Accessibility Standards For Customer Service Policy

ACCESSIBILITY STANDARDS FOR CUSTOMER SERVICE POLICY

Policy Statement

Homestead is committed to meeting its obligations under the Accessibility for Ontarians with Disabilities Act, 2005, in providing an environment that is accessible for all people and treats individuals with respect and dignity.

The goal of the Act is to identify, and to the extent possible, remove and prevent barriers and increase accessibility for persons with disabilities in the areas of information and communications as well as employment. These standards apply to Homestead.

Application

This policy applies to all Homestead employees regardless of position or classification. This policy also applies to all persons who attend Homestead workplaces including, but not limited to, all visitors, tenants, contractors, vendors and delivery persons.

Definitions (according to the Act)

Disability is:

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 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; 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.

Barriers are:

anything that prevents a person with a disability from fully participating in all aspects of society because of his or her disability, including a physical barrier, an architectural barrier, information or communications barrier, an attitudinal barrier, an information or communications barrier, a technological barrier, a policy or practice.

Assistive Devices are:

Personal assistive devices are usually devices that people bring with them, such as a walker or a personal oxygen tank.

Service Animals are:

An animal is qualified to be a service animal if it is readily apparent the animal is used by the person for reasons relating to his or her disability; or the person provides a letter from a physician or nurse confirming the person requires the animal for reasons relating to the disability.

Support Persons are:

in relation to a person with a disability, another person who accompanies the person with a disability in order to help with communication, mobility, personal care or medical needs or with access to goods, services or facilities;

D. Policy and Procedures for Providing Goods and Services to Persons with Disabilities

Homestead shall make all reasonable efforts to ensure that its policies and procedures are consistent with the following principles:

services are provided in a manner that respects the dignity and independence of persons with disabilities;
persons with disabilities are given an opportunity equal to that of persons without disabilities.

This commitment is demonstrated in the following areas:

Communication:

When communicating with a person with a disability, employees will do so in a manner that takes into account the person's disability. In addition, we will offer to communicate with customers by email or fax if telephone communication is not suitable to their communication needs or is not available.

The company will train all persons to whom this policy applies on how to interact and communicate with people with various types of disabilities.

Assistive Devices:

A person with a disability is permitted, where possible, to use their own assistive device when on our premises for the purpose of obtaining, using or benefiting from our goods and services. Exceptions may occur in situations where the company has determined that the assistive device may pose a risk to the health and safety of a person with a disability or others on the premises, or does not comply with the Municipal By-Laws of the Ontario Building Code.

It is the responsibility of the person with a disability to ensure that the assistive device is operated in a safe and controlled manner at all times.

Service Animals:

A person with a disability may enter premises owned or operated by Homestead accompanied by a service animal and keep the animal with them if the public has access to such premises and the animal is not otherwise excluded by law. If the service animal is excluded by law, Homestead will ensure that alternative means are available to enable the person with a disability to obtain, use or benefit from the company's goods or services.

It should be noted that it is the responsibility of the person with a disability to ensure that the service animal is kept in control at all times.

Support Persons

A person with a disability may enter premises owned and/or operated by Homestead with a support person and have access to the support person while on the premises. In addition, Homestead may require a person with a disability to be accompanied by a support person while on the premises in situations where it is necessary to protect the health and safety of the person with a disability or of others on the premises.

Notice of Temporary Disruption

Homestead will make reasonable efforts to provide prior notice of disruptions, if possible, recognizing that in some circumstances such as in the situation of unplanned temporary disruptions, advance notice will not be possible.

When it is possible to do so, Homestead will provide notice of any disruption to residents/customers while including the following information:

the reason for disruption;
its anticipated duration; and
a description of alternative facilities or services, if any, that may be available.

When elevators are being replaced reasonable assistance will be available for all who need it.

When temporary disruptions occur to Homestead's services or facilities, the company will provide notice by posting the information at relevant visible locations, in elevators, and/or by any other method that is reasonable and applicable under the circumstances. Other methods of notification may include notices under the door.

Training and Records

Homestead will ensure that all persons to whom this policy applies receive training as required under the Accessibility Standards for Customer Service. Training will be provided as soon as practicable upon an individual being hired or assigned the applicable duties, as well as on an ongoing basis as changes occur to the company's policies, procedures and practices in dealing with persons with disabilities.

The content of the training will include:

a review of the purpose of AODA;
the requirements of the Accessibility Standards for Customer Service
instruction on Homestead policies, procedures and practices pertaining to the provision of accommodation and services to persons with disabilities;
how to interact and communicate with persons with various types of disabilities;
what to do if a person with a disability is having difficulty accessing our premises and/or services;
how to interact with persons with disabilities who use assistive devices or who require the assistance of a service animal or support person; and,
information about the equipment or devices made available on our premises to assist persons with disabilities.

Homestead will maintain records of the training, including the date on which the training is provided, the number and names of individuals to whom it is provided, and the nature of the training that is provided.

Feedback Process

Homestead is committed to providing quality rental accommodations and services to all of its customers. Feedback from customers and/or third parties is welcomed and appreciated as it may identify areas that require change and encourage continuous service improvements.

Feedback can be provided in person, in writing, in electronic format, or through other methods. All feedback should be directed to the Property Manager of a particular building, or alternatively forwarded to the attention of the Assistant Vice President of Operations at:

Homestead Land Holdings Limited

80 Johnson Street

Kingston, ON

K7L 1X7

Phone: (613) 546-3146

Fax: (613) 546-5637

Email: customerservice@homestead.ca

We will send customers an acknowledgement and response to their feedback in accordance with the AODA.

Availability of Documents

All documents required by the Accessibility Standards for Customer Service, including the company Accessible Customer Service Policy and procedures are available upon request or may be accessed on the Homestead Land Holdings website at www.homestead.ca.

When a person with a disability requests a document in an alternate format, the company will reasonably provide the document, or the information contained in the document, in the requested format or an alternate format that complies with the AODA.

Notice of availability of all documents required by the Accessibility Standards for Customer Service will be posted on the company's website and will be made available at the rental office.

INTEGRATED ACCESSIBILITY STANDARDS POLICY

Policy Statement

This policy is intended to meet the requirements of the Integrated Accessibility Standards, Ontario Regulation 191/11, under the Accessibility for Ontarians with Disabilities Act, 2005 in meeting the accessibility needs of persons with disabilities.

Homestead is committed to ensuring and implementing accessibility standards in all of its practices, which includes providing employees with disabilities with the same opportunities as other employees.

Application

This policy applies to all Homestead employees regardless of position or classification.

General Requirements

Establishment of Accessibility Policies and Plans

Homestead will establish, maintain and document a multi-year accessibility plan outlining its strategy to prevent and remove barriers and meet its requirements under the IASR regulation. The multi-year accessibility plan will be reviewed and updated at least once every five years, and will be posted on Homestead's website. Upon request, Homestead will provide a copy of the multi-year accessibility plan in an accessible format.

Procuring or Acquiring Goods and Services, or Facilities

Homestead will incorporate accessibility criteria and features when procuring or acquiring goods, services or facilities where it is practical to do so.

Training Requirements

Homestead will provide training for its employees and individuals who are responsible for developing their policies, regarding the IASR, and will continue to provide training on the Human Rights Code as it pertains to persons with disabilities.

Training will be provided for new employees and when changes are made to the Accessibility Policy, and on an ongoing basis.

Homestead will keep a record of the training it provides, when it was provided and the number of employees that were trained.

Information and Communications Standards

Homestead will create, provide and receive information and communications in a way that is accessible for persons with Disabilities.

Feedback

Homestead will ensure that its process for receiving and responding to feedback is accessible to persons with disabilities by providing, or arranging for the provision of accessible formats and communication supports, upon request.

Accessible Formats and Communication Support

Upon request, Homestead will provide, or will arrange for the provision of accessible formats and communication supports for persons with disabilities in a timely manner that takes into account the person's accessibility needs due to disability. Homestead will consult with the person making the request in determining the suitability of an accessible format or communication support.

Emergency Information

When Homestead prepares emergency procedures, plans or public safety information and makes the information available to the public, the information will be available in an accessible format or with appropriate communication supports, as soon as practicable, upon request.

Accessible Websites and Web Content

Homestead will ensure that its internet website and web content conform to the Web Content Accessibility Guidelines (WCAG) 2.0 initially at Level A and increasing to Level AA as outlined by the IAS, except where it is impracticable.

Employment Standards

Recruitment

Homestead will notify employees and the public about the availability of accommodation for applicants with disabilities in its recruitment process.

Recruitment, Assessment and/or Selection Process

Homestead will notify job applicants when they are selected to participate in an assessment or selection process that accommodations are available upon request.

If a selected applicant requests an accommodation, Homestead will consult with the applicant and provide or arrange for the provision of suitable accommodation in a manner that takes into account the applicant's accessibility needs due to disability.

Notice to Successful Applicants

When making offers of employment, Homestead will notify the successful applicant of its policies for accommodating employees with disabilities.

Informing Employees of Supports

Homestead will inform its employees of its policies (and any updates to those policies) used to support employees with disabilities, including policies on the provision of job accommodations that take into account an employee's accessibility needs due to disability. This information will be provided to new employees as soon as practicable after commencing employment.

Accessible Formats and Communication Supports for Employees

Upon the request of an employee with a disability, Homestead will consult with the employee to provide or arrange for the provision of accessible formats and

communication supports needed to perform the employee's job, as well as information generally available to other employees.

When determining the suitability of an accessible format or communication support, Homestead will consult with the employee making the request. However, Homestead reserves the flexibility to decide on the most appropriate

accessible formats or communication supports for employees (based on the needs of the specific employee and the capacity of Homestead to provide the support).

Workplace Emergency Response Information

Homestead will provide individualized workplace emergency response information to employees who have a disability, if the disability is such that the individualized information is necessary, and if Homestead is aware of the need for accommodation due to the employee's disability. Homestead will provide this information as soon as practicable after becoming aware of the need for accommodation.

Where the employee requires assistance, Homestead will provide the workplace emergency response information to the person designated by Homestead to provide assistance to the employee.

Homestead will review the individualized workplace emergency response information when the employee moves to a different location in the organization, when the employee's overall accommodation needs or plans are modified, and when Homestead reviews its general emergency response policies.

Documented Individual Accommodation Plans

A written process for the development and maintenance of documented individual accommodation plans shall be developed for employees with disabilities. If requested, these plans shall include information regarding accessible formats and communication supports.

Return to Work Process

Homestead will maintain a documented return to work process for its 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 will outline the steps Homestead will take to facilitate the return to work and will include documented individual accommodation plans as part of the process.

This return to work process will not replace or override any other return to work process created by or under any statute (i.e. the Workplace Safety Insurance Act, 1997).

Performance Management, Career Development and Advancement & Redeployment

Homestead will continue to take into account the accessibility needs of employees with disabilities, as well as individual accommodation plans, when conducting performance management, providing career development and advancement to employees, or when redeploying employees.

Review Period

This policy will be reviewed annually and will be revised according to any legislative or organizational changes as required.

MULTI-YEAR ACCESSIBILITY PLAN

Introduction and Statement of Commitment

In 2005, the government of Ontario passed the Accessibility for Ontarians with Disabilities Act (AODA). The Integrated Accessibility Standards Regulations (IASR) under AODA requires Homestead to establish and implement a multi-year plan outlining their strategy to prevent and remove barriers, and to meet requirements under the Regulation.

This multi-year plan outlines Homestead's strategy to prevent and remove barriers to address the current and future requirements of the IASR, and fulfill Homestead's commitment as outlined in the company's Accessibility policies.

Accessibility Standards For Customer Service

Since 2011, Homestead has been in compliance with the Accessible Customer Service Regulation and will continue to comply with that regulation.

Homestead is committed to providing excellent service to customers, including customers with disabilities and it will continue to do so in a manner that offers an accessible customer service experience.

Action Taken:

Ensuring all employees, including those involved in the development and approval of customer service policies, practices and procedures are trained to communicate and provide the best possible customer service to all customers, including persons with disabilities;
Ensuring completion of accessibility training is tracked and recorded;
Offer various methods of communication with customers, such as by telephone, facsimile, email, and will offer alternate methods if requested and if practicable;
Ensuring customers accompanied by a service animal in any of our buildings are accommodated unless the service animal is excluded by law, in which Homestead will ensure that alternative means are available in order to obtain, use or benefit from the company's services;
Ensuring that if a person with a disability is accompanied by a support person, the support person is accommodated;
Providing customers with notice in the event of a planned or unexpected disruption of service or inaccessibility of facilities used by persons with disabilities, by posting the information at relevant visible locations such as in elevators, and/or any other reasonable location that is applicable under the circumstances. Other methods of notification may include notices under the door of residents;
Continuing to welcome and appreciate feedback from persons with disabilities through multiple communication channels;
Offers the public information on Homestead's accessible customer service policy and procedures on its website, www.homestead.ca;
Reporting compliance with the Customer Service Standard on the Accessibility Compliance Reporting tool at Service Ontario's website.

Implementation timeframe: January 2010 and ongoing

Integrated Accessibility Standards Regulations

Information and Communications:

Training

Homestead is committed to providing training for its employees and individuals who are responsible for developing their policies, regarding the requirements of the accessibility standards referred to in the IASR and will continue to provide training on the Human Rights Code as it pertains to persons with disabilities.

Planned Action:

Homestead will continue to provide training to employees on the Human Rights Code and will provide training on accessibility and removing barriers for persons with disabilities. This training will be delivered to employees on an ongoing basis and if any changes are made to the prescribed policies. Homestead will keep a training record including training dates and the number of individuals training was provided to.

Implementation Timeframe: January 1, 2015 and ongoing

Feedback

Homestead will ensure that its process for receiving and responding to feedback is accessible to persons with disabilities.

Planned Action:

Homestead will ensure that existing and new processes for receiving and responding to feedback are accessible to persons with disabilities by providing or arranging for the provision of accessible formats and communication supports, upon request.

When accessible formats and communication supports for persons with disabilities are requested, Homestead will:

Provide or arrange for the provision of such accessible formats and communication supports if practicable, or otherwise consider reasonable alternatives to achieve accessibility;
Consult with the person making the request to determine the suitability of the accessible format or communication support;
Provide or arrange for the provision of accessible formats and communication supports in a timely manner that takes into account the person's accessibility needs due to disability.
Notify the public about the availability of accessible formats and communication supports.

Implementation Timeframe: January 1, 2015 and ongoing

Homestead will, on an ongoing basis, review its general processes for providing feedback and consider how it may make those processes more accessible to persons with disabilities.

Accessible Formats and Communication Supports

Homestead is committed to making company information and communications accessible to person with disabilities.

Planned Action:

Upon request, Homestead will provide or arrange for the provision of accessible formats and communications supports for persons with disabilities in a timely manner that takes into account the person's accessibility needs due to disability.

Homestead will consult with the person making the request.

Homestead will notify the public about the availability of accessible formats and communication supports.

Also, if Homestead prepares emergency procedures, plans or public safety information and makes the information available to the public, Homestead will provide this information in an accessible format or with appropriate communication supports, as soon as practicable, upon request.

Implementation Timeframe: January 1, 2016 and ongoing

Homestead will, on an ongoing basis, review the way it communicates company information and consider how it may make that communication more accessible to persons with disabilities.

Accessible Websites and Web Content

Homestead's internet website and web content currently conforms to the Web Content Accessibility Guidelines (WCAG) 2.0 Level A, and will be increasing to Level AA as outlined by the IAS, except where it is impracticable.

Planned Action:

Homestead will ensure that its internet websites and web content are developed in accordance with the WCAG as required by the Regulation.

Implementation Timeframe: Homestead has and will continue to conform to WCAG 2.0 at level A. By January 1, 2021, the website and web content will conform to WCAG 2.0 at level AA, unless it is impracticable.

Implementation Timeframe: New website was implemented March 2016 and compliance will be ongoing

Employment

Recruitment Process

Homestead is committed to fair and accessible recruitment and employment practices. This involves providing accessibility at all stages of the recruitment cycle.

Planned Action:

Homestead will notify employees and the public of the availability of accommodation for applicants with disabilities in the recruitment process. This will include specifying that accommodation is available for applicants with disabilities on Homestead's website and on job postings.

Homestead will continue to advise job applicants when they are selected to participate in an assessment or selection process, about the availability of accommodations.

Applicants requesting accommodation will continue to be consulted about their needs and appropriate accommodation will be provided.

As part of the hiring process, new employees will be provided with Homestead's accommodation policies.

Implementation Timeframe: January 1, 2016 and ongoing

Informing Employees of Supports

Homestead will inform its staff of policies that support employees with disabilities, including, but not limited to, policies on the provision of job accommodations that take into account an employee's accessibility needs due to a disability. Homestead will provide this information to new employees as soon as practicable.

Planned Action:

Homestead will inform employees of relevant policies and policy changes on an ongoing basis.

Homestead will continue to consult with any employee who requests accommodation, and will provide accommodation support, including accessible formats and communication supports, needed for the employee to perform their job where it is practicable to do so.

Implementation Timeframe: January 1, 2016 and ongoing

Workplace Emergency Response Information

If Homestead is aware that an employee needs accommodation with respect to workplace emergencies, individualized workplace emergency response information will be provided to the employee as soon as practicable.

Planned Action:

Homestead will continue to advise employees to provide notice of any accommodation needs with respect to workplace emergencies.

If appropriate and in consultation with employees needing accommodation, Homestead will continue to prepare and provide employees with individualized workplace emergency response information. Homestead will keep a confidential record of individualized workplace emergency response information requests and responses. Individualized workplace emergency response information will be updated when the employee moves to a different location or job, and when overall accommodation needs or plans or general emergency response policies are reviewed.

Homestead will designate individuals to assist employees needing accommodation during workplace emergencies and, with the consent of the affected employee, may provide the individualized workplace emergency response information to the designated individual.

Implementation Timeframe: Current and ongoing

Individual Accommodation Plans/Return To Work

Homestead will incorporate new accessibility requirements under the IASR to ensure that barriers in accommodation and return to work processes are eliminated and company policies surrounding accommodation and return to work are followed, where applicable.

Planned Action:

Homestead maintains an accommodation/return to work policy that includes steps that Homestead will take to accommodate an employee with a disability and to facilitate an employee's return to work after absenteeism due to disability. The policy and accommodation plans under this policy will also include the following:

How 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;
How Homestead can request an evaluation by an outside medical or other expert, to assist the company in determining if accommodation can be achieved and, if so, how;
How the privacy of the employee's personal information, with respect to the accommodation, will be protected;
How the individual accommodation plan will be reviewed and updated and the manner in which it will done;
Reasons for the denial of an individual accommodation plan will be provided to the employee if denial is the outcome;
The means of providing the individual accommodation plan in a format that takes into account the employee's accessibility needs due to disability.

Implementation Timeframe: Current and ongoing

Performance Management, Career Development and Advancement, and Redeployment

Planned Action:

Homestead will continue to ensure that managers are aware of their responsibility to take into account the accessibility needs of employees with disabilities, as well as individual accommodation plans, when conducting performance management, providing career development and advancement to employees, or when engaging in employee redeployment.

Implementation Timeframe: January 1, 2016 and ongoing

Design of Public Spaces Standards

Homestead is committed to designing and building spaces that are accessible for all persons.

Planned Action:

Homestead will ensure that accessibility standards are incorporated when building or making major modification to public spaces.

Implementation Timeframe: By January 1, 2017 and ongoing

ADDENDUMS TO:

ACCESSIBILITY STANDARDS FOR CUSTOMER SERVICE POLICY

INTEGRATED ACCESSIBILITY STANDARD POLICY

MULTI-YEAR ACCESSIBILITY PLAN

Effective July 1^st, 2016 the following addendums have been implemented:

All accessibility standards - including the accessible customer service standard - are now part of one regulation: the Integrated Accessibility Standards Regulation (O. Reg. 191/11). Consequently this change revokes the Accessibility Standards for Customer Service (Ontario Reg. 429/07) and Exemption from Reporting Requirements (O. Reg. 430/07).

A person with a disability can provide documentation from a regulated health professional (including Physicians and Surgeons, Nurses, Psychologists, Psychotherapists and Mental Health Therapists, Audiologists and Speech-Language Pathologists, Chiropractors, Occupational Therapists, Physiotherapists and Optometrists).

Effects ACCESSIBILITY STANDARDS FOR CUSTOMER SERVICE POLICY section C; Definitions; Service Animal.

Before making a decision to require a support person, an organization must:

consult with the person with a disability to understand their needs;
consider health or safety reasons based on the available evidence;
determine if there is any other reasonable way to protect the health or safety of the person or others on the premises. In such a situation, you must waive the admission fee or fare for the support person, if one exists.

Effects ACCESSIBILITY STANDARDS FOR CUSTOMER SERVICE POLICY section D; Policy and Procedures for Providing Goods and Services to Persons with Disabilities; Subsection 4; Support Persons.

The feedback process must be accessible and organizations must provide or arrange accessible formats and communication supports, on request.

Effects ACCESSIBILITY STANDARDS FOR CUSTOMER SERVICE POLICY section D; Policy and Procedures for Providing Goods and Services to Persons with Disabilities; Subsection 1; Communication.

Effects ACCESSIBILITY STANDARDS FOR CUSTOMER SERVICE POLICY section E; Feedback Process.

Effects INTEGRATED ACCESSIBILITY STANDARD POLICY section D Information and Communication Standards, subsection 1Feedback.

Effects MULTI-YEAR ACCESSIBILITY PLAN section B Accessibility Standards For Customer Service.