Integrated Standards for Accessibility Policy

Introduction & Purpose
This policy is intended to meet the requirements of the Integrated Accessibility Standards, Ontario Regulation 191/11 for the Employment Standard set forth under the Accessibility for Ontarians with Disabilities Act, 2005. This policy applies to the provision of accessible employment services for persons with disabilities in Ontario. All employment services provided by Picton Mahoney Asset Management shall follow the principles of dignity, independence, integration and equal opportunity. Any employees whose place of work is outside of Ontario will follow in accordance with their province’s accessibility standards and regulations.

Definitions
Accessible Formats – Include but are not limited to large print, recorded audio and electronic formats, braille and other formats usable by persons with disabilities.

Communication Supports – Include but are not limited to captioning, alternative and augmentative communication supports, plain language, sign language and other supports that facilitate effective communications.

Disability or Disabilities – Means:

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 coordination, 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 developmental disability
A learning disability, or dysfunction in one or more of the processes involved in understanding or using symbols or spoken language
A mental disorder
An injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997

Performance Management – Activities related to assessing and improving employee performance, productivity and effectiveness with the goal of facilitating employee success.

Redeployment – The reassignment of employees to other departments or jobs within the organization as an alternative to layoff, when a particular job or department has been eliminated by the organization.

Statement of Commitment
Picton Mahoney Asset Management is committed to identifying, eliminating, and preventing accessibility barriers at all stages of the employment life cycle for persons with disabilities. We strive to maintain an accommodating environment by:

Monitoring and complying with legal and regulatory requirements
Administering accessibility training to all employees
Providing information in accessible formats, when requested, in an effective, timely manner
Creating an accessibility plan outlining our strategy to continually provide equal access and opportunity for all individuals interacting with or employed by Picton Mahoney Asset Management

We welcome your feedback on the physical and digital accessibility of Picton Mahoney Asset Management. If you encounter an accessibility barrier or have questions about this policy please let us know:

Phone: 416-955-4108
E-mail: accessibility@pictonmahoney.com
Postal Address:
Picton Mahoney Asset Management
33 Yonge Street
Suite 830
Toronto, ON M5E 1G4

Picton Mahoney Asset Management
1055 Dunsmuir Street
Suite 3370
Vancouver, BCV7X 1L3

Guidelines
In accordance with the Integrated Accessibility Standards, Ontario Regulation 191/11, (the “IASR”) this policy addresses the following:

A. General Requirements

General requirements that apply across the five (5) standards (information and communication, employment, transportation, design of public spaces, and customer service) are outlined as follows.

Establishment of Accessibility Policies and Plans
Picton Mahoney Asset Management will develop, implement and maintain policies governing how it will achieve accessibility through the requirements as stipulated in the Integrated Accessibility Standards, Ontario Regulation 191/11 for the Employment Standard set forth under the Accessibility for Ontarians with Disabilities Act, 2005.

Training Requirements
Picton Mahoney Asset Management will provide training for its employees and volunteers regarding the IASR and the Ontario Human Rights Code as they pertain to individuals with disabilities. Training will also be provided to individuals who are responsible for developing Picton Mahoney Asset Management's policies, and all other persons who provide goods, services or facilities on behalf of Picton Mahoney Asset Management.

Training will include:

A review of this policy as apart of our new hire onboarding
How to interact and communicate with persons with various types of both visible and non-visible disabilities
How to interact with persons with disabilities who use an assistive device or require the assistance of a guide dog, service animal or support person
How to use equipment and/or devices made available on Picton Mahoney Asset Management’s premises to assist persons with disabilities with obtaining, using or benefiting from Picton Mahoney Asset Management’s and services, upon request and as applicable
What to do if a person with a disability is having difficulty accessing Picton Mahoney Asset Management’s premises and/or and services upon request and as applicable

Training and/or updates will be provided on an ongoing basis to new employees and as changes to Picton Mahoney Asset Management's accessibility policies occur, as applicable.

Records
Picton Mahoney Asset Management will maintain records on the training provided, when it was provided and the number of employees that were trained.

B. Recruitment, Assessment and Selection
Picton Mahoney Asset Management will notify job applicants about the availability of accommodation for job applicants who have disabilities. Applicants will be informed that these accommodations are available, upon request, for the interview process and for other candidate selection methods. Where an accommodation is requested, Picton Mahoney Asset Management will consult with the applicant and provide or arrange for suitable accommodation.

Successful applicants will be made aware of Picton Mahoney Asset Management’s policies and supports for accommodating people with disabilities.

C. Accessible Formats and Communication Supports for Employees
Picton Mahoney Asset Management will ensure that employees are aware of our policies for employees with disabilities and any changes to these policies as they occur.

Upon employee request, Picton Mahoney Asset Management will provide or arrange for the provision of accessible formats and communication supports for the following:

Information needed in order to perform his/her job
Information that is generally available to all employees in the workplace

We will consult with the employee making the request to determine the best way to provide the accessible format or communication support. However, we reserve the flexibility to decide on the most appropriate accessible formats or communication supports for employees (based on the needs of the specific employee and our capacity to provide the support).

Picton Mahoney Asset Management will ensure that its new internet websites, including web content, conform to the World Wide Web Consortium Web Content Accessibility Guidelines (“WCAG”). We will also take action to ensure that its new internet websites and web content conform with WCAG 2.0 Level AA, (except where this is impracticable), as outlined by the IASR.

D. Workplace Emergency Response Information
Where required, Picton Mahoney Asset Management will create individual workplace emergency response information for employees with disabilities. This information will take into account the unique challenges created by the individual's disability and the physical nature of the workplace and will be created in consultation with the employee.

In circumstances where the employee requires assistance, we will, with the consent of the employee, provide the workplace emergency response information to those designated by Picton Mahoney Asset Management to provide assistance to the employee (e.g., immediate supervisor, fire warden, etc).
This information will be reviewed when:

The employee moves to a different physical location in the organization
The employee's overall accommodation needs or plans are reviewed

Picton Mahoney Asset Management is committed to reviewing general emergency response policies as applicable.

E. Documented Individual Accommodation Plans
Picton Mahoney Asset Management has developed a written process for documenting individual accommodation plans for employees with disabilities. Please refer to the separate “PMAM Accommodation Plan” which includes:

The ways in which the employee can participate in the development of the plan
The means by which the employee is assessed on an individual basis
The ways that an employer can request an evaluation to determine if accommodation can be achieved, or how it can be achieved
The ways that an employee can request the participation of a representative from the workplace for the creation of the accommodation plan
The steps taken to protect the privacy of the employee's personal information
The frequency with which the individual accommodation plan should be reviewed or updated and how it should be done
The way in which the reasons for the denial of an individual accommodation plan will be provided to the employee
The means of providing the accommodation plan in an accessible format, based on the employee's accessibility needs

The individual accommodation will also:

Include information regarding accessible formats and communication supports upon request
Where needed, include individualized workplace emergency response information; and
Outline all other accommodation provided

F. Customer Service
Core Principles
Picton Mahoney Asset Management is committed to providing an equal opportunity to all of our customers. The objective of this policy is to ensure we meet the requirements of the customer service standard and promote its underlying core principles. We will make every effort to ensure that this policy and related practices and procedures are consistent with the following four core principles:

Dignity: Persons with Disabilities must be treated as valued customers as deserving of service as any other customer
Equality of Opportunity: Persons with Disabilities should be given an equal opportunity to obtain, use and benefit from Picton Mahoney Asset Management’s goods and services
Integration: Wherever possible, persons with Disabilities should benefit from Picton Mahoney Asset Management’s goods and services in the same place and in the same or in a similar manner as any other customer. In circumstances where integration does not serve the needs of persons with Disabilities, goods and services will, to the extent possible, be provided in another way that takes into account the person’s individual needs
Independence: Goods and services must be provided in a way that respects the independence of persons with Disabilities. To this end, Picton Mahoney Asset Management will always be willing to assist persons with Disabilities but will not do so without expressed permission

Communication
Picton Mahoney Asset Management strives to communicate with persons with disabilities in a manner that takes into account the person’s disability. Communication strategies are set out in our accessibility training program.

Assistive Devices
Persons with disabilities are permitted to use their own assistive devices when on Picton Mahoney Asset Management’s premises for the purposes of obtaining, using or benefiting from Picton Mahoney Asset Management’s services.

If there is a physical, technological or other type of barrier that prevents the use of an assistive device on Picton Mahoney Asset Management’s premises, we will make best efforts to remove that barrier. If we are not able to remove the barrier, we will ask the individual with the disability how they can be accommodated, what alternative measures would enable equal access to our services and we will make its best effort to provide the individual with alternative means of assistance.

Employees will receive training on the various types of assistive devices that may be used by persons with disabilities while accessing Picton Mahoney Asset Management’s services.

Accessibility to Picton Mahoney Asset Management Premises
Picton Mahoney Asset Management is committed to equipping its office facilities with services in order to provide persons with disabilities with an equal opportunity to obtain, use and benefit from our services.
Requests for accommodations to our office facilities should be directed to our Accessibility team who can by contacted by:

Phone: 416-955-4108
E-mail: accessibility@pictonmahoney.com
Postal Address:
Picton Mahoney Asset Management
33 Yonge Street
Suite 830
Toronto, ONM5E 1G4

Picton Mahoney Asset Management’s office facilities are managed by 3^rd party realty services. For more information on accessibility of our building premises please contact the Picton Mahoney Accessibility team who can assist with your request and provide you with more details.

Guide Dogs and Service Animals
Persons with disabilities that are accompanied by a guide dog or service animal will be allowed to access Picton Mahoney Asset Management’s premises that are open to the public and keep the animal with him or her unless otherwise excluded by law. If a guide dog or service animal must be excluded from the premises, we will provide the individual with the reasons for the exclusion and explore alternative ways to meet the individual’s needs.
If it is not readily apparent that the animal is a service animal, we may request a letter from a regulated health professional confirming that the person requires the animal for reasons relating to his/her disability.
Employees will receive training on how to interact with persons with disabilities accompanied by a guide dog or service animal.

Support Persons
Persons with disabilities may enter premises owned and/or operated by Picton Mahoney Asset Management with a support person and have unobstructed access to the support person while on the premises.
Picton Mahoney Asset Management may require persons with disabilities to be accompanied by a support person where it is necessary to protect the health or safety of the person with a disability or the health and safety of others on the premises. Before making this decision, we will: (a) consult with the person who has a disability regarding their needs; (b) consider the health and safety reasons based on available evidence; and (c) determine whether there is another reasonable way to protect the health and safety of the person who has a disability or others on the premises.

Employees will receive training on how to interact with persons with disabilities who are accompanied by a support person.

Notice of Temporary Disruptions
We will notify clients if there is a planned or unexpected disruption of facilities or services typically used by persons with disabilities in order to access Picton Mahoney Asset Management’s services. The notice will be posted at the entrance of the affected premises and the internal contact will reach out to Human Resources regarding applicable communications and updates to clients.
The notice will include the following information:

The facility or service that is unavailable;
The anticipated duration of the disruption;
The reason for the disruption; and
Alternative facilities or services, if available.

Documentation Made Available
This policy is made available to any member of the public upon request. This policy will also be posted on our Intranet and in a conspicuous place in the workplace.

G. Performance Management and Career Development and Advancement
Picton Mahoney Asset Management will consider the accessibility needs of employees with disabilities when implementing performance management processes, or when offering career development or advancement opportunities.

Individual accommodation plans will be consulted, as required.

H. Return to Work
Picton Mahoney Asset Management commits to developing and implementing a return to work processes for employees who are absent from work due to a disability and require disability-related accommodation(s) in order to return to work.

The return-to-work process will outline the steps Picton Mahoney Asset Management will take to facilitate the employee's return to work and shall use documented individual accommodation plans.

I. Redeployment
The accessibility needs of employees with disabilities will be taken into account in the event of redeployment.
Individual accommodation plans will be consulted, as required.

J. Review
This policy will be reviewed regularly to ensure that it is reflective of Picton Mahoney Asset Management's current practices as well as legislative requirements.

Accessibility Plan
The Accessibility Plan outlines the steps that Picton Mahoney Asset Management will take to prevent and remove barriers to accessibility, and demonstrates our commitment to meeting the accessibility needs of people with disabilities, in accordance with the Integrated Accessibility Standards, Ontario Regulation 191/11 for the Employment Standard set forth under the Accessibility for Ontarians with Disabilities Act, 2005 .

Subject	Regulation	Action	Status
Establishment of Accessibility Policies	O. Reg. 191/11, s. 3 (1). O. Reg. 191/11, s. 3 (2). O. Reg. 165/16, s. 3 (1).	Policies have been developed, communicated, and are publicly available through the company website.	Completed
Accessibility Plans	O. Reg. 191/11, s. 4 (1).	An accessibility plan has been implemented and documented on the company website. Reviews of the plan will occur at least once every five years.	Completed and ongoing
Training	O. Reg. 191/11, s. 7 (1). O. Reg. 165/16, s. 5 (1). O. Reg. 191/11, s. 7 (2). O. Reg. 191/11, s. 7 (3).	All persons employed with or consulted by Picton Mahoney are required to complete assigned accessibility trainings as soon as practicable. Training records are kept, including completion dates.	Completed and ongoing
Feedback	O. Reg. 191/11, s. 11 (1). O. Reg. 165/16, s. 7.	Feedback processes are accessible to persons with disabilities by providing accessible formats, upon request.	Completed
Accessible Formats and Communication Supports	O. Reg. 191/11, s. 12 (1). O. Reg. 191/11, s. 12 (2). O. Reg. 191/11, s. 12 (3).	Upon request, processes will be established to provide accessible formats and communication supports for persons with disabilities, in a timely manner. Furthermore, Picton Mahoney Asset Management will consult with the requestor to determine a suitable format or communication support.	Completed and ongoing
Accessible Websites and Web Content	O. Reg. 191/11, s. 14 (4).	New internet websites and web content on those sites conform with WCAG 2.0 Level A and WCAG 2.0 Level AA excluding the exemptions set forth by the Government of Ontario.	Completed and ongoing
Recruitment, General	O. Reg. 191/11, s. 22.	All job postings notify employees and the public of accommodation availability in Picton Mahoney Asset Management’s recruitment processes.	Ongoing
Recruitment, Assessment, or Selection Process	O. Reg. 191/11, s. 23 (1). O. Reg. 191/11, s. 23 (2).	All candidates selected to participate in our recruitment and selection process are made aware that accommodations are available by request.	Ongoing
Notice to Successful Applicants	O. Reg. 191/11, s. 24.	Successful candidates are notified of Picton Mahoney Asset Management’s accessibility policies upon joining the firm.	Ongoing
Informing Employees of Supports	O. Reg. 191/11, s. 25 (1). O. Reg. 191/11, s. 25 (2). O. Reg. 191/11, s. 25 (3)	New and current employees are informed of Picton Mahoney Asset Management’s policies used to support employees with disabilities and any changes that occur to these policies as soon as practicable.	Completed and ongoing
Workplace Emergency Response Information	O. Reg. 191/11, s. 27 (1). O. Reg. 191/11, s. 27 (2). O. Reg. 191/11, s. 27 (3).	Picton Mahoney Asset Management is committed to providing individualized workplace emergency response information to employees with disabilities in a timely manner. Should permission be given, this information will also be provided to the person designated to aid the employee with disabilities.	Ongoing
Documented Individual Accommodation Plans	O. Reg. 191/11, s. 28 (1). O. Reg. 191/11, s. 28 (2). O. Reg. 191/11, s. 28 (3).	Picton Mahoney is committed to implementing written processes to develop and document individual accommodation plans for employees with disabilities.	Completed
Return to Work Process	O. Reg. 191/11, s. 29 (1). O. Reg. 191/11, s. 29 (2). O. Reg. 191/11, s. 29 (3).	Picton Mahoney is committed to developing and implementing a return-to-work process for any employees absent from work due to a disability and require a disability-related accommodation to return to work.	Completed and ongoing
Performance Management	O. Reg. 191/11, s. 30 (1). O. Reg. 191/11, s. 30 (2).	Employees with disabilities’ individual accommodation plans are considered during the performance management process.	Completed and ongoing
Career Development and Advancement	O. Reg. 191/11, s. 31 (1). O. Reg. 191/11, s. 31 (2).	When providing career development and advancement, employees with disabilities’ accessibility needs and individual accommodation plans are considered.	Completed and ongoing
Redeployment	O. Reg. 191/11, s. 32 (1).	Picton Mahoney is committed to creating procedures to ensure employees’ accessibility needs and individual accommodation plans are prioritized when redeploying.	Completed and ongoing
Customer Service Standards	O. Reg. 165/16, s. 16.	Picton Mahoney is committed to creating a welcoming environment for all, regardless of ability, by implementing policies, feedback mediums, staff trainings, service animal acceptances and prompt temporary disruption notices, available in accessible formats.	Completed and ongoing