities will benefit from the same goods and services, in the same place and in a similar way as other customers.
- GEM Health Care is committed to ensuring that every employee and customer receives equitable treatment with respect to employment and services, without discrimination, and receives accommodation where required, in accordance with the provisions of the Code and the AODA and its Regulations. GEM Health Care will meet the accessibility needs of persons with disabilities in a timely manner.
- This policy applies to all individuals entitled to the protections set out in the AODA and its Regulations, including customers and employees of GEM Health Care. Accessible Emergency InformationGEM Health Care is committed to providing its employees and customers with publicly available emergency information in an accessible way upon request. GEM Health Care will also provide its employees with disabilities with individualized emergency response information when necessary.
- Customers with Disabilities: GEM Health Care has implemented an Accessibility Standards for Customer Service policy that applies to all its stores to ensure that customers with disabilities are treated with respect and dignity in their shopping experience.
- Duty to Accommodate: GEM Health Care has implemented an Employment policy that applies to the entire organization to ensure that employees do not face barriers to working or continuing to work because of disabilities.
Accessibility Standards for Customer Service
- GEM Health Care has established a Plan, including guidelines and training, for the delivery of customer service to people with disabilities, in compliance with requirements of the Accessibility Standards for Customer Service, O.Reg. 429/07 made under the Accessibility for Ontarians with Disabilities Act, 2005, S.O. 2005, c.11.
- The GEM Health Care™ Accessible Customer Service Plan (AG – Appendix 9) will be posted on the GEM Health Care website, with progress updates as required. The Plan will also be provided to individuals, upon request, in an appropriate, accessible format.
- This policy applies to all GEM Health Care employees, volunteers, agents and contractors who provide goods and/or services to customers within GEM Health Care or on its behalf. Contractors shall be required to demonstrate to GEM Health Care that they are compliant with the AODA Customer Service Standard training.
- GEM Health Care services, programs and products shall be provided to people with disabilities in a manner that: (a) accommodates disability-related needs; (b) reflects the principles of dignity and independence; and (c) seeks to provide integrated services.
- GEM Health Care shall accommodate the use of personal assistive devices including, but not limited to wheelchairs, walkers, oxygen tanks, and Braille display boards. Assistive devices that are available to access specific services within GEM Health Care shall be kept in good working order and staff will be trained on such devices.
- GEM Health Care shall accommodate the use of service animals by people with disabilities. Cross reference to Policy 3.019.1, Use of Service Animals.
- Where a person with a disability is accompanied by a support person, GEM Health Care shall ensure that both persons are permitted to enter the premises together and shall ensure that the person with the disability can access the support person while on the premises.
- When communicating with a person with a disability, or referring to a person with a disability, GEM Health Care employees and third party contractors shall do so in a manner that respects the person’s disability.
- In the event that there is a temporary disruption in the availability of facilities, services or products used by persons with disabilities; e.g., public washroom out of service, GEM Health Care shall give notice to the public of the reason for the disruption, the anticipated duration and a description of alternative facilities or services, if any, that are available. Such notice may be provided by a variety of methods, depending on the circumstances, and may include postings in conspicuous places at the affected premises and, if appropriate, the company’s website, as well 03.07.14 as other means that will ensure that the notice reaches those persons potentially affected by the temporary disruption. Sample of Notice of Temporary Disruption below.
- The Director of Administration, in conjunction with the Director of Training & Development, is responsible for reviewing this Policy annually and recommending amendments to ensure ongoing compliance with regulated accessibility standards and legislated obligations.
- Managers shall monitor current practices to ensure compliance. Failure to comply with this Policy may result in disciplinary action, up to and including dismissal.
- GEM Health Care is committed to fair and accessible employment practices.
- GEM Health Care will accommodate all employees throughout its organization to ensure that employees do not face barriers to working or continuing to work because of disabilities.
- GEM Health Care will accommodate people with disabilities during the recruitment, assessment and hiring processes and during employment. GEM Health Care will review current recruitment policies, job descriptions, processes and communications and amend as necessary to reflect required integrated accessibility standards.
- GEM Health Care will develop, or revise as required, individual accommodation plans and return-to work policies for employees who have been absent due to a disability.
- GEM Health Care will review and amend as required its performance management, career development and re-deployment processes to ensure the accessibility needs of employees with disabilities are taken into account in connection with these processes.
- GEM Health Care will identify and take any necessary steps to prevent and remove other accessibility barriers impacting employment.03.07.14
- All employees, including managers and supervisors, who deal with the public on behalf of GEM Health Care shall receive training on accessible customer service. This includes information on the Accessibility for Ontarians with Disabilities Act, 2005, S.O. 2005, c. 11 and the requirements of the Accessibility Standards for Customer Service, O. Reg. 429/07 as they pertain to GEM Health Care.
- Accessibility training shall also be provided to all management who are involved in developing, directing or evaluating policies and procedures on providing goods or services.
- Managers shall ensure that training records are maintained, including dates when training is provided and the number of employees who received training.
- Assistive devices that are available to access specific services within GEM Health Care shall be kept in good working order and staff will be trained on such devices.
- GEM Health Care will ensure that the training remains current at all times.
Information and Communications
- The GEM Health Care™ Accessibility Plan will be posted on the GEM Health Care website, with progress updates as required. The Plan will also be provided to individuals, upon request, in an appropriate, accessible format.
- GEM Health Care will take the following steps to make all its internet and intranet websites and web content conform to the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0 level AA by January 2021: review existing websites, assess if current websites meets requirements and make any necessary amendments as required.
- GEM Health Care will take the following steps to ensure existing feedback processes are accessible to people with disabilities upon request: assess current forms of company communication, consider accessibility requirements when creating new forms of communication, make appropriate changes and accommodation, ensure customers and employees are aware of how to participate in providing and receiving a response to feedback.
- GEM Health Care will take the following steps to make sure all publicly available information is made accessible upon request by January 1, 2016: assess all forms of information provided to the public and determine if there is anything that would make it hard for someone with a disability to read, see, hear or understand and establish processes for ensuring alternate formats are available in a timely manner.
- GEM Health Care welcomes and appreciates feedback from persons with disabilities. Feedback can be provided through multiple communication channels. Customers are encouraged to: speak with the store manager; fill out a customer comment card at a store; email us at firstname.lastname@example.org. Feedback will be forwarded to the H.R. Program Administrator, responded to as required, documented and tracked. 03.07.14
- All interactions between customers and employees of GEM Health Care regarding the application of this policy will be considered confidential and will be disclosed only as required to provide appropriate customer service or as required by law.
- If at any point in the future kiosks are to be provided in GEM Health Care stores, we will consider the needs of people with disabilities when designing, procuring or acquiring these self-service kiosks. We will identify areas of our business in which kiosks are to be used and coordinate with its vendors and suppliers to ensure that appropriate accessibility features (technical, structural, access path, etc.) are included in the design of any future purchased kiosks.
Design of Public Spaces
- GEM Health Care will work toward meeting the Accessibility Standards for the Design of Public Spaces when building or making major modifications to public spaces which can include: outdoor public eating areas, off-street parking, ramps, sidewalk, entrances and service-related elements such as service counters, checkout lanes, waiting areas, and washrooms.
- GEM Health Care will put in place procedures to prevent service disruption to its accessible parts of its public spaces. In the event of a service disruption, we will notify the public of the service disruption and alternatives available.
For more information on this accessibility plan, please contact the GEM Health Care Home Office at:
Accessible formats of this document are available free upon request from the GEM Health Care Home Office.
Disability – is defined, per Section 2 of the Accessibility for Ontarians with Disabilities Act, 2005, S.O. 2005, c. 11 and Human Rights Code, R.S.O. 1990, c.H.19, as follows:
a) “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, 03.07.14 amputation, lack of physical coordination, blindness 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,
b) a condition of mental impairment or a developmental disability,
c) a learning disability, or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language,
d) a mental disorder, or
e) an injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997”:
Service Animals – are defined, per Section 4(9) of the Accessibility Standards for Customer Service, O. Reg. 429/07, as follows: “an animal is a service animal for a person with a disability:
a) if it is readily apparent that the animal is used by the person for reasons relating to his or her disability; or
b) if the person provides a letter from a physician or nurse confirming that the person requires the animal for reasons relating to the disability.”
Support Person – is defined, per Section 4(8) Accessibility Standards for Customer Service, O. Reg. 429/07, as follows: “a support person means, in relation to a person with a disability, another person who accompanies him or her in order to help with communication, mobility, personal care or medical needs or with access to goods or services.”