ACCESSIBLE CUSTOMER SERVICE POLICY

1. PURPOSE AND POLICY STATEMENT

The goal of the Accessibility for Ontarians with Disabilities Act, 2005 (the “Act”) is to create a more accessible Ontario, by identifying, and to the extent possible, preventing, and eliminating barriers experienced by a person with a disability.

The Customer Service Standards adopted under the Integrated Accessibility Standards (“IAS”) were established under the Act to ensure goods, services and facilities are, where at all possible, equally accessible to every member of the public.

Primont (the “Company”) strives to provide an accessible customer service experience. The Company is committed to ensuring its customer service practices respect the dignity and independence of persons with a disability. The Company also strives to ensure a person with a disability is able to access the Company’s goods, services and facilities and receive the same benefit from those goods, services and facilities as any other member of the public.

The objective of this policy (the “Policy”) is to identify and document how the Company seeks to achieve compliance with the requirements of the IAS and how it will continue to work towards improving accessibility in customer service for persons with a disability.

2. APPLICATION OF THE POLICY

The Policy applies to:

(a) Every person who is an employee of, or a volunteer with, the Company.
(b) Every person who participates in developing the Company’s policies
(c) Every other person who provides goods, services or facilities on behalf of the Company.

3. DEFINITIONS

Accessible Format - May include, but is not limited to, large print, recorded audio and electronic format, braille and any other format usable by a person with a disability.

Assistive Device - Any device used to assist a person in performing a particular task or tasks or to aid the person in an activity of daily living.

Communication Support - May include, but is not limited to, captioning, alternative and an augmentative communication support, plain language, sign language and any other support that facilitates effective communication.

Disability – means:

(a) 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.
(b) A condition of mental impairment or a developmental disability.
(c) A learning disability, or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language.
(d) A mental disorder.
(e) An injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997.

Guide Dog - A guide dog as defined in section 1 of the Blind Persons Rights’ Act is a dog trained as a guide for a person who is blind and having qualifications prescribed by the regulations under the Blind Persons’ Rights Act.

Service Animal – means an animal:

(a) That can be readily identified as one that is being used by the person for reasons relating to the person’s disability, as a result of visual indicators such as the vest or harness worn by the animal.

(b) For which the person provides documentation from a member of the following regulated health professionals confirming the person requires the animal for reasons relating to the disability:
• College of Audiologists and Speech-Language Pathologists of Ontario.
• College of Chiropractors of Ontario.
• College of Nurses of Ontario.
• College of Occupational Therapists of Ontario.
• College of Optometrists of Ontario.
• College of Physicians and Surgeons of Ontario.
• College of Physiotherapists of Ontario.
• College of Psychologists of Ontario.
• College of Registered Psychotherapists and Registered Mental Health Therapists of Ontario.

Support Person – A person who accompanies a person with a disability to assist with communication, mobility, personal care or medical needs or with access to goods, services and facilities.

4. COMMUNICATION

The Company strives to communicate with a person with a disability in a manner that takes into account the individual’s disability.

5. ASSISTIVE DEVICES

A person with a disability is permitted, where possible, to use his or her own Assistive Device when on Company premises for the purposes of obtaining, using or benefiting from the Company’s services.

If there is a physical, technological or other type of barrier that prevents the use of an Assistive Device on Company premises, the Company will make efforts to provide an alternative means of assistance to the person with a disability.

6. ACCESSIBILITY AT COMPANY PREMISES

Depending on the location and circumstances, the Company may offer the following facilities and services to enable a person with a disability to obtain, use or benefit from our goods, services and facilities:

• Assistance of a staff person to complete a form;
• Ramp to access facilities; or
• Chair for waiting in line if a person’s disability prevents him or her from standing for lengthy period.

The Company may be able to provide additional facilities and services, upon request.

7. SERVICE ANIMAL

A person with a disability may enter Company premises accompanied by a Guide Dog or Service Animal, and keep the Guide Dog or Service Animal with them, if the public has access to such premises and the Guide Dog or Service Animal is not otherwise excluded by law.

If a Guide Dog or Service Animal must be excluded by law, the Company will provide the explanation for why and explore alternative ways to meet the customer’s needs.

8. SUPPORT PERSON

A person with a disability may enter Company premises with a Support Person and have access to the Support Person while on the premises.

The Company may require a person with a disability to be accompanied by a Support Person when on the premises, but only if, after consulting with the person with a disability and considering the available evidence, the Company determines:

(a) A Support Person is necessary to protect the health or safety of the person with a disability or the health or safety of others on the premises; and
(b) There is no other reasonable way to protect the health or safety of the person with a disability and the health or safety of others on the premises.

9. TRAINING

The Company will provide initial training, and ongoing training as required under the IAS, to all persons to whom this Policy applies.

Training will include:

(a) A review of the purpose of the Act and requirements of the IAS.
(b) A review of the Policy.
(c) How to interact and communicate with persons with various types of disabilities.
(d) How to interact with persons with a disability who use an Assistive Device or require the assistance of a Service Animal or Support Person.
(e) How to use equipment or devices made available on Company premises to assist persons with a disability to obtain, use or benefit from the Company’s goods, services and facilities.
(f) What to do if a person with a disability is having difficulty accessing Company premises and/or services.

The Company will ensure training is provided to all persons to whom this Policy applies as soon as practicable after a new individual assumes a role to which this Policy applies. On-going training will also occur as changes are made to the Policy.

The Company will maintain records of the individuals to whom training is provided and when the training occurred.

10. NOTICE OF TEMPORARY SERVICE DISRUPTION

The Company will notify customers if there is a planned or unexpected disruption of a facility or service a person with a disability may otherwise use to access the Company’s goods, services and facilities. The notice will be posted where it is likely to come to the attention of the Company’s customers, such as at the entrance of the Company’s premises and/or on the home page of the Company’s website.

The notice will include the following information:

(a) The facility or service that is unavailable.
(d) The anticipated duration of the disruption.
(c) The reason for the disruption.
(d) Alternative facilities or services, if available.

11. FEEDBACK PROCEDURE

The Company welcomes and appreciates feedback regarding this Policy and its implementation. Feedback can be provided in the following ways:

(a) By telephone at 905-770-7002.
(b) Electronically, by email to Marsha Jodrell (or designate) at primont@primont.com.

Where the feedback requires the Company to take an action or where a complaint is received, the Company will take the necessary action in response to the feedback or complaint and will document the action taken. This documentation will be available upon request.

The Company will make information about this feedback procedure readily available to the public and shall make it accessible to a person with a disability by providing, or arranging for the provision of Accessible Formats and Communication Supports, on request.

12. DOCUMENTATION TO BE MADE AVAILABLE

This Policy and any other documentation required by the IAS shall be made available to any member of the public upon request.

Notification of the availability of this documentation will be posted at a conspicuous place on the Company’s premises, by posting it on the Company’s website, or by such other method as is reasonable in the circumstances.

13. FORMAT OF DOCUMENTS

The Company will provide documents, or the information contained in documents, required to be provided under the IAS, to a person with a disability in an Accessible Format or with a Communication Support, upon request.

Where a request is so made, the document(s) will be provided in a timely and in a manner that takes into account the person’s accessibility needs due to disability. The document will also be provided at a cost that is no more than the regular cost charged to other persons.

The Company will consult with the person making the request in determining the suitability of an Accessible Format or Communication Support.

14. QUESTIONS ABOUT THIS POLICY

For more information about the Policy please contact:

Marsha Jodrell
905-770-7002
primont@primont.com