Accessibility for Ontarians with Disabilities (AODA)

COMMITMENT:

Silver Hotel Group (“SHG”) 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 Accessibility for Ontarians with Disabilities Act and Ontario’s accessibility laws.

Silver Hotel Group is committed to meeting its current and ongoing obligations under the Ontario Human Rights Code respecting non-discrimination. We understand that obligations under the Accessibility for Ontarians with Disabilities Act, 2005 (AODA) and its accessibility standards do not substitute or limit its obligations under the Ontario Human Rights Code or obligations to people with disabilities under any other law.

We are committed to excellence in serving and providing goods, services or facilities to all customers including people with disabilities.

Our accessible customer service policies are consistent with the principles of independence, dignity, integration, and equality of opportunity for people with disabilities.

PURPOSE:

The Accessibility for Ontarians with Disabilities Act, 2005 (AODA) is a law in Ontario with the purpose of developing, implementing, and mandating accessibility standards to achieve accessibility for persons with disabilities and applies to the provision of goods and services to the public, not the good themselves.

This accessible customer service policy will be available to anyone who requests it and will be provided in an accessible format or with communication support, on request.

SCOPE:

This policy has been developed for Silver Hotel Group’s properties in Ontario and is specifically applies to Team Members, volunteers, and/or contractors who deal with the public or other third parties that act on behalf of the Silver Hotel Group.

DEFINITIONS:

Assistive Device: is a technical aid, communication device or other instrument that is used to maintain or improve the functional abilities of people with disabilities. Personal assistive devices are typically devices that guests bring with them that might assist in hearing, communicating, moving, breathing, remembering and/or reading such as a wheelchair, walker, or a personal oxygen tank.

Barrier: anything that prevents a person with a disability from fully participating in all aspects of society because of the person’s disability, including physical barrier, an architectural barrier, an information or communication barrier, and attitudinal barrier, a technological barrier, a policy, or a practice (“obstacle”).

Disability: the term disability as defined by AODA, 2005 and the Human Rights Code, refers to:

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 coordination, blindness or visual impairment, deafness or hearing impediment, muteness or speech impediment, or physical reliance on a guide dog other animal or on a wheel chair or other medical remedial appliance or device;
2. A condition of mental impairment or a developmental disability or a mental disorder;
3. A learning disability, or dysfunction in one or more of the processes involved in understanding or using symbols or spoken language; or
4. 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: is a highly trained working dog that has been trained at one of the facilities listed in Ontario Regulation 58 under the Blind Person’s Rights Act, to provide mobility safety and increased independence for people who are blind.

Service Animal: as reflected in Ontario Regulation 429/07, an animal is a service animal for a person with a disability if:

1. It is readily apparent that the animal is used by the person for reasons relating to his or her disability; or
2. The person provides a letter from a physician or nurse confirming that the person requires the animal for reasons relating to the disability.

Service Dog: as reflected in Health Protection and Promotion Act, Ontario Regulation 562, a dog other than a guide dog for the blind is a service dog if:

1. It is readily apparent to an average person that the dog functions as a service dog for a person with a medical disability; or
2. The person who requires the dog can provide on request a letter from a physician or nurse confirming that the person requires a service dog.

Support Person: as reflected in Ontario Regulation 429/07, a support person means, in relation to a person with a disability, another person who accompanies them to help with communication, mobility, personal care, medical needs or access to goods and services.

POLICY:

Each SHG Hotel will strive to ensure that its policies, practices, and procedures are consistent with the following core principles as outlined in the AODA.

• Dignity: Goods and services are provided in a manner that is respectful to persons with a disability and does not diminish the person’s importance.
• Independence: Accommodating a person’s disability means respecting their right to do for themselves and to choose the way they wish to receive goods and services.
• Integration: Persons with disabilities can access all goods and services. They may require alternative formats and flexible approaches. It means inclusiveness and full participation. This is a fundamental human right.
• Equal Opportunity: Service provided to persons with disabilities in a way that their opportunity to access goods and services is equal to that given to others.

Communication with Persons with Disabilities

When communicating with a person with a disability, the Company will do so in a manner that considers the person’s disability. SHG commits to providing training on customer service to all current and future team members, volunteers, and contract trainers. This training will include how to interact and communicate with persons with various types of disabilities.

Assistive Devices

Personal assistive devices are permitted in all SHG hotels/offices except when subject to safety. SHG will train its current and future team members and co-op students on the use of various assistive devices available at the hotel. It should be noted that the provision, use and safety of personal assistive devices is the responsibility of the person with the disability.

Guests’ own assistive device(s):

Persons with disabilities may use their own assistive devices as required when accessing goods or services provided by the hotel.

In cases where the assistive device presents a safety concern or where accessibility might be an issue, other measures will be used to ensure the access of goods and services.

For example, open flames and oxygen tanks cannot be near one another. Therefore, the accommodation of a guest with an oxygen tank may involve extinguishing candles and ensuring the guest is seated in a location that would be considered safe for both the guest and other patrons. Or, where elevators are not present and a guest requires assistive devices for the purposes of mobility, the Hotel will make every reasonable effort to provide guest rooms that are easily accessible.

Assistive devices provided by the Hotel:

The following assistive devices are available, on a first come first serve basis and upon request, to assist guests in accessing our goods and services:

• Anti-slip runner mats
• Bath benches
• Hypoallergenic bedding

Guide Dogs, Service Animals and Service Dogs

Persons with a disability who are accompanied by a guide dog, service animal and service dogs may access premises owned and operated by SHG and its affiliated hotels provided the public has access to such premises and the animal is not otherwise excluded by law. If the animal is excluded by law, the hotel will ensure that alternate means are available within reasonable time and location to provide persons with a disability access to the hotel’s goods and services. For example, securing the animal in a safe location and offering the guidance of an employee). “No pet” policies do not apply to guide dogs, service animals and/or service dogs.

Food Service Areas

A guest with a disability that is accompanied by a guide dog or service dog will be allowed access to food service areas that are open to the public unless otherwise excluded by law.  Other types of service animals are not permitted into food service areas due to the Health Protection and Promotion Act, Ontario Regulation 562.

Applicable Laws: The Health Protection and Promotion Acy, Ontario Regulation 562 Section 60, normally does not allow animals in places where food is manufactured, prepared, processed, handled, served, displayed, stored, sold, or offered for sale. It does allow guide dogs and service dogs to go into places where food is served, sold, or offered for sale; however, other types of service animals are not included in this exception.

Dog Owners’ Liability Act, Ontario: If there is a conflict between a provision of this Act or of a regulation under this or any other Act relating to banned breeds (such as pit bulls) and a provision of a by-law passed by a municipality relating to these breeds, the provision that is more restrictive in relation to controls or bans on these breeds prevail.

If it is not readily apparent that an animal is a service animal, a Hotel Representative may ask the person with the service animal to provide verification of the animal’s duty. This can include: a letter from a physician or nurse confirming the person requires the animal relating to the disability; a valid identification card signed by the Attorney General of Ontario; or a certificate of training from a recognized guide dog or service animal training school.

The use, safety and clean-up of the service animal is the responsibility of the person with a disability.

Allergies:

If a health and safety concern present itself, for example in the form of a sever allergy to the animal, the Hotel will make all reasonable efforts to meet the needs of all individuals.

Support Persons

The Hotel welcomes guests who are accompanied by a support person, when the support person has been hired or chosen by the person with a disability to accompany them to assist in accessing goods or services and/or for the purpose of providing support with mobility, personal assistance and/or communication. Individuals who are accompanied by a support person are encouraged to inform relevant Hotel team members of their participation.

The Hotel will ensure that both parties can enter the premises together and that the guest is not prevented from having access to the support person. In situations where confidential information might be discussed, consent will be obtained from the guest, prior to the conversation where confidential information might be discussed.

In certain cases, the Hotel might require a person with a disability to be accompanied by a support person for health and safety reasons.

Before deciding, we must:

1. Consult the person with a disability to understand their needs
2. Consider health or safety reasons based on available evidence
3. Determine if there is no other reasonable way to protect the health and safety of the person or others on the premises.

Fees: The Hotel will provide advance notice if there are fees applied to support persons within the hotel during events, meeting, or other gatherings. This will be discussed in advance, where applicable. Discounts may apply depending on the situation.

For example, if there is a function scheduled in a meeting room and food and beverage is provided, the hotel may apply an additional or reduced fee to cover the costs for the additional person (the support person).

Notice of Disruptions in Service

Service disruptions may occur due to reasons that may or may not be within the control or knowledge of the Hotel. In the event of any temporary disruptions to facilities or services that guests with disabilities rely on to access or use the Hotel’s goods or services, reasonable efforts will be made to provide advanced notice. In some circumstances, such as in the situation of unplanned temporary disruptions, advance notice may not be possible.

The required information necessary for any communication of a temporary disruption may include, but is not limited to:

• The time, date, and location of the disruption;
• Information about the reason for the disruption;
• Anticipated duration of the disruption; and
• Descriptions of alternative facilities or services, if any.

Notification may include:

• Posting notices in conspicuous places including at the point of disruption, at the main entrance and the nearest accessible entrance to the service;
• Contacting guests with reservations;
• Verbally notifying guests when they are making a reservation; or
• By any other method that may be reasonable under the circumstances.

Training

The Hotel shall provide all team members, leaders, volunteers, and contractors that interact with the public or who are involved in developing policies, practices, and procedures.

The training will include the core principles of customer service which include dignity, equity, inclusion, independence, integration, sensitivity, and equality. The required training must include:

• The purpose of the Accessibility of Ontarians with Disabilities Act, 2005 and the requirements of the customer service standard;
• Best practices of communicating and interacting with people with various types of disabilities;
• Bet practices of interacting with people who have assistive devices or require the assistance of a service animal or support person;
• How to learn about the use of various assistive devices;
• What to do if a person has difficulty accessing the Hotel’s goods and services; and
• The Hotel’s policies, practices, procedures relating to the customer service standard.

Team Members will also be trained on an ongoing basis when changes are made to these policies, practices, and procedures.

Training records will be kept indicating the date and training provided, and the number of individuals to whom it was provided.

A training program of varying modules will be implemented which will ensure compliance and meet the needs of our various departments and team members.

Accountabilities & Responsibilities

SHG Leadership:

• Governance of the policy, ensure compliance with legislative requirements, provide resources to hotels for training, support and promote the policy, and promote a culture change for understanding disability and accommodation.

Hotel Leadership

• Participate and facilitate workplace accommodation, enroll in respective training courses, engage in open dialogue, demonstrate respect and sensitivity, raise awareness and understanding of policies and programs, and hold all Team Members accountable.

Hotel Team Members

• Attend in respective training courses, participate, and cooperate with all parties to facilitate workplace accommodation in a respectful and sensitive manner.
• Self-identify if a person with a disability

Corporate/Regional HR Team

• Act as a resource for hotel leadership and Team Members, enroll in respective training courses, and liaise with Airline Hotels Leadership on all matters pertaining to this policy.

Feedback

Feedback about the delivery of services to persons with disabilities is welcomed, as it may identify areas that require change and assist in continuous service improvement. Information about the feedback process will be readily available to all guests and notice of the process will be available. Guests who wish to provide feedback can do so by completing a feedback form or verbally to any of the Hotel’s team members.  Feedback forms along with alternative methods of providing feedback, such as by telephone, in person, in writing, website or by email.

Submitting Feedback:

Guests can submit feedback to:

Jor5dan Gravelle
General Manager
Hotel Victoria Toronto
56 Yonge Street, Toronto Ontario
(416) 363-1666

Notice of Availability and Format of Documents

The Hotel shall notify guests that the documents related to the Accessibility Standards for Customer Service are available upon request and in a format that considers the guest’s disability. Notification will be given by posting the information at a conspicuous place ( i.e., Guest Service desk) owned and operated by the Hotel.

QUESTIONS ABOUT THIS POLICY

The purpose of this policy is to provide a framework through which the Hotel can achieve service excellence for all customers including customers with disabilities. If anyone has a question about the policy, or if the purpose of a policy is not understood, an explanation will be provided by Human Resources.

This policy and its related procedures will be reviewed as required in the event of legislative changes.