Accessibility Policy
Morguard Multi-Year Accessibility Plan and Policy
Last Updated: October 18, 2022
Previous Revision Date: June 29, 2021
Original Effective Date: May 9, 2011
- Introduction and Multi-Year Accessibility Plan
- Principles and Statement of Commitment
- Application
- Limitations
- Definitions
- Assistive Devices
- Communication
- Service Animals
- Support Persons
- Notification of Temporary Disruptions
- Accessibility Training for Staff
- Accessible Emergency Procedures
- Employment Standards
- Accessible Public Spaces
- Feedback Process
- Notice of Availability of Documents
- Questions about this Policy
1.0 INTRODUCTION AND MULTI-YEAR PLAN
Morguard is committed to providing accessible, equitable and barrier-free services to all residents, clients, visitors and employees. This commitment stems not only from our desire meet legislative and policy obligations, but also out of our strong desire to achieve customer service excellence.
The Morguard Multi-Year Accessibility Plan and Policy (the “Policy”) outlines the goals, policies, practices, and procedures adopted by Morguard Corporation and certain of its subsidiaries – including Morguard Investments Limited, Morguard REIT, and Morguard North American Residential REIT (referred to in this Policy as “we,” “our,” “us,” or Morguard, as appropriate) – regarding accessibility for Ontarians with disabilities, in compliance with the Accessibility for Ontarians with Disabilities Act, 2005 (the “AODA”). This Policy, which contains Morguard’s multi-year accessibility plan (the “Plan”), outlines the measures Morguard has taken and will take to identify, remove and prevent barriers to people with disabilities, in compliance with the AODA regulations. This Policy and Plan will be reviewed and updated at least every 5 years.
The purpose of AODA is “to benefit all Ontarians by developing, implementing, and enforcing accessibility standards in order to achieve accessibility for Ontarians with disabilities with respect to goods, services, facilities, accommodation, employment, buildings, structures, and premises on or before January 1, 2025.
Under the AODA, various Accessibility Standards are planned to ensure Ontario is fully accessible to persons with disabilities by 2025. The Accessibility Standard for Customer Services (the “ASCS”), Ontario Regulation 429/07, became effective for Morguard on January 1st, 2012. The Integrated Accessibility Standards (the “IAS”), Ontario Regulation 191/11, has a staggered implementation date, with requirements becoming effective for Morguard between January 1st, 2012, and January 1st 2021. Morguard has created this Accessibility Plan and Policy, which outlines our plans for compliance with the AODA, ASCS, IAS and similar laws. This document is posted on Morguard’s web-site, and is available in alternative formats, upon request.
This Policy addresses the requirements of the AODA, the ASCS and the IAS by speaking to Morguard’s policies, practices, and procedures with respect to accessible customer service in general, and in relation to assistive devices, communication with persons with disabilities, the use of service animals and support persons by persons with disabilities, the provision of notice for disruptions to accessibility services, accessibility training, accessible emergency procedures, our feedback process, accommodation for employees with disabilities, and the provision of notice. This Policy is intended to benefit all persons with disabilities, as defined in the AODA, and strives towards adhering to the principles of dignity, independence, integration, and equality of opportunity for persons with disabilities in the provision of our goods and services. This Policy will be amended, from time to time, to meet ongoing regulatory and legislative requirements and in response to feedback from staff, clients, customers, or the public. Morguard will proactively and continually work to ensure that this Policy meets applicable laws, standards and industry practices, and functions appropriately to identify, prevent and remove accessibility barriers.
Through working towards achieving accessibility for Ontarians with disabilities with respect to goods, services, facilities, accommodation, communications employment, buildings, structures, and premises, Morguard hopes to achieve and maintain its principles and standards.
This Policy is available to the public and to employees on internal and external websites, and in alternative formats upon request.
2.0 PRINCIPLES AND STATEMENT OF COMMITMENT
Morguard is committed to providing timely, inclusive and integrated customer service, in a way that respects the dignity and independence of persons with disabilities, through limiting barriers to access. It is Morguard’s goal that all policies, practices, and procedures contained in this Policy or derived therefrom are consistent with the principles of dignity, independence, equal opportunity, and integration for persons with disabilities.
Morguard strives to provide all employees the opportunity to achieve personal and professional growth, and talent development. Morguard is committed to providing these same opportunities to employees or prospective employees with disabilities through the provision of accommodations to persons with disabilities. Morguard’s mandate is to be an equal opportunity employer.
This Policy applies to all employees who interact with the public or third parties in the provision of our goods and services in Ontario.
Morguard will strive to ensure that any third parties who act on our behalf and interact with the public or third parties will comply with the requirements of the AODA. This may include, but is not necessarily limited to, the use of reasonable efforts to include a general requirement of compliance with all Morguard and government directives and policies as applicable to Morguard and/or the third party, in all relevant third-party service contracts, and the distribution of a copy of this Policy to said third parties.
Third parties are responsible for ensuring that all contractors and sub-contractors they retain comply with this Policy and their own requirements under the AODA.
This Policy only addresses the requirements of the AODA, ASCS and IAS, and not any other legislated requirements regarding persons with disabilities. If this policy conflicts with a provision of any other legislative act or regulation, the provision that provides the highest level of accessibility for persons with disabilities with respect to goods, services, facilities, employment, accommodation, buildings, structures or premises shall prevail.
ASCS principles are fundamental to the Policy, and underlie the policies, practices, and procedures contained therein. These principles include dignity, independence, equality of opportunity, and integration for persons with disabilities.
- Dignity means treatment of persons with disabilities as equally valuable and equally deserving of effective and full service.
- Independence means that persons with disabilities should be allowed to perform tasks at their own pace and in their own way, receiving assistance and accommodation, but free from control or undue influence over their actions.
- Equality of opportunity relates to obtaining, using, and benefiting from our services. It means that persons with disabilities should have no more burdens and no fewer benefits because of the method of providing goods and services.
- Integration means that persons with disabilities should receive the same service, in the same place, and in a similar way as other customers, insofar as this is reasonably possible.
Assistive devices are specialized tools or mechanisms used by or provided to persons with disabilities in order to allow for their full participation in society. Without limiting the foregoing, assistive devices may include mobility devices (e.g. wheelchairs, walkers, canes, crutches etc.), elevators, automatic doors, hearing aids, white canes, teletypewriters, and speech generating devices.
Barriers include all things that prevent persons with disabilities from fully participating in society. These include attitudinal barriers (how people think about and interact with persons with disabilities), structural barriers, communicational barriers, systemic barriers (arising from an organization’s policies, practices, and procedures), and technological barriers.
Disability includes both visible and non-visible disabilities. A disability is:
- Any degree of physical disability, infirmity, malformation or disfigurement that is caused by bodily injury, birth defect or illness, including but not limited to 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.
Service Animal is any animal that is used by a person for reasons relating to his or her disability.
Examples of service animals include dogs used by people who are blind; hearing alert animals for people who are deaf, deafened or hard of hearing; and animals trained to alert an individual to an oncoming seizure and/or lead them to safety.
Support Persons are individuals who help with communication, mobility, personal care, medical needs, or with access to goods or services for persons with disabilities.
Morguard is committed to serving persons with disabilities who use assistive devices to obtain, use, or benefit from our goods and services, in accordance with the ASCS principles. Employees who interact with the public or third parties in the provision of our goods and services will allow persons with disabilities to use their assistive devices to obtain, use, or benefit from our goods and services.
Morguard will make efforts to ensure that any third parties who act on our behalf will allow persons with disabilities to use their assistive devices to obtain, use, or benefit from our goods and services. Where Morguard provides assistive devices for persons with disabilities, Morguard will ensure that the appropriate staff members are aware of their existence, and are able to inform customers on their availability, location, and use.
In aiming to provide accessible goods and services to persons with disabilities, Morguard strives to communicate effectively with persons with disabilities. As such, Morguard and its employees will communicate with persons with disabilities in a way that takes into account their disabilities. Morguard’s employees are expected to uphold the highest standards of customer service, speaking to all customers with courtesy, respect, and patience. They should communicate with customers by speaking clearly and directly to the customer.
Morguard aims to leverage new technology in an effort to achieve accessible communications. As such, Morguard will strive to ensure that any websites or web content under Morguard’s control, that has been published externally since January 1st, 2012 (or that will be published in the future), will conform to the extent required by law with the web accessibility guidelines known as WCAG 2.0 Level AA. Moreover, we will take into account accessibility for persons with disabilities when designing, procuring, or acquiring any self-service kiosks.
Morguard is committed to providing alternative formats and communications supports to persons with disabilities. This commitment includes all communications with the public and extends to, but is not limited to, any system for receiving and responding to feedback from the public. Morguard will provide or arrange for the provision of these accessible formats and communications supports to persons with disabilities upon request, in a timely manner that takes into account the person’s accessibility needs due to disability, at no greater cost than the regular cost charged to anyone else, and through consultation with the person who is requesting access. If it is not technically feasible to convert the information into an accessible format or the technology required to do so is not readily available, Morguard will provide an explanation for why the information cannot be converted, and will provide a summary of the information in an accessible format. Morguard will provide notice to the public of the availability of these alternative formats or communications supports for persons with disabilities.
Morguard strives to ensure that all premises that we own or operate, and that are accessible to the public or third parties, are accessible to persons with disabilities who are accompanied by a service animal. Any person with a disability who is accompanied by a service animal may freely enter any premise owned or operated by Morguard with his or her service animal, provided that the following requirements are met: the premise is accessible to the public or third parties; the person is entitled or permitted to enter the premise; and, the service animals is not otherwise excluded from the premise by law. So long as the requirements of this section are met, at no time will a person accompanied by a service animal be prevented from having access to that service animal while on those premises.
Morguard will ensure that the appropriate staff members are trained on how to interact with persons with disabilities who are accompanied by service animals.
Where a service animal is excluded by law, Morguard and its employees will take all steps as required by the AODA to ensure the availability of some other measure that enables the person with a disability to obtain, use, or benefit from our goods and services.
Morguard will make efforts to ensure that any properties owned by Morguard, but leased to third parties, comply with AODA requirements in regards to service animals. These efforts may include, but are not necessarily limited to, the use of reasonable efforts to include a general requirement in all relevant third party lease contracts to comply with all Morguard and government directives and policies as applicable to Morguard and/or the third party.
Morguard strives to ensure that all premises that we own or operate, and that are accessible to the public or third parties, are accessible to persons with disabilities who are accompanied by support persons. Any person with a disability who is accompanied by a support person may enter any premise owned or operated by Morguard with his or her support person, provided that it is accessible to the public or third parties, and that person is entitled or permitted to enter it. So long as the requirements of this section are met, at no time will a person accompanied by a support person be prevented from having access to that support person while on those premises.
If an amount is payable by a support person for admission to the premises or in connection with his or her presence at the premises, Morguard will ensure that reasonable notice is provided in advance of this fact and the amount payable.
In some circumstances, a manager may deem that it is necessary for a person with a disability to be accompanied by a support person while on a property owned or operated by Morguard. In such cases, a manager may require that a person with a disability be accompanied by an adequate support person, but only in those circumstances that are deemed necessary either to protect the health or safety of the person with a disability, or the health or safety of others on the premises.
Morguard will make efforts to ensure that any properties owned by Morguard, but leased to third parties, comply with AODA requirements in regards to support persons. These efforts may include, but are not necessarily limited to, the use of reasonable efforts to include a general requirement in all relevant third party lease contracts to comply with all Morguard and government directives and policies as applicable to Morguard and/or the third party.
10.0 NOTIFICATION OF TEMPORARY DISRUPTIONS
To the extent reasonably possible, Morguard will provide notice to its customers in the event of a planned or unexpected disruption in facilities and services provided by Morguard and used by persons with disabilities to gain access to our goods and services. In the event of a planned disruption, reasonable notice will be provided, as determined by a manager or an appropriate employee. In the event of an unexpected disruption, notice will be provided as soon as is practicable following the discovery of the disruption. This notice will include information about the reason for the disruption, its anticipated duration, and a description of alternative facilities or services, if any, that are available.
The notice will be provided in such a location or locations so as to achieve effective notice, as reasonably determined by a manager or an appropriate employee. Possible locations include, but are not limited to, conspicuous places on the affected premises and on appropriate web-sites.
11.0 ACCESSIBILITY TRAINING FOR STAFF
Morguard will provide accessibility training to all employees and volunteers, as well as all persons involved in developing Morguard’s policies. Morguard will ensure that all other persons who provide goods, services or facilities on behalf of Morguard are provided with accessibility training. This accessibility training will deal with the Accessibility Standard for Customer Services and its requirements, the Integrated Accessibility Standards and its requirements, and the Human Rights Code as it pertains to persons with disabilities. This training will be appropriate to the duties of the employees, volunteers and other persons. New employees will undertake training as part of their orientation as soon as is practicable. Training will be provided on an ongoing basis in connection with any material changes to this Policy or Morguard’s practices and procedures relating thereto. Morguard will keep a record of the training, including the number of individuals trained and the dates on which they were trained.
The accessibility training includes:
- A review of the purpose of the AODA, the requirements of the ASCS, the requirements of the IAS, and the contents of this Policy;
- The contents of the Human Rights Code as they pertain to persons with disabilities;
- Methods of interaction and communication with persons who have various types of disabilities;
- Methods of interaction with persons with disabilities who use assistive devices or require the assistance of service animals or support persons;
- Instruction on the use of equipment or devices available on our premises or provided by us that may help with the provision of services to a person with a disability; and
- Procedures to undertake when a person with a particular type of disability is having difficulty accessing Morguard’s goods or services.
Morguard will make efforts to ensure that all other persons who provide goods, services, or facilities on our behalf undertake accessibility training, either through training provided by Morguard or through the method set out in Section 3.0 of this Policy.
12.0 ACCESSIBLE EMERGENCY PROCEDURES
Morguard will ensure that any emergency procedures, plans, or public safety information that we make available to the public will be provided in an accessible format and/or with communications supports, upon request, as soon as is practicable following the request. Morguard will also provide notice to the public of the availability of such accessible formats and/or communication supports for these procedures, plans, and information.
When requested to do so, Morguard will strive to provide these procedures, plans, and information in accessible formats and/or with communications supports in a timely manner, at no greater cost than the regular cost charged to anyone else, and through consultation with the person with a disability who has made the request, in order to determine an accommodation that can meet their needs.
If the information cannot be converted into an accessible format, Morguard will provide the individual who has requested the information with the reason why the information cannot be converted, and will offer to provide a summary of the data in an accessible format, as determined through consultation with the person who has made the request.
Morguard will also provide individualized emergency response information as soon as is practicable for every employee who has a disability, so long as Morguard is aware or has been alerted of the need for such accommodations. If, as part of the emergency response plan, the disabled employee requires the assistance of another, Morguard will provide the individualized emergency response information to the person designated to provide assistance, so long as the employee with a disability consents that this can be done.
The individualized emergency response information will be reviewed whenever the employee moves to a different location within the organization; whenever the employee’s accommodation needs are reviewed; and, whenever Morguard reviews our general emergency response policies.
Morguard strives to ensure that our workplace is accessible for persons with disabilities, starting from the recruitment process for prospective employees, and continuing into an employee’s day-to-day work and career development.
All employees will be notified of Morguard’s policies relating to accommodating and supporting employees with disabilities, including, but not limited to, our policies relating to the provision of workplace accommodations that take into account our employees’ accessibility needs due to disability. Employees will be given notice of such policies through the provision of this Policy, along with any supplemental information that Morguard wishes to supply, or through any other method deemed suitable by Morguard given the circumstances. Morguard will provide this information to all new employees as soon as is practicable. Updated information will be provided to Morguard’s employees on an ongoing basis in conjunction with material changes to this Policy.
Recruitment
Morguard will notify its employees and the public that accommodation for job applicants with disabilities is available, upon request, in our recruitment process. This notice will be provided in such a location or locations, such as the Morguard web-site, so as to achieve effective notice, as reasonably determined by a manager or an appropriate employee.
When individual job applicants are selected for an interview or assessment process, they will be notified that accommodations are available, upon request, in relation to the process and any materials to be used. If a request for accommodation is made, Morguard 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.
When making an offer of employment, Morguard will notify the successful applicant of our policies for accommodating employees with disabilities, through providing them with this Section of the Morguard Accessibility Plan and Policy (Section 13.0: Employment Standards), along with any supplemental information that Morguard wishes to supply, or through any other method deemed suitable by Morguard given the circumstances.
Providing Accessibility Support
When requested to do so by an employee with a disability, Morguard will consult with the employee to provide or arrange for the provision of accessible formats and communication supports for information that is necessary for job performance and information that is generally available to employees in the workplace. Morguard will consult with the employee making the request in determining the suitability of an accessible format or communication support.
Individualized Accommodation Plans
Morguard has in place a general written process for the development of documented, individualized accommodation plans for employees with disabilities. The plans will describe any accommodation that is provided, including, but not limited to, accommodations pertaining to accessible formats and communications supports, and individualized workplace emergency response information (as described above), to the extent such accommodations are provided.
The process for the development of individualized accommodation plans includes the following information: the manner in which an employee requesting accommodation can participate in the development of their individualized plan; the manner in which an employee’s needs will be assessed on an individualized basis; the manner in which Morguard may request, at its own expense, an outside medical (or other) expert to assist in determining if and how accommodation can be achieved; the manner in which an employee can request a representative from the workplace in the development of their accommodation plan; the steps to be taken to protect the privacy of the employee’s personal information; the frequency with which and the manner in which the individualized accommodation plan will be reviewed and updated; the manner in which reasons for denial of an individualized accommodation plan will be provided to the employee, if the plan is denied; and, the means of providing the individualized accommodation plan in an accessible format that takes into account the employee’s accessibility needs due to disability. Such policy may be accessed on PolicyLink, or through your manager.
Performance Management, Career Development, and Redeployment
Morguard is committed to conducting employee performance management and career development in a way that is fair and equitable for persons with disabilities. As such, Morguard requires that managers, when conducting performance management, providing career development and advancement, and/or undertaking employee redeployment, must take into account the accessibility needs of employees with disabilities as they are outlined in the employees’ individualized accommodation plans or otherwise documented. Managers must review the employees’ individualized accommodation plans to see if any adjustments or accommodations are required in respect of performance management processes, career development and advancement, or redeployment.
Morguard shall make any relevant new or redeveloped public spaces under its control accessible in accordance with Part IV.1 of the IAS, as well as in keeping with applicable building codes and industry practices. These public spaces include any outdoor paths (such as sidewalks), trails, play spaces and outdoor public eating areas; any service counters and waiting areas; and, any parking areas. Any employee undertaking to build or redevelop any of the above public spaces must first contact their operational vice-president or a senior member of the corporate development department. Morguard shall properly maintain such accessible public spaces and notice shall be given in accordance with Section 10.0 of this Plan and Policy in the event such accessible public space is not available. In the event of unavailability of accessible public space, either planned or unplanned, alternative accessibility should be implemented where reasonably possible.
In connection with Morguard’s commitment to maintaining the highest principles and ethical and legal standards, Morguard welcomes and appreciates feedback from its customers and clients on all of its operations, including its success at achieving accessible customer services for persons with disabilities.
Notice shall be provided of the existence of our feedback process, including where and/or to whom feedback should be directed, as well as the format in which feedback will be accepted. Notice shall be provided in such a way and in such a location as to be effective, as reasonably determined by a manger or an appropriate employee. One or more of the following formats for providing feedback will be possible, as appropriate in the circumstances: in person, by telephone, in writing, and by electronic text. If such methods are not suitable, customers may request another format for providing feedback, and Morguard will use reasonable efforts to accommodate the requested format or find another suitable alternative.
Where possible, as reasonably determined by a manager or an appropriate employee, immediate action will be taken to address complaints. All feedback pertaining to Morguard’s Accessibility Plan and Policy will be directed to Morguard’s Accessibility Plan and Policy Officer, who will consider possible steps for addressing the complaint, including, but not limited to, the modification of this Policy and Morguard’s practices and procedures.
16.0 NOTICE OF AVAILABILITY OF DOCUMENTS
Morguard shall provide notice to its customers that the documents required by the ASCS, IAS and AODA are available upon request. The notice will be provided in such a location or locations so as to achieve effective notice, as reasonably determined by a manager or an appropriate employee. Possible locations include, but are not limited to, conspicuous places on the affected premises and on appropriate web-sites.
Morguard is committed to providing accessibility documentation in an accessible format. If a person with a disability requests a document that Morguard is required to provide by the IAS, ASCS and/or the AODA, we will provide the document, or the information contained therein, in a format that takes into account the person’s disability. Morguard will use reasonable efforts to provide the document, or the information contained therein, in the format requested by a person with a disability. If it is not feasible to convert the requested information into that format, Morguard will make reasonable efforts to accommodate the requestor’s needs in a manner that would make such information accessible.
17.0 QUESTIONS ABOUT THIS POLICY
If anyone has a question about this policy or would like to request a copy of it, please contact Morguard’s Compliance Officer:
Beverley Flynn
T 905.281.5923
E
BFlynn@Morguard.com
Please click here to view
Morguard’s Accessibility Procedures. This document provides guidance to compliance with the Morguard Accessibility Policy by setting out procedures to be followed in generalized scenarios.