Multi-Year Accessibility Plan
This policy and multi-year accessibility plan outlines CannTrust Inc. (the “Company”) policies and strategy to prevent and remove barriers to address the current and future requirements of Accessibility for Ontarians with Disability Act, 2005 (the “AODA) under the Integrated Accessibility Standards, Ontario Regulation 191/11.
In working towards its goal under this policy and plan, the Company is committed to becoming a barrier free environment, and will endeavor to do the following in accordance with provincial legal requirements:
- Identify barriers,
- Remove identified barriers,
- Prevent barriers,
- Increase awareness of accessibility initiatives at all levels of our organization,
- Promote compliance policies and procedures with respect to accessibility to our staff, as well as to our customers and consumers, and
- Provide appropriate training to our employees who deal with the public with a view to ensure greater awareness and responsiveness to the needs of those with disabilities.
A barrier is anything that prevents a person with a disability from fully taking part in society because of that disability. Some barriers include:
- Physical barriers
- Architectural barriers
- Information or communication barriers
- Attitudinal barriers
- Technological barriers
- Barriers created by policies or practices.
This policy and plan will be reviewed once every five years. A review will be conducted more frequently in the event of legislative changes or any changes to the work or the workplace that necessitates an earlier review.
Individuals can request a copy of this policy and plan at any time in a format or with communication supports that meets the needs of the individual.
Unless otherwise stated in this policy and plan or in accordance with applicable law, the commitments set out in the plan are being achieved and/or implement and/or planned as of the effective date of this policy.
Statement of Commitment
CannTrust Inc. believes in equal opportunity and is committed to providing a barrier-free environment that allows all people to maintain their independence and dignity. As an organization, we respect and uphold the requirements set forth under the Accessibility for Ontarians with Disabilities Act (2005) and its associated Regulations and strive to meet the needs of individuals with disabilities in a timely and effective manner.
The Company welcomes feedback in relation to this Plan, in the format most convenient to the persons providing feedback. Feedback and/or request for copies of our Accessibility policies, procedures, and Multi-Year Plan can be directed to Human Resources via:
Mail: CannTrust Inc.
Attention: Human Resources
Customer Service Accessibility
The Company complies with the AODA and its regulation. The Company’s goal is to deliver exceptional customer service and it is committed to servicing its customers in a way that respects the dignity and independence of persons with disabilities.
Among the measures that have been implemented by the Company are the following:
- The Company will ensure training is provided to every person who interacts with the public on the Company’s behalf, as well as to those who are involved in the development of The Company’s policies, procedures and practices governing the provision of goods or services to public. This training includes the purpose of standards regarding accessibility set by provincial legislation and related requirements, as well as how to communicate, interact, and support persons with disabilities in ways that take the person’s disability into account. The training will be delivered as soon as practicable after hire and on an ongoing basis in connection changes to the Company’s policies or procedures governing the provisions of gods or services to persons with disabilities.
- Persons with disabilities are permitted to use their own assistive devices to obtain, use or benefit from the Company’s goods and/or services
- Persons accompanied by a service animal are permitted to enter areas of our facilities that are open to the public, except in areas prohibited by law
- Where a person with a disability is accompanied by a support person, both the person with the disability and the support person are provided equal access to our goods and services.
- Notice is provided to the public of any temporary or other disruptions to facilities or service usually used by persons with disabilities, including information about the reason and expected length of disruption with a description of any alternatives available.
- The Company welcomes feedback about how it provides goods/services to persons with disabilities in the manner deemed most convenient to them.
Information and Communication
The Company is committed to making company information and communications accessible to persons with disabilities. The company will incorporate new accessibility requirements under the information and communications standards to ensure that its information and communications systems and platforms are accessible and are provided in accessible formats that meet the needs of persons with disabilities.
Accessible Website and Web Content:
Action Taken and planned actions:
- The Company will ensure development of its digital platform for public websites, information technology infrastructure meet AODA Information and Communication Standards and that partnering vendors have necessary expertise with such technology.
- New or substantially refreshed websites and web content for the Company will confirm to Level A of the Worldwide Web Consortium’s Web Content Accessibility Guidelines (WCAG 2.0). All website will comply with WCAG 2.0 Level AA by 2021
Feedback, Accessible Formats and Communication Supports:
The Company has ensured that:
- Its processes for receiving and responding to feedback are accessible, by providing or arranging for the provision of accessible formats and communication supports, upon requests
- Upon request, the Company will provide or arrange for the provision of accessible formats and communication supports for persons with disabilities, in a timely manner.
- Feedback and requests will be accepted by all employees and will be directed to their Manager or his or her designated, who will respond to the person giving feedback or making the request
- Requesting persons will be consulted as to the suitability of an accessible format or communications support
- Accessible formats and communication supports to make all publicly available information is made accessible to persons with disabilities upon request.
Emergency Procedures, Public Emergency Safety Information
Where the Company is aware that an employee has a disability and that there is a need for accommodation in an emergency situation, individualized workplace emergency response information will be provided to the employee as soon as practicable if such information is necessary give the nature of the employee’s disability.
Action to be taken:
The Company will periodically notify employees of the availability of individualized assistance, and prepare individual plans for employees, in consultation with the employee, who advise of the need for accommodation in emergency situations.
If an employee who receives individualized workplace emergency response information requires assistance and wit the employee’s consent, the Company will provide the workplace emergency response information to the person designated to provide the assistance to the employee in the event of an emergency.
The Company will review the individualized workplace emergency response information that is in place for an employee (a) when the employee moves to a different location in the organization; (b) when the employee’s overall accommodations needs or plans are reviewed: and (c) when the Company reviews its general emergency response policies.
The Company is committed to fair and accessible employment practices that attract and retain employees with disabilities. This includes providing accessibility across all stages of the employment cycle.
Action Taken and Planned Actions:
The Company has integrated accessibility into the Company’s employment-related practices, as follows:
- Review and, as necessary, modify existing recruitment, assessment, and selection procedures and processes
- Notify all job applicants and the public the accommodation is available during the recruitment process on request, by specifying the same in the job posting
- Specify that accommodation is available for applicants with disabilities in recruitment-related materials and during scheduling of interviews
- If an applicant requests accommodation, consult with the applicant and arrange for suitable accommodations that takes into account the applicant’s needs due to disability
- When making offers employment, notify the successful applicant of the Company’s policies for accommodating employees with disabilities; and
- Develop and provide appropriate training to employees responsible for recruitment, assessment, selection and on-boarding to ensure delivery of required actions, and accommodations requests are fulfilled in effective, timely manner
- Review and, as necessary, modify existing orientation and on-boarding processes to ensure new employees are provided information about the Company’s accessibility policies as soon as practicable after employment commences
- Develop and integrate procedure for documenting and updating, as required, documented individual accommodation plans, which will provide for the method(s) by which requesting employees will be assessed and how they can participate in the plan’s development, and the method by which a copy of the plan will be provided to the employee in a format that takes into account the accessibility needs required
- Develop and provide appropriate training to managers and employees responsible for supporting the individualized accommodation plan process, and a training schedule that will ensure the process is upheld in a continual basis
Return to work from Disability-Related Leaves
- Review and, as necessary, modify and document existing return to work processes for employees who have been absent from work due to a disability and require accommodation in order to return to work
- Ensure documented individual accommodation plans comprise part of the return to work process
- Develop and provide appropriate training to managers and other employees responsible for supporting the return to work process for employees who require accommodation in order to return to work, and any ongoing training required to ensure the continual execution of the return to work process
Performance Management, Career Development and Redeployment
- Review and, as necessary, modify existing performance management, career development, and redeployment processes to ensure that the accessibility needs and individual accommodation plans of employees with disabilities are taken into account
- Develop and provide appropriate training to mangers and other employees responsible for supporting or impacting performance management, career development and advancement, and redeployment processes. Schedule training as necessary to ensure continual compliance with the process.
In accordance with the Design of Public Spaces Standard, the Company will ensure that if it is constructing a new development with respect to a public space or redeveloping a public space (this does not include maintenance), such as a parking lot or service counter, it will comply with its obligation relating to accessible public spaces.
The Company will also ensure compliance with any Ontario Building Code requirements related to accessibility.
The Company is committed to implementing a process to ensure that all employees, volunteers, third-party contractors who provide goods, services and facilities on the Company’s behalf, and persons participating in the development and approval of CannTrust’s polices, are provided with appropriate training on the requirements of the AODA and on the Ontario Human Rights Code as it pertains to the persons with disabilities, and are provided with such training as soon as practicable.
Action Taken and Planned Actions:
The Company, has delivered, implemented and continually refreshes training to ensure that all employees and those who provide services on the Company’s behalf on the standards set by provincial legislation regarding accessibility as well as any aspects of local human rights legislation relating to persons with disabilities.
- Developed and implemented appropriate training materials
- Delivered training was provided before or as soon as possible after the trainee commences duties and whenever the Company alters its policies and practices regarding accessibility
- Kept and maintains a record of the training provided, including the dates that the training was provided and the number of individuals to whom it was provided
- Ensuring that training is provided on any changes to the prescribed policies on an ongoing basis.
Review and Update
We will review and update this policy at least once every five (5) years.