This accessibility policy and plan outlines how the Omni King Edward Hotel (the “Hotel”) complies with Ontario Regulation 191/11 (the “Integrated Accessibility Standards”) under the Accessibility for Ontarians with Disabilities Act, 2005 (“AODA”)
Introduction
The Integrated Accessibility Standards Regulations (“IASR”) under the Accessibility for Ontarians with Disabilities Act, 2005 (the “AODA”) requires that the Hotel establish, implement, maintain and document its accessibility policies and multi-year accessibility plan (the “Accessibility Plan”), which outlines the Hotel’s strategy for preventing and removing barriers for persons with disabilities and to meet our requirements under the IASR.
The Accessibility Plan can be found on the Hotel’s website and is also available in an accessible format upon request. The Accessibility Plan will be reviewed and updated, if applicable, at least once every five years.
Application
The Accessibility Plan applies to all employees and clients of the Hotel, and, where indicated, to any independent contractor representatives working for the company.
Our Commitment
In fulfilling its mission, the Hotel strives to treat all individuals in a manner that allows them to maintain their dignity and independence. The Hotel promotes integration and equal opportunity and is committed to meeting the needs of people with disabilities in a timely manner. The Hotel seeks to achieve this by preventing and removing barriers to accessibility and by meeting accessibility requirements under the AODA. This Accessibility Policy and Multi-Year Accessibility Plan sets out the Hotel’s policy on how it achieves accessibility generally, as well as in employment, information and communications and design of public spaces (built environment).
Under the IASR, the following accessibility strategies set out the requirements that are applicable to the Hotel:
- Workplace Emergency Response Information;
- Training;
- Information and Communication;
- Employment; and
- Design of Public Spaces Standards
Accessibility Standards for Customer Service
The Hotel is committed to providing goods and services in a way that respects the dignity and independence of people with disabilities. The Hotel has as an Accessible Customer Service Policy that addresses the AODA’s specific standards for accessible customer service. A copy of the Accessible Customer Service Policy is available on site at our premises and will be made available to members of the public and third parties upon request.
Accessible Emergency Information
The Hotel is committed to providing all customers and clients with publicly available emergency information in an accessible way upon request.
Integrated Accessibility Standards Regulations (IASR)
The following sets out how the Hotel is committed to complying with the IASR.
1. Workplace Emergency Response Information
Where the Hotel is aware that an employee has a disability and that there is a need for accommodation, individualized workplace emergency response information will be provided to the employee as soon as practicable if such information is necessary given the nature of the employee’s disability.
Actions:
The Hotel will be implementing the following measures to address Emergency Response for employees who have disabilities:
- individualized workplace emergency response information procedures will be developed for employees with disabilities where required;
- where employees disclose a disability and are being accommodated according to their disabilities, workplace emergency response information forms will be prepared where required;
- where required, the Hotel provides assistance to specific disabled employees, with the disabled employees’ prior consent, to help them evacuate the workplace in case of an emergency or disaster. Plans for providing assistance will be set out in individualized emergency plans for the employees;
- individualized emergency plans will be communicated 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, the Hotel will review and assess general workplace emergency response procedures and individualized emergency plans to ensure accessibility issues are addressed.
2. Training
The Hotel is committed to providing training on the requirements of the accessibility standards referred to in the IASR and on the Ontario Human Rights Code, as it pertains to persons with disabilities.
Actions:
In accordance with the IASR, the Hotel:
- determines and ensures that appropriate training on the requirements of the IASR and on the Human Rights Code as it pertains to persons with disabilities, is provided to all employees and persons providing services on behalf of the Hotel in the Province of Ontario, as well as all persons participating in the development and approval of the Hotel’s policies;
- ensures that the training is provided to persons referenced above as soon as practicable;
- keeps and maintains a record of the training provided, including dates the training was provided and number of individuals to whom it was provided; and
- ensures training is provided on any changes to the Hotel’s policies on an ongoing basis.
3. Information and Communication
The Hotel is committed to making company information and communications accessible to persons with disabilities. The Hotel will incorporate new accessibility requirements under the information and communication standards to ensure that its information and communications systems and platforms are accessible and are provided, upon request, in accessible formats that meet the needs of persons with disabilities.
a. Feedback, Accessible Formats and Communication Supports
Actions:
In accordance with the IASR, The Hotel:
- ensures that 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 and in a timely manner;
- more broadly, as a general principle where accessible formats and communication supports for persons with disabilities are requested:
- provides or arranges for the provision of such accessible formats and communication supports;
- consults with the person making the request to determine the suitability of the accessible format or communication support;
- provides or arranges 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, and at a no cost.; and
- notifies the public about the availability of accessible formats and communication supports.
b. Accessible Websites and Web Content
Actions:
In accordance with the IASR, The Hotel recognizes its obligation to provide web content which conforms with the World Wide Consortium Web Content Accessibility Guidelines (WCAG 2.0) Level AA.
Any website controlled by The Hotel shall meet the requirements set out in the IASR.
4. Employment
a. Recruitment
The Hotel is committed to fair and accessible employment recruiting practices that attract and retain employees with disabilities. This includes providing accessibility at all stages of the employment cycle.
Actions:
In accordance with the IASR, the Hotel does the following:
(i) Recruitment General
The Hotel notifies employees and the public of the availability of accommodation for applicants with disabilities in the recruitment process. This includes:
- Ongoing review and, as necessary, modification of existing recruitment policies, procedures and processes;
- specifying that accommodation is available for applicants with disabilities, on the Hotel’s website and on job postings.
(ii) Recruitment, assessment and selection
The Hotel notifies job applicants, when they are individually selected to participate in an assessment or selection process and inform them that accommodations are available upon request in relation to the materials or processes to be used in the assessment/selection process. This includes:
- review and, as necessary, modification of existing recruitment policies, procedures and processes;
- inclusion of availability of accommodation notice as part of the script in the scheduling of an interview and/or assessment; and
- consultation with the applicant and arrangement for provision of suitable accommodations in a manner that takes into account the applicant’s accessibility needs due to the disability where a selected applicant requests accommodation.
(iii) Notice to Successful Applicants
When making offers of employment, the Hotel notifies the successful applicant of its policies for accommodating employees with disabilities. This includes:
- a review and, as necessary, modification of existing recruitment policies, procedures and processes; and
- inclusion of notification of the Hotel’s policies on accommodating employees with disabilities in offer of employment letters.
b. Informing Employees of Supports and General Provision of Accessible Formats and Communications Supports
In accordance with the IASR, the Hotel informs all employees 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. This includes:
- informing current employees and new hires of the Hotel’s policies supporting employees with disabilities, including, but not limited to, policies on the provision of job accommodations that take into account an employee’s needs due to disability;
- providing information as soon as practicable after the new employee begins employment, specifically in the orientation process;
- keeping employees up to date on changes to existing policies on job accommodations with respect to disabilities;
- where an employee with a disability so requests it, the Hotel will provide or arrange for provision of suitable accessible formats and communications supports for:
- information that is needed in order to perform the employee’s job;
- information that is generally available to employees in the workplace; and
- in meeting the obligations to provide the information that is set out above, the Hotel will consult with the requesting employee in determining the suitability of an accessible format or communication support.
c. Documented Individual Accommodation Plans/Return to Work Process
The Hotel incorporates accessibility requirements under the IASR to ensure that barriers in accommodation and return to work processes are eliminated and hotel policies surrounding accommodation and return to work are followed, where applicable.
Actions:
The Hotel’s existing policies include steps that the Hotel takes to accommodate employees with disabilities and to facilitate employees’ return to work after absence due to disability.
The Hotel reviews and assesses the existing policies to ensure that they include a process for the development of documented individual accommodation plans for employees with disabilities, if such plans are required.
In accordance with the provisions of the IASR, the Hotel ensures that the process for the development of documented individual accommodation plans include the following elements:
- information regarding the manner in which the employee requesting accommodation can participate in the development of the plan;
- information regarding the means by which the employee is assessed on an individual basis;
- information regarding the manner in which the Hotel can request an evaluation by an outside medical or other expert, at the Hotel’s expense, to assist the Hotel in determining if and 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;
- steps to protect the privacy of the employee’s personal information;
- information regarding the frequency with which individual accommodation plans will be reviewed and updated and the manner in which this will be done;
- the reasons for a denial where an individual accommodation plan is denied;
- information regarding the means of providing the individual accommodation plan in a format that takes into account the employee’s accessibility needs;
- the following will be included if individual accommodation plans are established:
- any individualized workplace emergency response information that is required;
- any information regarding accessible formats and communication supports that have been provided for or arranged, in order to provide the employee with:
- information that is needed in order to perform the employee’s job;
- information that is generally available to employees in the workplace; and
- identify any other accommodation that is to be provided to the employee.
The Hotel’s return to work process as set out in its existing policies outlines:
- the steps the Hotel will take to facilitate the employee’s return to work after a disability-related absence;
- the development of a written individualized return to work plan for such employees; and
- the use of individual accommodation plans, as discussed above, in the return to work process.
d. Performance Management, Career Development and Redeployment
The Hotel takes 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;
- when providing career development and advancement to employees with disabilities; and
- when redeploying employees with disabilities.
Actions:
In accordance with the IASR, the Hotel:
- reviews, assesses and, as necessary, modifies existing policies, procedures and practices to ensure compliance with the IASR;
- takes the accessibility needs of employees with disabilities and, as applicable, their individualized accommodation plans, into account when:
- assessing performance;
- managing career development and advancement; and
- redeployment is required.
- reviews, assesses and, as necessary, include in performance management workshops, accessibility criteria;
- takes into account the accessibility needs of employees with disabilities when providing career development and advancement to its employees with disabilities, including notification of the ability to provide accommodations on internal job postings; and
- takes into account the accessibility needs of employees with disabilities when redeploying employees, including review and, as necessary, modification of employee transfer checklist.
Design of Public Spaces Standard
While the Hotel has no current plans to engage in new construction or redevelopment which would be captured by the requirements of the IASR concerning the Design of Public Spaces, the Hotel recognizes its obligations under the relevant sections of the Regulation and is committed to incorporating barrier-free design principles into any public spaces that are newly constructed and redeveloped on or after January 1, 2017.
Information and Feedback
For more information on this accessibility plan or to provide feedback, please contact Anna Salvati, Human Resources Director by email at anna.salvati@omnihotels.com or by phone at 416-863-4104
Accessible formats of this document are available free upon request.