Vac Aero Accessibility Policy

1. Application

This Policy applies to all Ontario-based employees at Vac Aero International Inc. (“Vac Aero” or “the Company”), including full-time, part-time, permanent, and fixed-term employees, and to co-op students, clients, and vendors at Vac Aero.

2. Purpose

Vac Aero seeks to create an inclusive environment for our employees, co-op students, clients, vendors, and visitors. This Policy and the responsibilities described in Section 5 apply to the Company’s Ontario operations, with the goal of removing and preventing accessibility barriers.

This Policy is intended to comply with the principles and guidelines set out in the Accessibility for Ontarians with Disabilities Act, 2005 (AODA). Information is included to meet the requirements of the Integrated Accessibility Standards, Ontario Regulation 191/11 (IASR), as well as Vac Aero’s own accessibility and inclusion goals.

To view the official wording of the AODA and the Integrated Accessibility Standards under Ontario Regulation 191/11, visit https://www.ontario.ca/laws/regulation/110191.

By following the standards outlined by the AODA and the procedures included in this Accessibility Policy, Vac Aero will ensure equitable treatment regarding the goods, services, facilities, and employment opportunities we provide.

3. Statement of Commitment to Accessibility

Vac Aero International Inc. (“Vac Aero”) is committed to creating an inclusive and welcoming environment for everyone. We seek to ensure accessibility for all employees, vendors, and visitors who use our goods, services, information, or facilities. We are committed to meeting the requirements of the Accessibility for Ontarians with Disabilities Act, 2005 (AODA), the Ontario Human Rights Code, and all applicable legislation that seeks to prevent discrimination. Vac Aero is committed to treating all people in a way that respects the dignity and independence of others. We continue to work towards integration and equal opportunity by identifying, removing, and preventing barriers to accessibility at Vac Aero.

4. Definitions

The following terms are used in this policy and have the following meanings:

Accessible, Accessibility: products, services, facilities, or environments that can be accessed, used by, or understood by all persons, including those with disabilities

Accessible or Alternate Formats: include but are not limited to large print, recorded audio and electronic formats, braille, and other formats usable by persons with disabilities

Accommodation: efforts to ensure that people with disabilities are not denied jobs or services if they can be accommodated to the point of undue hardship through changes to a company’s policies, practices, training, technology, or other reasonable supports

Assistive Devices: any device used to assist persons with disabilities in carrying out activities or in accessing services. Assistive devices include:

Mobility assistive devices, such as a cane, walker, wheelchair, electronic scooter, or similar device used to assist with mobility;
Communication devices, such as a hearing device, laptop computer, communication board, or similar device used to assist with communication; and
Medical devices, such as a personal oxygen tank or similar device used to assist with medical requirements of a disability.

Barrier: anything that prevents a person with a disability from fully participating in all aspects of society because of their disability, including physical, architectural, information or communications, attitudinal, technological, or systemic policies or practices

Communication Supports: include but are not limited to captioning, alternative or additional communication methods or technology, and the use of plain language, sign language, or other supports that facilitate clear and effective communication

Disability: This policy uses the AODA and Ontario Human Rights Code definition of Disability, which defines a disability as:

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;
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.

This definition includes disabilities that may be visible or not visible and disabilities that may be temporary, permanent, or episodic.

Information: includes data, facts and knowledge that exists in any format, including text, audio, images, digital or print, and that conveys meaning

Kiosk: an interactive electronic terminal, including a point-of-sale device, for public use that allows users to access one or more services or products

Public spaces: As defined by the AODA, public spaces include:

Recreational trails/beach access routes;
Outdoor public eating areas like rest stops or picnic areas;
Outdoor play spaces, like playgrounds in provincial parks and local communities;
Outdoor paths of travel, like sidewalks, ramps, stairs, curb ramps, rest areas and accessible pedestrian signals;
Accessible off-street parking and accessible on-street parking; and
Service-related elements like service counters, fixed queuing lines and waiting areas.

Service Animal: An animal is a service animal for a person with a disability if:

The animal can be readily identified as one that is being used by the person for reasons relating to the person’s disability, because of visual indicators such as an identifying vest or harness worn by the animal;
The person provides documentation confirming that they require the animal for reasons relating to a disability; documentation must identify the animal the person is accompanied by and be from one of the following types of regulated health professionals:
1. audiologist or speech-language pathologist
2. chiropractor
3. nurse
4. occupational therapist
5. optometrist
6. physician or surgeon
7. physiotherapist
8. psychologist
9. psychotherapist or mental health therapist; or
The animal is a trained guide dog, trained as a guide for a person who is blind, having qualifications required by guide dog regulations.

Support Person: in relation to a person with a disability, a support person is any person who accompanies a person with a disability in order to help with communication, mobility, personal care, or medical needs or with access to goods, services, or facilities

Web Content Accessibility Guidelines: refers to the World Wide Web Consortium (W3C) recommendations, the Web Content Accessibility Guidelines (WCAG)

5. Responsibilities

The following Vac Aero responsibilities describe procedures and commitments made by the Company and its Ontario-based employees. All procedures incorporate the following four AODA principles:

Dignity – The Company is committed to respecting and treating every person as valued and deserving of effective and full service as any other customer.
Independence – The Company makes every effort to ensure that persons with disabilities have the freedom and resources available to make choices and decisions without the control or influence of others.
Integration – The Company is committed to making its goods, services, facilities, and employment opportunities available to persons with disabilities in an inclusive and integrated manner wherever possible. If complete integration is not possible, the Company will make every effort to ensure that persons with disabilities receive, use, and benefit from goods and services in an equally effective way.
Equality of Opportunity – The Company will ensure that persons with disabilities are given equal opportunities to obtain, use, and benefit from the goods, services, and employment opportunities it provides.

Information and Communication

Vac Aero encourages open communication throughout the organization. The Company makes every effort to provide information and communication in an accessible format. Persons with disabilities are encouraged to communicate their feedback and their requests for accommodation or information in an alternate format if needed.

Information

Vac Aero will provide information about the Company and its services, including public safety information, in accessible formats or with communication supports, upon request.

The Company will meet internationally recognized Web Content Accessibility Guidelines (WCAG) 2.0 Level AA website requirements as required by the AODA, for any web content that Vac Aero controls or manages.

Vac Aero’s Statement of Commitment to Accessibility and accompanying contact information will be posted in our facility reception area, employee bulletin boards in main gathering areas, and on our Vac Aero Accessibility page.

Communication

Vac Aero is committed to communicating with persons with disabilities in ways that take into consideration their disability and any individual needs or requirements. To ensure communication is as accessible and inclusive as possible, the Company is committed to the following:

Training employees in how to interact and communicate with persons with disabilities guided by the principles of dignity, independence, and equality in a timely manner;
Considering the person’s accessibility needs and providing services at no additional cost to that charged to other customers;
Consulting with persons with disabilities regarding how to communicate with them to ensure their needs are met in a respectful, considerate manner;
Not making assumptions or generalizations about individual needs and consulting with individuals to understand their unique needs and circumstances;
Considering and using appropriate language when communicating (e.g., plain language that is easily understood);
Considering and using appropriate method of communication and meeting individual requests for alternate format wherever possible (e.g., phone, email, large print, audio formats); and
Using appropriate assistive devices or services when required (e.g., amplifying devices, magnifying devices, teletypewriters (TTY), sign language interpreter, etc.).

Training

Vac Aero will provide AODA and accessibility training as required under legislation. This training will include, at minimum:

The purpose and principles of the Accessibility for Ontarians with Disabilities Act and any applicable accessibility legislation;
An overview of the requirements of the AODA’s Customer Service standard;
An overview of Vac Aero’s Accessibility Policy and related procedures;
Information on how to interact with persons with disabilities;
Information on how to interact with people who use an assistive device or require the assistance of a service animal or support person;
Information on what to do if a person with a disability is having difficulty accessing Vac Aero’s services, goods, or facilities;
Role-specific responsibilities of the AODA standards related to individual departments; and
Applicable Human Rights Code content, as it relates to persons with disabilities.

This training will be provided by Human Resources or designated managers:

During the onboarding period for new employees;
When changes are made to the AODA or other applicable accessibility or human rights legislation;
When changes are made to Vac Aero’s accessibility policies or procedures; and
Made available when requested or required as refresher training.

The Company will also ensure that those who are involved in the development and approval of accessibility-related policies, practices, and procedures are trained on the AODA and Ontario Human Rights Code content that relates to persons with disabilities.

A record of training provided will be maintained by Human Resources and will include the date of training and the names of the participants in attendance.

Emergency or Evacuation Support for on-site visitors

All Vac Aero facility visitors are requested to notify the person they are meeting with (or the facility receptionist) if they might require accommodation or support during a meeting or during an emergency or evacuation situation while visiting Vac Aero facilities.

Receptionists and other employees are trained on how to arrange accommodations for any emergency or evacuation support requests, as well as requests for information in alternate formats.

Accessible or Alternate Formats and Communication Supports

Upon request, Vac Aero will provide or arrange for the provision of accessible or alternate formats and communication supports for persons with disabilities, in a timely manner and at no additional cost to the individual. The Company will take into account the person’s accessibility needs when responding to individual requests.

If Vac Aero determines information or communications cannot be provided in the format requested, the Company will provide the individual making the request with an explanation. For example, Vac Aero product information that is produced outside of the Company may not be available in an accessible format. In such cases, when requested and wherever possible, the Company will provide a summary version of the information or communication provided.

The Company will provide accounting information (such as bills, receipts, and invoices) in an alternate format upon request and respond to accounting queries in the manner requested by customers.

Assistive Devices

Vac Aero is committed to serving persons with disabilities who use assistive devices to obtain, use or benefit from the Company’s goods and services. Employees will be trained how to interact with persons with disabilities who use an assistive device.

Wherever possible, Vac Aero will ensure that the access, use and benefit of goods and services are not compromised for persons with disabilities who require assistive devices or who are accompanied by a service animal or support person.

Persons with disabilities shall be permitted to obtain, use, or benefit from goods and services using their own assistive devices. The Company emphasizes that it is the responsibility of the person with disability to ensure that their assistive device is always operated in a safe and controlled manner.

Service Animals

Vac Aero employees will be trained how to interact with persons with disabilities who require the assistance of a guide dog or other service animal.

Service animals include but are not limited to guide dogs and other trained or certified service animals. Service animals can often be identified through visual indicators (for example, a harness or a vest with a certification badge). If a service animal cannot be identified easily, Vac Aero employees may request that a person accompanied by an animal provide documentation from a regulated health professional to confirm that the animal is required for reasons relating to their disability.

Wherever possible, Vac Aero is committed to welcoming persons with disabilities who are accompanied by a service animal on Company premises that are open to the public and other third parties. This excludes areas prohibited by law (for example, in an area where food is being prepared in a commercial kitchen).

Service animals always must remain under the care and control of the person with a disability or an accompanying support person.

Support Persons

The Company is committed to welcoming persons with disabilities who are accompanied by a support person. A support person may be a paid professional, a volunteer, a friend, or a family member. As with all Vac Aero facility visitors, support persons must abide by Company rules and regulations.

Vac Aero employees will be trained how to interact with persons with disabilities who require the assistance of a support person.

Any person with a disability who is accompanied by a support person will be allowed to access Vac Aero premises that are open to the public and other third parties. At no time will a person with a disability who is accompanied by a support person be prevented from having access to their support person while on the premises. Fees will not be charged to support persons for admission to Company premises.

Persons with disabilities shall determine whether a support person is necessary and are required to provide their own support person. They are asked to inform the Company that they will be accompanied by a support person upon entering the premises.

In some cases, a support person may need to sign a confidentiality agreement dependent on the information to be discussed (for example, where confidentiality is essential for the Company or for the customer being served).

Notice of Temporary Disruption of Accessible Services or Facilities

The Company will provide notice in the event of a planned or unexpected disruption in accessible services or accessible facilities usually used by persons with disabilities. This notice will include information about:

What accessible service or facility is disrupted and not currently available;
The reason for the disruption;
The anticipated duration of the disruption;
A description of alternate facilities or services, if available; and
Contact information for questions or follow-up regarding the disruption.

Notice of the disruption of facilities or services will be announced and posted as soon as possible after becoming aware of a disruption.

Notice will be posted at the location of the disruption and at the main Vac Aero facility entrance affected by the disruption.

For lengthy or planned disruptions, notice may also be posted on our website on the Vac Aero Accessibility page.

If a disruption occurs, persons with disabilities will be accommodated using other possible means to deliver the goods and services. Accommodation options will be discussed with those involved and alternate service methods may include:

Using an alternative place and time to provide the goods or services to persons with disabilities;
Conducting the goods or services in another format (such as arranging a consultation or meeting with a client over the phone, online, or in person); or
Using other appropriate measures available to deliver goods and services.

Accessibility Feedback

Feedback regarding accessibility to goods and services and the way Vac Aero employees interact with others is welcome and appreciated. Our goal is to meet the needs of all of our customers and visitors.

Feedback can be provided in person, by phone, by email, or by using a Company Accessibility Feedback Form that is available upon request and on our website on the Vac Aero Accessibility page.

The Company will provide an initial response to accessibility feedback within five business days. Concerns will be addressed according to the Company’s complaint management procedures, directed to the Human Resources and Business Manager and, if necessary, to the Vice-President, Ontario Operations. Where needed, management will work with the person who submitted the feedback to address and resolve complaints.

Establishment of Accessibility Plans

Vac Aero will create and maintain a multi-year accessibility plan outlining its strategy to identify, prevent, and remove barriers and to meet its requirements under the AODA.

The Company will post its accessibility plan on our website on the Vac Aero Accessibility page and will provide the plan in an alternate format upon request.

The Company will review and update its accessibility plan once every five years, in consultation with Vac Aero Human Resources and senior management.

Procuring or Acquiring Self-Service Kiosks

Vac Aero currently does not provide self-service kiosks to members of the public. If the Company plans to procure or acquire self-service kiosks, it will incorporate accessibility criteria and features, except where it is not possible or practical to do so. If it is not possible and practical to incorporate accessibility criteria, the Company will provide an explanation upon request.

Hiring (for applicants)

Vac Aero is committed to being inclusive in our hiring policies. We will notify the public that we will accommodate the needs of persons with disabilities throughout our selection and hiring process. During the selection process, we will include the following paragraph in print and online job postings:

Vac Aero is committed to inclusive recruitment and employment practices. If you have any accommodation requests during the recruitment process, please inform us at accessibility@vacaero.com as soon as possible and we will make every effort to fulfill your request.

When scheduling an interview, we will ask applicants if they have any accommodation requests. If an interview candidate requests an accommodation, we will discuss their request with them and make every effort to fulfill their accommodation requests.

Workplace information (for employees)

Upon request by an employee, the Company will provide workplace information in an accessible or alternate format or offer communication supports when needed. Workplace information includes:

Any information employees need to perform their jobs (for example, job descriptions and manuals), and
General information that is available to all employees at work (for example, the Vac Aero Accessible Employment Policy, company newsletters and memos, and health and safety information).

The Company will work with employees who request accommodations to determine how best to meet their needs and to provide accessible workplace information in a timely manner.

Vac Aero will work with employees with disabilities to develop individual accommodation plans. Where necessary, these plans will also include individual emergency response plans and information to assist during an emergency or evacuation.
The Company will consider any accessibility requests or needs identified by employees during performance management, career development and redeployment processes. This will include checking in with employees to review any current accommodation request arrangements, to confirm or modify arrangements if needed.

Design of Public Spaces

When building or making major changes to public spaces of its facilities, the Company will ensure that accessible designs are incorporated wherever possible.

Communication of Policies, Plans, and Procedures

The Company will inform all employees about policies to support persons with disabilities. Our Accessibility Policy will be reviewed with new employees when they are hired, and updates will be announced when revised.

The current Vac Aero Accessibility Policy, Multi-year Accessibility Plan, and other public accessibility policies and procedures are posted in an accessible format on our website on the Vac Aero Accessibility page.

Changes to existing Company policies

The Company will modify or remove any existing policies that do not respect and promote the dignity and independence of persons with disabilities.

6. Contact Information

Vac Aero International Inc.
accessibility@vacaero.com
905-827-4171, extension 320
1371 Speers Road, Oakville, ON L6L 2X5

Date of Creation:	December 2023
Date Last Reviewed:	December 2023
Scheduled Review Date:	December 2025
Approved by:	Human Resources and Business Manager