Reviewed September 2023
Pallett Valo LLP (the “firm” or “we”) has established a multi-year accessibility plan which outlines the firm’s commitment and strategy to improve opportunities for persons with disabilities.
This accessibility plan has been developed in accordance with the requirements of the Accessibility for Ontarians with Disabilities Act, 2005 (the “AODA”) and O.Reg. 191/11 the Integrated Accessibility Standards (the “IASR”). The goal of the plan is to be compliant with all related legislation but more importantly to prevent and/or remove barriers for persons with disabilities.
We will review this plan in consultation with employees and persons with disabilities at least once every 5 years. We will use independent consultants specializing in this area to review our plan from time to time. We have and will continue to conduct accessibility audits with third-party providers who specialize in accessibility for persons with disabilities.
General Requirements
Establishment of Accessibility Policies:
We have developed and implemented accessibility policies. We have established a process to regularly review these policies with all firm members during onboarding and each year with our employees.
Training:
We have established a process whereby all employees are trained with respect to AODA regulations and on the Ontario Human Rights Code. Vendors used by the firm must provide proof of their compliance with these requirements as well. The firm has also created a Diversity and Inclusion Committee that meets regularly on all aspects of diversity and inclusion. A standard agenda item for this Committee is specifically dedicated to the enhancement of actions under the AODA and persons with disabilities.
Accessibility Standards for Customer Service:
We strive to maintain an accessible environment for persons with disabilities in the delivery of our services:
- We have created a policy for the delivery of customer service to people with disabilities.
- We have posted our Accessibility Plan on the firm’s website. This plan has been audited by independent auditors from time to time.
- Vendors and contractors to the firm are required to demonstrate to us that they are compliant with the AODA Customer Service Standards training.
- We will accommodate the use of personal assistive devices.
- We will accommodate the use of service animals by people with disabilities.
- Where a person with a disability is accompanied by a support person, we will ensure that they are permitted to enter the premises together and that the person with the disability can access the support person while on our premises.
- When communicating with a person with a disability, or referring to a person with a disability, our employees and third-party contractors/vendors will do so in a manner that respects the person’s disability.
- NOTICE OF TEMPORARY DISRUPTION: We will notify clients and visitors in the event of a planned or unexpected disruption in the facilities or services used by persons with disabilities. This notice will include the reason for the disruption, its anticipated duration, and a description of alternative facilities or services, if available. Such notice may be provided by a variety of methods, depending on the circumstances, and may include postings at reception, and if appropriate, the firm’s website, as well as other means that will ensure that the notice reaches those persons potentially affected by the temporary disruption.
- The Director of Operations, in conjunction with Human Resources, is responsible for reviewing this plan annually and recommending amendments to ensure ongoing compliance with regulated accessibility standards and legislated obligations.
- Any employee who fails to comply with this plan may be subjected to disciplinary action, up to and including dismissal.
Self-Serve Kiosks:
We do not own the kiosk associated with the building we are located in. We will advise the landlord of any issues with the kiosk, parking etc. that persons with disabilities may provide us feedback on.
Design of Public Spaces:
We will meet the Accessibility Standards for the Design of Public Spaces, as applicable, when building or make major modifications to service-related elements. We have and will continue to conduct audits of the design by qualified third-party vendors specializing in Ontario’s accessibility laws and requirements as they relate to space design.
Feedback:
We have created several feedback processes and procedures. We have provided the information on our website, posted signage in our reception area, and incorporated specific questions around accessibility in our client survey process.
Policy Access:
We will notify persons to whom we provide services of our policies by posting information in a conspicuous place on our premises, on the firm’s website or by such method as is reasonable in the circumstances.
When required to give a copy of a document to a person with a disability, we will provide the document or information in a format that takes into account the person’s disability.
Training:
We are committed to training all firm members in Ontario’s accessibility laws and aspects of the Ontario Human Rights Code that relate to persons with disabilities.
We have incorporated that training into our onboarding program which occurs within the first two days of the firm member’s start date.
We also provide ongoing training through our formalized in-house training programs. This training has included specific training on AODA and IASR, the Ontario Human Rights Code and other training such as Unconscious Bias.
Training is provided in respect of any changes to our accessibility policies on an ongoing basis. We maintain records of all of these training sessions.
We have a dedicated page to the AODA and accessibility on the firm’s intranet.
Accessible Formats and Communication:
We are committed to communicating with people with disabilities in ways that take into account their disabilities. When asked, we will provide information about the firm and its services, including public safety information, in accessible formats or with communication supports.
Requests for accessible formats and communications supports will be dealt with promptly. We will consult with the person making the request to determine the suitability of the accessible format or communication support. We will ensure that this commitment is communicated to the public in general, through various means, such as but not limited to our website and seminar materials.
We are reviewing our document creation policies to develop best practices for the creation of accessible documents for not only our clients and the public, but for our firm members as well.
Emergency Procedures:
Upon request, the firm will provide clients and visitors with publicly available emergency information in an accessible format. While emergency response procedures are determined by our landlord, the firm has developed procedures to assist a guest of the firm should there be a need for an emergency response in our office space, should the guest disclose their disability to us at the time of attending our premises.
Accessible Website and Web Content:
The firm has made its website and web content conform with the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0 initially at Level A and it was then increased to Level AA in accordance with the schedule set out in Ontario’s accessibility laws.
We have retained third-party experts who work with persons with disabilities to conduct audits of our website. We have worked through any deficiencies resulting from the audit. We will continue to use independent audits to ensure that our website remains in compliance.
We only use website vendors who satisfy the firm that they are experts in the requirements under Ontario’s accessibility laws, for website design and maintenance.
Training Material – General:
While the Firm is not an educational institution, we believe that to the degree that we do conduct seminars for our clients and the public, we are committed to ensuring that:
- All material we create can be provided in an accessible format upon request.
- Should an accommodation for a disability be required, our invitations outline the process for making such a request.
Employment Standards Requirements
Recruitment, Assessment, Selection and Notification Processes:
Notifications to employees and the public about the availability of accommodation for applicants with disabilities in the firm’s recruitment process have been included on all job postings with notification of same to recruiting vendors that may be used from time to time. Our website content also includes this notification.
During the recruitment process, we will ensure that candidates selected to participate in the interview process are notified that accommodations are available upon request in relation to the materials or processes to be used.
If an accommodation request is made, we will consult with the candidate and provide or arrange for the provision of a suitable accommodation in a manner that takes into account the candidate’s accessibility needs due to his/her disability.
We have included wording in our offer of employment letters, notifying successful applicants of our accommodation policies. These letters are reviewed annually to ensure compliance with Ontario’s accessibility laws.
We will inform our employees of our accommodation policies through various methods which include the following:
- A centralized electronic policy manual database housing the firm’s workplace policies such as accommodation, human rights, diversity and inclusion, telecommuting etc.
- The firm’s intranet has a dedicated section to all items related to Ontario’s accessibility laws and requirements.
- Ongoing training through the firm’s formalized in-house training program.
- Our onboarding program discusses Ontario’s accessibility laws and requirements within the first few days of hire.
- Any changes to policies related to Ontario’s accessibility laws and requirements are posted to both the firm’s intranet (that sends out automated notices of changes) and to the firm’s centralized electronic policy manual database, along with an email notification of such changes.
- Through the communication plans set out by our Diversity and Inclusion Committee as they relate to accommodating persons with disabilities.
Accessible Formats & Communication Supports for Employees:
Where an employee with a disability requests an accommodation, our Human Resources department will consult with that employee and his/her manager to provide or arrange for the provision of accessible formats and communications supports for the information that is needed to perform the employee’s job and information that is generally available for all of our employees. We have in place a formal process for requesting accommodation in general and also specifically as it relates to a disability.
We are currently working on updating best practices for accommodating persons with disabilities when creating our documentation through our document creation policies.
Workplace Emergency Response Information:
As it relates to our employees, we have a policy and process in place to develop and maintain individualized emergency response information with employees with disabilities, if the individualized information is necessary and the firm is aware of the need for accommodation due to the employee’s disability.
We will review annually all internal emergency procedures being created under our Business Continuity Planning and will assess how accessibility concerns can be integrated into our procedures in a manner that protects the dignity of persons with disabilities.
Return to Work Process and Redeployment:
The firm has return to work policies and processes (that included step-by-step documentation) in place for employees who are absent from work due to a disability and who require disability-related accommodations to return to work or if applicable, redeployment.
Performance Management and Career Development & Advancement:
The firm’s Performance Management Process takes into account the accessibility needs of employees with disabilities, as well as individual accommodation plans in the performance evaluation process, succession planning and career development.
Contact Us
This Multi-Year Plan and information about our related practices and procedures will be made available to any member of the public upon request.
Feedback concerning this plan, related policies and practices may be provided in person, by telephone, in writing, electronically or by other available methods. Individuals who provide feedback can expect to hear back from us within seven (7) business days. Complaints will be addressed in accordance with the firm’s regular complaints procedure.
To obtain more information on this plan and related policies in an accessible format, or to provide feedback on the way that the firm provides services to people with disabilities, please contact:
Trevor Silver
Chief Operating Officer
77 City Centre Drive, Suite 300, Mississauga, ON L5B 1M5
Phone: 905 273 3300
Email: tsilver@pallettvalo.com