Accessibility Policy

Purpose

Western Financial Group is committed to ensuring equal access and participation for people with disabilities. We are committed to treating people with disabilities in a way that allows them to maintain their dignity and independence. We believe in integration and we are committed to meeting the needs of people with disabilities in a timely manner. We will do so by removing and preventing barriers to accessibility and meeting our accessibility requirements under the different Provincial accessibility laws and Acts such as the Accessibility for Ontarians with Disabilities Act and the Accessibility for Manitobans Act.

Eligibility

All employees

Definitions

Assistive devices refer to devices that are alternative to standard and are accessible to people with disabilities

Disability is defined as per Section 10 of the Ontario Human Rights Act as;

1. 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 on a wheelchair or other remedial appliance or device,

2. a condition of mental impairment or a developmental disability,

3. a learning disability, or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language,

4. a mental disorder, or

5. an injury or disability for which benefits were claimed or received under an insurance plan

Public spaces include: Service-related elements like service counters, fixed queuing lines and waiting areas

Service Animals are working animals that have been trained to perform tasks that assist disabled people. A customer with a disability that is accompanied by a service animal or guide dog will be allowed access to premises that are open to the public, unless otherwise excluded by law. If a service animal or guide dog is excluded by law, such as a municipal by-law or regulation, Western will try to offer alternative methods to enable the person with a disability to access products and services, when possible.

The customer that is accompanied by a service animal or guide dog is responsible for maintaining care and control of the animal at all times. If a health and safety concern presents itself to a third-party as a result of the use of a service animal or guide dog (for example in the form of a severe allergy), Western will make reasonable efforts to meet the needs of all individuals.

Support Persons means, in relation to a person with a disability, another person who accompanies him or her in order to help with communication, mobility, personal care or medical needs or with access to goods or services. If a customer with a disability is accompanied by a support person, Western will ensure that both persons are allowed to enter the premises together and that the customer is not prevented from having access to the support person.

Western means Western Financial Group Inc. and all its businesses and subsidiaries

Workplace means any place from, or at which, the employee carries out work-related duties at any time and includes circumstances where an employee is carrying out those duties from home, in public, or in a vehicle.

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.

Web Accessibility Solution is an application that audits our site to ensure we are aligning with accessibility standards.

Policy Guidelines & Procedures

Western AODA Statement of Organizational Commitment

Western Multi-Year Accessibility Plan

Assistive devices

All people with disabilities can use their assistive devices.

Training and Education

Western will train all employees and volunteers on accessibility, accessibility laws and aspects of the Human Rights Code that relate to persons with disabilities.

Information and communications

Western will communicate with people with disabilities in ways that consider their disability. When requested, we will provide information about our organization and its services, including public safety information, in accessible formats or with communication supports.

We will also meet internationally recognized Web Content Accessibility Guidelines (WCAG) 2.0 Level AA website requirements in accordance with accessibility laws.

Employment

Western will notify employees, potential hires and the public that accommodations can be made during recruitment and hiring.

We will notify staff that supports are available for those with disabilities. We will put in place a process to develop individual accommodation plans for employees.

Where needed, we will also provide customized emergency information to help an employee with a disability during an emergency.

Our performance management, career development and redeployment processes will take into account the accessibility needs of all employees.

We will meet accessibility laws when building or making major changes to public spaces.

We will put procedures in place to prevent service disruptions to our accessible parts of our public spaces.

Changes to existing policies

We will modify or remove an existing policy that does not respect and promote the dignity and independence of people with disabilities.

Responsibilities

Employees are responsible for:

• Following this policy;

• Reporting actual or suspected violations of this policy;

In addition to the employee responsibilities set out above, Leaders are responsible for:

Providing leadership and knowledge when implementing and enforcing this policy;

The Human Resources team is responsible for:

Providing guidance and advice to leaders related to reports that are raised to them.
Responding to reports in the areas that the team is responsible for, including the conduct of any applicable investigations; and
Ensuring timely closure of investigations.