Last Updated: December 8, 2023

Introduction and Multi-Year Plan

ISI is committed to providing accessible, equitable and barrier-free services to all clients, visitors and employees. This commitment stems not only from our desire to meet legislative and policy obligations, but also out of our strong desire to achieve customer service excellence.

The ISI Multi-Year Accessibility Plan and Policy (the “Policy”) outlines the goals, policies, practices, and procedures adopted by Insurance Supermarket International Inc. and certain of its subsidiaries – including Insurance Supermarket Inc. and Specialty Life Inc. (referred to in this policy as “we”, “our”, “us”, or ISI, as appropriate) – regarding accessibility for Ontarians with disabilities, in compliance with the Accessibility for Ontarians with Disabilities Act, 2005 (the “AODA”). This Policy, which contains ISI’s multi-year accessibility plan (the “Plan”), outlines the measures ISI has taken and will take to identify, remove and prevent barriers to people with disabilities, in compliance with the AODA regulations. This Policy and Plan will be reviewed and updated at least every five years.

The purpose of AODA is “to benefit all Ontarians by developing, implementing, and enforcing accessibility standards in order to achieve accessibility for Ontarians with disabilities with respect to goods, services, facilities, accommodation, employment, buildings, structures, and premises on or before January 1, 2025.”

This Policy addresses the requirements of the AODA, the Accessibility Standard for Customer Services (the “ASCS”) and The Integrated Accessibility Standards (the “IAS”) by speaking to ISI’s policies, practices, and procedures with respect to accessible customer service in general, and in relation to assistive devices, communication with persons with disabilities, the use of service animals and support persons by persons with disabilities, the provision of notice for disruptions to accessibility services, accessibility training, accessible emergency procedures, our feedback process, accommodation for employees with disabilities, and the provision of notice. This Policy is intended to benefit all persons with disabilities, as defined in the AODA, and strives towards adhering to the principles of dignity, independence, integration, and equality of opportunity for persons with disabilities in the provision of our goods and services. This Policy will be amended, from time to time, to meet ongoing regulatory and legislative requirements and in response to feedback from staff, clients, customers, or the public. ISI will proactively and continually work to ensure that this Policy meets applicable laws, standards and industry practices, and functions appropriately to identify, prevent and remove accessibility barriers.

Through working towards achieving accessibility for Ontarians with disabilities with respect to goods, services, facilities, accommodation, communications, and employment, ISI hopes to achieve and maintain its principles and standards.

This Policy is available to the public and to employees on internal and external websites, and in alternative formats upon request.

Statement of Commitment

ISI is committed to providing alternative formats and communications supports to persons with disabilities. This commitment includes all communications with the public and extends to, but is not limited to, any system for receiving and responding to feedback from the public. ISI will provide or arrange for the provision of these accessible formats and communications supports to persons with disabilities upon request, in a timely manner that takes into account the person’s accessibility needs due to disability, at no greater cost than the regular cost charged to anyone else, and through consultation with the person who is requesting access. If it is not technically feasible to convert the information into an accessible format or the technology required to do so is not readily available, ISI will provide an explanation for why the information cannot be converted, and will provide a summary of the information in an accessible format. ISI will provide notice to the public of the availability of these alternative formats or communications supports for persons with disabilities.

ISI strives to provide all employees with the opportunity to achieve personal and professional growth, and talent development. ISI is committed to providing these same opportunities to employees or prospective employees with disabilities through the provision of accommodations to persons with disabilities. ISI's mandate is to be an equal opportunity employer.

Application

This Policy applies to all employees who interact with the public or third parties in the provision of our goods and services in Ontario.

ISI will strive to ensure that any third parties who act on our behalf and interact with the public or third parties will comply with the requirements of the AODA. This may include, but is not necessarily limited to, the use of reasonable efforts to include a general requirement of compliance with all ISI and government directives and policies as applicable to ISI and/or the third party, in all relevant third-party service contracts, and the distribution of a copy of this Policy to said third parties.

Third parties are responsible for ensuring that all contractors and sub-contractors they retain comply with this Policy and their own requirements under the AODA.

Limitations

This Policy only addresses the requirements of the AODA, ASCS and IAS, and not any other legislated requirements regarding persons with disabilities. If this policy conflicts with a provision of any other legislative act or regulation, the provision that provides the highest level of accessibility for persons with disabilities with respect to goods, services, facilities, employment, and accommodation shall prevail.

Definitions

ASCS principles are fundamental to the Policy, and underlie the policies, practices, and procedures contained therein. These principles include dignity, independence, equality of opportunity, and integration for persons with disabilities.

Dignity means treatment of persons with disabilities as equally valuable and equally deserving of effective and full service.

Independence means that persons with disabilities should be allowed to perform tasks at their own pace and in their own way, receiving assistance and accommodation, but free from control or undue influence over their actions.

Equality of opportunity relates to obtaining, using, and benefiting from our services. It means that persons with disabilities should have no more burdens and no fewer benefits because of the method of providing goods and services.

Integration means that persons with disabilities should receive the same service, in the same place, and in a similar way as other customers, insofar as this is reasonably possible.

Assistive devices are specialized tools or mechanisms used by or provided to persons with disabilities to allow for their full participation in society. Without limiting the foregoing, assistive devices may include mobility devices (e.g., wheelchairs, walkers, canes, crutches etc.), elevators, automatic doors, hearing aids, white canes, teletypewriters, and speech generating devices.

Barriers include all things that prevent persons with disabilities from fully participating in society. These include attitudinal barriers (how people think about and interact with persons with disabilities), structural barriers, communicational barriers, systemic barriers (arising from an organization’s policies, practices, and procedures), and technological barriers.

Disability includes both visible and non-visible disabilities. A disability is:

• Any degree of physical disability, infirmity, malformation or disfigurement that is caused by bodily injury, birth defect or illness, including but not limited to 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 disfunction 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.

Service Animal is any animal that is used by a person for reasons relating to his or her disability.

Examples of service animals include dogs used by people who are blind; hearing alert animals for people who are deaf, deafened or hard of hearing; and animals trained to alert an individual to an oncoming seizure and/or lead them to safety.

Support Persons are individuals who help with communication, mobility, personal care, medical needs, or with access to goods or services for persons with disabilities.

Assistive Devices

ISI is committed to serving persons with disabilities who use assistive devices to obtain, use, or benefit from our goods and services, in accordance with the ASCS principles. Employees who interact with the public or third parties in the provision of our goods and services will allow persons with disabilities to use their assistive devices to obtain, use, or benefit from our goods and services.

ISI will make efforts to ensure that any third parties who act on our behalf will allow persons with disabilities to use their assistive devices to obtain, use, or benefit from our goods and services. Where ISI provides assistive devices for persons with disabilities, ISI will ensure that the appropriate staff members are aware of their existence, and are able to inform customers on their availability, location and use.

Communication

In aiming to provide accessible goods and services to persons with disabilities, ISI strives to communicate effectively with persons with disabilities. As such, ISI and its employees will communicate with persons with disabilities in a way that takes into account their disabilities. ISI’s employees are expected to uphold the highest standards of customer service, speaking to all customers with courtesy, respect and patience. They should communicate with customers by speaking clearly and directly to the customer.

ISI aims to leverage new technology in an effort to achieve accessible communications. As such, ISI will strive to ensure that any websites or web content under ISI’s control, that has been or will be published externally, will conform to the extent required by law with the web accessibility guidelines known as WCAG 2.0 Level AA. Moreover, we will take into account accessibility for persons with disabilities when designing, procuring, or acquiring any self-service kiosks.

ISI is committed to providing alternative formats and communications supports to persons with disabilities. This commitment includes all communications with the public and extends to, but is not limited to, any system for receiving and responding to feedback from the public. ISI will provide or arrange for the provision of these accessible formats and communications supports to persons with disabilities upon request, in a timely manner that takes into account the person’s accessibility needs due to disability, at no greater cost than the regular cost charged to anyone else, and through consultation with the person who is requesting access. If it is not technically feasible to convert the information into an accessible format or the technology required to do so is not readily available, ISI will provide an explanation for why the information cannot be converted, and will provide a summary of the information in an accessible format. ISI will provide notice to the public of the availability of these alternative formats or communications supports for persons with disabilities.

Service Animals

Persons with a disability who are accompanied by a guide dog or other service animal will generally be permitted to enter the parts of the premises that are open to the public or other third parties with the guide dog or other service animal, as applicable, and keep the animal with them. In the rare occurrence that a service animal’s access may be excluded by law, ISI will make reasonable efforts to arrange alternative way for the individual to obtain, use, or benefit from ISI’s products and services.

The person with a disability will be responsible for the care and control of the guide dog or other service animal at all times.

Support Persons

A person with a disability who is accompanied by a support person will be permitted to enter ISI’s premises that is open to the public or other third parties with their support person.

A person with a disability who is accompanied by a support person will not be prevented from having access to his or her support person while on ISI’s premises unless the health and safety of the person with a disability or of others on the premises would be negatively impacted.

Given the nature of information that may be discussed in the presence of a support person accompanying or assisting an individual with a disability, ISI may require that the person with a disability give their consent to ISI to discuss confidential information in the presence of the support person.

Notification of Temporary Disruptions

ISI will notify customers in the event of planned or unexpected disruption in the facilities or services used by persons with disabilities. 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 that are available.

The notice will be placed at all public entrances and reception counters on our premises. Depending on the nature of the disruption, notice will also be provided on outgoing telephone recordings and/or on Company websites.

Accessibility Training for Staff

ISI will provide accessibility training to all employees as well as persons involved in developing ISI’s policies. ISI will ensure that all other persons who provide goods, services or facilities on behalf of ISI are provided with accessibility training. This accessibility training will deal with the Accessibility Standard for Customer Services and its requirements, the Integrated Accessibility Standards and its requirement, and the Human Rights Code as it pertains to persons with disabilities. This training will be appropriate to the duties of the employees and other persons. New employees will undertake training as part of their orientation as soon as is practicable. Training will be provided on an ongoing basis in connection with any material changes to this Policy or ISI’s practices and procedures relating thereto. ISI will keep a record of the training, including the number of individuals trained and the dates on which they were trained.

The accessibility training includes:

• A review of the purpose of the AODA, the requirements of the ASCS, the requirements of the IAS, and the contents of this Policy;

• The contents of the Human Rights Code as they pertain to persons with disabilities;

• Methods of interaction with persons with disabilities who use assistive devices or require the assistance of service animals or support persons;

• Instruction on the use of equipment or devices available on our premises or provided by us that may help with the provision of services to a person with a disability; and

• Procedures to undertake when a person with a disability is having difficulty accessing ISI’s goods or services.

Accessible Emergency Procedures

ISI will ensure that any emergency procedures, plans, or public safety information that we make available to the public will be provided in an accessible format and/or with communications supports, upon request, as soon as is practicable following the request. ISI will also provide notice to the public of the availability of such accessible formats and/or communication supports for these procedures, plans, and information.

When requested to do so by an employee with a disability, ISI will consult with the employee to provide or arrange for the provision of accessible formats and communication supports for information that is necessary for job performance and information that is generally available to employees in the workplace. ISI will consult with the employee making the request in determining the suitability of an accessible format or communication support.

If the information cannot be converted into an accessible format, ISI will provide the individual who has requested the information with the reason why the information cannot be converted and will offer to provide a summary of the data in an accessible format, as determined through consultation with the person who has made the request.

ISI will also provide individualized emergency response information as soon as is practicable for every employee who has a disability, so long as ISI is aware or has been alerted of the need for such accommodation. If, as part of the emergency response plan, the disabled employee requires the assistance of another, ISI will provide the individualized emergency response information to the person designated to provide assistance, so long as the employee with a disability consents that this can be done.

The individualized emergency response information will be reviewed whenever the employee moves to a difference location within the organization; whenever the employee’s accommodation needs are reviewed; and, whenever ISI reviews our general emergency response policies.

Employment Standards

ISI strives to ensure that our workplace is accessible for persons with disabilities, starting from the recruitment process for prospective employees, and continuing into an employee’s day-to-day work and career development.

All employees will be notified of ISI’s policies regarding accommodating and supporting employees with disabilities, including, but not limited to, our policies relating to the provision of workplace accommodations that take into account our employees’ accessibility needs due to disability. Employees will be given notice of such policies through the provision of this Policy, along with any supplemental information that ISI wishes to supply, or through any other method deemed suitable by ISI given the circumstances. ISI will provide this information to all new employees as soon as is practicable. Updated information will be provided to ISI’s employees on an ongoing basis in conjunction with material changes to this Policy.

Recruitment

ISI will notify its employees and the public that accommodation for job applicants with disabilities is available, upon request, in our recruitment process. This notice will be provided in such a location or locations, such as the ISI website, so as to achieve effective notice, as reasonably determined by a manager or an appropriate employee.

When individual job applicants are selected for an interview or assessment process, they will be notified that accommodations are available, upon request, in relation to the process and any materials to be used. If a request for accommodation is made, ISI will consult with the applicant and provide or arrange for the provision of suitable accommodation in a manner that takes into account the applicant’s accessibility needs due to disability.

When making an offer of employment, ISI will notify the successful applicant of our policies for accommodating employees with disabilities, through providing them with this Section of the ISI Accessibility Plan and Policy (Employment Standards Section), along with any supplemental information that ISI wishes to supply, or through any other method deemed suitable by ISI given the circumstances.

Providing Accessibility Support

When requested to do so by an employee with a disability, ISI will consult with the employee to provide or arrange for the provision of accessible formats and communication supports for information that is necessary for job performance and information that is generally available to employees in the workplace. ISI will consult with the employee making the request in determining the suitability of an accessible format or communication support.

Individualized Accommodation Plans

ISI has in place a general written process for the development of documented, individualized accommodation plans for employees with disabilities. The plans will describe any accommodation that is provided, including, but not limited to, accommodations pertaining to accessible formats and communications supports, and individualized workplace emergency response information (as described above), to the extent such accommodations are provided.

The process for the development of individualized accommodation plans includes the following information: the manner in which an employee requesting accommodation can participate in the development of their individualized plan; the manner in which an employee’s needs will be assessed on an individualized basis; the manner in which ISI may request, at its own expense, an outside medical (or other) expert to assist in determine if and ow accommodation can be achieved; the manner in which an employee can request a representative from the workplace in the development of their accommodation plan; the steps to be taken to protect the privacy of the employee’s personal information; the frequency with which and the manner in which the individualized accommodation plan will be reviewed and updated; the manner in which reasons for denial of an individualized accommodation plan will be provided to the employee, if the plan is denied; and, the means of providing the individualized accommodation plan in an accessible format that takes into account the employee’s accessibility needs due to disability.

Performance Management, Career Development, and Redeployment

ISI is committed to conducting employee performance management and career development in a way that is fair and equitable for persons with disabilities. As such, ISI requires that managers, when conducting performance management, providing career development and advancement, and/or undertaking employee redeployment, must take into account the accessibility needs of employees with disabilities as they are outlined in the employees’ individualized accommodation plans or otherwise documented. Managers must review the employees’ individualized accommodation plans to see if any adjustments or accommodations are required in respect of performance management processes, career development and advancement, or redeployment.

Accessible Public Spaces

Where ISI owns real property that includes public spaces and undertakes to build new structures or make major changes to existing structural features, ISI is committed to meeting the design and accessibility requirements of the Accessibility Legislation within the time frames specified therein. ISI makes reasonable efforts to require that all structural features of ISI’s premises that are intended to facilitate barrier-free access are available for use in the intended manner.

Feedback

To continue to improve our customer service, we welcome your comments about the provision of our goods and services to people with disabilities. We will continue to ensure that our process for receiving and responding to feedback is accessible to persons with disabilities by providing, or arranging for the provision of, accessible formats and communications supports, upon request. Please contact nicky.rua@isi.ca.