Purpose

Torys is committed to creating and maintaining an accessible environment for all firm members, clients and visitors and to meeting the objectives and requirements outlined in the Accessibility for Ontarians with Disabilities Act, 2005 (the “AODA”).

Under the AODA, the Integrated Accessibility Standards Regulation (the “IASR”) establishes standards to address barriers that people with disabilities face in the areas of information and communications, employment, transportation and the design of public spaces. The requirements under the AODA are not a replacement or substitution for the Ontario Human Rights Code and work in conjunction with the Code. The purpose of this policy is to outline Torys’ responsibilities under the AODA and the Integrated Accessibility Standards Regulation.

Policy

The Integrated Accessibility Standards Policy is designed to ensure that the firm is accessible to all firm members, clients and visitors in a way that respects the dignity and independence of people with disabilities. Torys is committed to meeting the needs of people with disabilities and will do so by preventing and removing barriers to accessibility and meeting the requirements under the AODA in a timely manner.

Definitions

“Accessible formats” refers to formats that are alternative to standard print and are accessible to people with disabilities, such as large print, Braille, DVDs and audio formats.

“Communication supports” refers to methods that assist communication and access to information for people with disabilities. Examples include plain language formats, sign language, reading out loud, captioning or using written notes to communicate.

“Disability” as defined under the Ontario Human Rights Code 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 in 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.

“Web Content Accessibility Guidelines (WCAG)” is an international standard for websites and web content that are accessible to people with a wide range of disabilities. More information on WCAG development and website accessibility can be found at the W3C Web Accessibility Initiative.

Multi-Year Accessibility Plan

The Multi-Year Accessibility Plan outlines the steps the firm has taken to prevent and remove barriers to accessibility. The plan is available on the intranet and external website, and will be provided in an accessible format, upon request. As required by law, Torys will review and update the plan every 5 years. The first update to the plan was completed in 2019. In accordance with the requirements of the Act, Torys reports accessibility achievements every 3 years, beginning in 2014.

IASR: Information And Communication Standard

In accordance with the Integrated Accessibility Standards Regulation with respect to Information and Communications, Torys is committed to making firm information and feedback processes accessible to people with disabilities. In order to achieve this:

1. Information will be made available in accessible formats, on request. Alternative formats are available at no additional cost and will be provided in a timely manner.
2. The Accessibility Coordinator will consult with the person making the request to determine the suitability of an accessible format or communication support.
3. The IASR gives flexibility to the Accessibility Coordinator to determine the most appropriate accessible format or communication support, given the needs of the person making the request and the firm’s ability to deliver.
4. If the information cannot be converted, the Accessibility Coordinator will explain why the firm is unable to do so and provide a summary of the content.

Web Content

As required by the IASR, all new web content on the Torys website conforms with WCAG 2.0, Level A, and WCAG 2.0, Level AA. This applies to websites and web content, including web-based applications that Torys controls directly or through a contractual relationship that allows for modification of the product, unless it is not practicable to conform due to the availability of commercial software or tools or both.

Emergency Response Procedures

The firm’s emergency response procedures and the Protect-in-Place program can be found on Torysnet. Torys will provide, upon request, all existing emergency procedures, plans and public safety information in an accessible format or with appropriate communication supports, in a timely manner, on request.

Training

Torys provides training on the Accessible Customer Service Standard and the Integrated Accessibility Standards Regulation requirements to all firm members and employees, including those who work with the public or other third parties or who are involved in the development of customer service policies, practices and procedures. Training will be provided as part of the new hire orientation process and in a way that best suits the duties of the firm member and will be refreshed where there are changes to the policies. Training will take place as soon as is practicable and a record will be maintained of the training provided and to whom.

IASR: Employment Standard

Individual Accommodation Plans

In accordance with the Integrated Accessibility Standards Regulation with respect to Employment, a process has been established for responding to requests for individual accommodation. Torys will provide job accommodations that take into account an employee’s accessibility needs due to disability, where suitable and necessary.

If an employee is absent from work due to disability and requires accommodation consideration in order to return to work, Torys will work with a third party adjudicator, where suitable and necessary, to develop an individual accommodation plan for that employee.

Ontario Human Rights Code

• Under the Ontario Human Rights Code (the “Code”), all employers must meet the accommodations needs of employees with disabilities as fully and promptly as possible, up to the point of undue hardship (which is determined by cost, availability of alternative funding, and health and safety concerns).
• The Code and the AODA work in conjunction with one another. The Code is a complaints-based legislation that addresses discrimination. The Code offers protection of rights, equal opportunity and freedom from discrimination.
• The Code applies to all Ontario organizations regardless of type or size.

Requests for Information and Process for Responding to Feedback

Requests for information in accessible formats or communication supports, and feedback regarding accessibility can be made in person, via telephone, fax, e-mail or in writing to:

Marc Gignac, Accessibility Coordinator
79 Wellington St. W., 30th Floor
Box 270, TD South Tower
Toronto, Ontario M5K 1N2 Canada

P. 416.945.7710 | F. 416.865.7380
E. [email protected]

The Accessibility Coordinator will respond within 7 business days either in writing, in person, by e-mail or telephone acknowledging receipt of feedback and will set out the action to be taken in response to any concerns. The Accessibility Coordinator will provide information in accessible formats, upon request.

Accessible Customer Service Standards Policy

Purpose

Torys strives at all times to provide services in a way that respects the dignity and independence of persons with disabilities. We are committed to ensuring that persons with disabilities receive the same access to and quality of services.

This policy has been developed to address the Accessible Customer Service Standard of the Accessibility for Ontarians with Disabilities Act, 2005 (the “AODA”) and applies in conjunction with and should be read together with other policies that affect the provision of services to our clients and visitors.

Policy

We are committed to providing access to our facilities and delivering excellent service at all times in a way that respects the dignity and independence of all of our clients and visitors.

Our commitment to this is demonstrated in the following areas:

Communication - We will communicate in ways that take into account the needs of persons with disabilities. The firm is equipped with a number of devices to assist those who are hearing and visually impaired. For example, we have a personal voice amplification device to assist the hearing impaired and large viewing screens which magnify text for those that require it.

Assistive devices - We are committed to serving persons with disabilities who use assistive devices to obtain, use or benefit from our services. Our frontline employees who deal directly with clients and visitors are trained and familiar with various assistive devices.

Use of registered service animals and support persons - We welcome clients and visitors who are accompanied by a registered service animal or support person to our premises. At no time will we prevent a client or visitor from having access to their registered service animal or support person while on our premises.

Notice of temporary disruption - We will provide notice to clients and visitors with disabilities in the event of a planned or unexpected disruption to services or office facilities. Where possible, we will post a notification on TorysNet regarding the disruption. The notice will include information about the reason for the disruption, how long the disruption is expected to last, and a description of any alternative facilities or services available (where applicable). While we cannot provide the same guarantee in emergency temporary disruption situations, every reasonable effort will be made to give adequate notice.

Training - Training is provided to all employees on the purpose and requirements of the AODA legislation and specifically on how to:

• interact and communicate with people with various types of disabilities;
• interact with people who use assistive devices or require the assistance of a service animal or a support person;
• use equipment or devices available on-site or otherwise that may help with providing services to people with disabilities; and
• assist a client or visitor who is having difficulty accessing our services.

Training is provided to our employees as part of our new hire orientation process and on an ongoing basis whenever changes are made to relevant policies and procedures. We will maintain records of the training provided, including the dates of the training and the number of (or the names of the) people trained.

Processes

The following processes should be followed, where possible, to ensure that the firm is prepared to receive clients/visitors with disabilities and accommodate their needs in advance of coming to our offices.

Communication and Assistive Devices

• When you become aware of a client/visitor with a disability coming into our offices please select ‘special event set up” in the boardroom booking system and record the details of what equipment, assistive devices or requests that are needed for the client/visitor in the comments section of the boardroom booking request (e.g., personal voice amplification devices, telephone relay service, etc.).
• The boardroom booking staff will advise Boardroom Technical Support, who will set up the necessary equipment in advance of the meeting.
• Boardroom Technical Support will be available at the start of each meeting to ensure the appropriate set up is made and to source any additional requirements.

Requests for documents to be provided in alternate formats (e.g., large print, Braille) should be handled directly by the meeting organizer/host. In the event that a document conversion is required which cannot be performed onsite (e.g., braille) please contact the Meeting Services Supervisor, who will make every reasonable effort to source an external provider to assist in the conversion.

The Meeting Services Supervisor will make every reasonable effort to source out and coordinate any requested equipment and services for clients/visitors with disabilities.

If a telephone relay service is requested for communicating with a client who may be deaf, oral deaf, deafened or hard of hearing, the Client Service Representative will provide the number to the meeting organizer/host to access the service. The Relay Service number is 1-800-855-0511. When this number is called, the operator will then contact the client to begin the conversation.

Notice of Disruption

In the event of a disruption to our services or office facilities, the following steps will be taken:

• Building management will notify the Accessibility Coordinator of any disruption of service which may impact access to our office tower.
• The Accessibility Coordinator will notify the Boardroom Bookings staff of the disruption and advise of an alternative route to access our tower, if one is available. The notice of disruption will also be posted on our intranet, TorysNet.
• The Boardroom Bookings staff will identify if any meetings have been booked with clients/visitors with a disability.
• The Boardroom Bookings staff will then contact the meeting organizer/host and provide the following information:
  
  • Where the disruption is taking place,
  • Provide an alternative route (if possible),
  • Provide information regarding length of delay (if possible),
  • The meeting organizer/host will contact the client/visitor directly and provide the details listed above.

Registered Service Animals

• When you become aware of a client/visitor with a disability coming to our offices with a registered service animal, please select ‘special events set up’ in the boardroom booking system and indicate he/she will be accompanied by a registered service animal in the comments section of the boardroom booking request.
• The Client Service Representatives will have available and offer the client/visitor a water and food bowl for the service animal (food will not be provided).
• The Client Service Representatives will advise clients/visitors with a service animal that the relief zone for the animal is located on the grass area to the west of our building.

Support Persons

• When you become aware of a client/visitor with a disability coming to our offices with a support person, please select ‘special events set up’ in the boardroom booking system and indicate that he/she will be accompanied by a support person and note, if known, whether the support person will be present during the meeting or will require a separate waiting area. Boardroom Bookings staff will arrange a separate waiting area if required.
• If a support person is required to be present during a meeting, the meeting organizer/host will be responsible for issuing a confidentiality agreement to be signed by the support person, if deemed necessary.