Accessibility for Ontarians with Disabilities (AODA)

COMMITMENT

Silver Hotel Group (the “Company” or “SHG”) is committed to the promotion of accessible hotels, compliance with the Accessibility for Ontarians with Disabilities Act (AODA) and meeting the accessibility needs of individuals with a disability in a timely manner.

Purpose:

The purpose of the Integrated Accessibility Standards Policy is to develop, implement and maintain policies which govern how each SHG hotel will achieve accessibility measures as required throughout the AODA.

Scope:

This policy has been created in accordance with the Integrated Accessibility Standards Regulation to address the Company’s accessibility program. The policy provides strategic direction to provide accessibility support to all team members and guests who have a disability.

This policy applies to Silver Hotel Group’s properties in Ontario, specifically to team members, volunteers, and/or contractors who deal with the public or other third parties that act on behalf of Silver Hotel Group.

A. GENERAL REQUIREMENTS

Through the Integrated Accessibility Standards Policy, the Company will develop, implement, and maintain policies which govern how each hotel will achieve accessibility measures as required through the AODA. The Company is committed to meet the accessibility needs of persons with a disability in a timely manner.

i. Multi-Year Accessibility Plan

The Multi-Year Accessibility Plan (the “Plan”) establishes, implements, and maintains, and documents the phased-in strategy to prevent and remove barriers as well as address current and future requirements of the AODA. The Plan will be reviewed by the General Manager and Human Resources Department and approved by the Corporate Director of Operations and the Vice President of Operations at least once every five years.

ii. Training

The Company is committed to ensuring training is provided on the requirements of the Integrated Accessibility Standard to all Team Members, volunteers, and all other persons who provide goods and services on behalf of the Hotel.

Each person will be trained as soon as practicable. New Team Members will receive training during onboarding. Training will also be provided in respect to the changes in the policy on an ongoing basis. Records of the training will be maintained within Payworks and/or an alternative tracking platform. It will also include the date and number of individuals in attendance if it executed in a group setting.

B. INFORMATION & COMMUNICATION

The Company strives to create, provide, and receive information and communications in ways that are accessible to people with disabilities.

i. Feedback

The Company will ensure that feedback processes are accessible to persons with disabilities by providing or arranging for the provision of accessible communications and supports, upon requests. Feedback can be received online (email), in writing, (letter, fax etc.) or verbally (in person, on telephone, etc.) to the Hotel’s General Manager and the Human Resources department at hr@silverhotelgroup.com.

ii. Accessible Formats and Communication Support

Upon request, the Company will provide or arrange for the provision of accessible formats and communication supports for individuals with a disability. The formats will be provided in a timely manner and consider the person’s disability. There will be no additional charge for accessible formats.

The Hotel will consult with the person with the making the request to determine the suitability of an accessible format or communication support.

iii. Emergency Procedures, Plans, or Safety Information

The Company has implemented emergency procedures, plans and public safety information to promote the safety of its guests, team members, volunteers, and contractors. Upon request, public information regarding the Hotel’s emergency procedures will be provided in an accessible format. This information will be made as soon as practicable upon request.

iv. Accessible Websites & Web Content

Silver Hotel Group will ensure that the official website and web content conforms to the Worldwide Consortium Web Content Accessibility Guidelines (WCAG) 2.0, Level A, at minimum. Except where meeting this requirement is not practicable, this conformity applies to websites, web content and web-based applications that are controlled directly or through a contractual relationship that allows for the modification of the product and web content.

New documents, (PDF, Word, PowerPoint etc.) posted to the Company’s website will be presented in an accessible format as defined by the WCAG 2.0 standards. Website users are encouraged to contact the General Manager if they are unable to access a document posted on the website.

C. EMPLOYMENT

Silver Hotel Group is committed to providing equal treatment with respect to employment without discrimination on the prohibited grounds outlined in the Human Rights Code. We have adopted this policy to ensure that our team members are provided with meaningful employment that is ethical and fair, and in compliance with all applicable employment and human rights legislation.

The approach taken by Silver Hotel Group in the provision of reasonable accommodation shall include:

• Personalized plans designed to meet specific needs of individuals;
• Collaborative practices in the creation and implementation of accommodation plans through consultation of all relevant stakeholders, the job applicant and/or team member to be accommodated and medical professionals;
• An approach that ensures confidentiality and dignity.

Employment standards apply to paid Team Members- not volunteers and other non-paid individuals.

i. Recruitment

The Hotel will support the accommodation of team members and job applicants who require workplace accommodation under any of the grounds described in the Human Rights Code. We will work in a consultative manner that involves the Company, the job applicant, team member, and as appropriate, any applicable union representatives, health care professionals and other third parties that are required to assist with he accommodation process, up to the point where it causes undue hardship for the Hotel.

Through the recruitment process, all interested applicants will be notified about the availability of accommodations for those with a disability. A standard statement of commitment will be provided on all Hotel job postings:

“The Silver Hotel Group believes in outstanding hospitality and takes seriously its obligations under the Human Rights Code and the Accessibility for Ontarians with Disabilities Act, 2005. We are committed to respecting the independence and dignity of all persons by providing a barrier-free environment for all guests, colleagues, and job applicants. Accommodations are available upon request for all applicants with a disability throughout the recruitment process. Please contact Human Resources at 1-905-362-9480.

During the recruitment process, applicants selected for the position will be notified that accommodations are available.

“Silver Hotel Group is committed to providing accessible employment practices, in compliance with the Accessibility for Ontarians with Disabilities Act, 2005 (AODA). If you have accommodation requests related to your employment at Silver Hotel Group, please contact the undersigned. As part of your orientation to your role, you will receive training on the AODA and related SHG policies.”

If an applicant requests an accommodation, the Hotel will arrange for a suitable accommodation in a manner that considers the applicant’s accessibility needs.

ii. Return to Work Process

The Company has in place an Early and Safe Return to Work Policy which outlines Silver Hotel Group’s commitment to make every reasonable effort to provide temporary modified or suitable alternative duties to a team member who had been absent from work due to disability.

The Early and Safe Return to Work Policy outlines the steps the Hotel takes to facilitate the return of Team Members who were absent because of their disability. Any team member requesting accommodation must make a request to their Manager or immediate Supervisor. That Manager is responsible for ensuring that a written description of the accommodation is captured on the Individual Accommodation Plan and is used during this process.

In the creation of an accommodation plan and together, in consultation with Human Resources, and where appropriate, healthcare professionals, the accommodation plan shall:

• Identify the need for the accommodation;
• Determine the objectives for performance in the role, and the potential barriers;
• Examine the options for accommodation and select the most appropriate avenue for accommodation;
• Implement the accommodation process;
• Provide training as appropriate; and
• Review and revise based on the feedback.

In the event a Team Member cannot be accommodated in their current position:

In some cases, it will be reasonable to accommodate an individual in another position within the Hotel. The Human Resources Department, working with appropriate Silver Hotel Group officers, the Team Member, and union, if applicable, will attempt to place the Team Member in another available position. This may require the assistance of third parties with specialized expertise.

Where a Team Member is placed in an alternate position, Silver Hotel Group shall ensure that they have the requisite qualifications and skill-sets necessary for success in the position, that they are capable of performing the tasks associated with the position, and that the Team Member agrees that the alternate work is acceptable.

Job Redesign:

If the accommodation requires a substantial change in the position, the Team Member, the Reporting Manager, and Human Resources will work collaboratively to determine the best resolution. This may include but is not limited to adjusting the duties, hours or work, or work location.

Financing the Accommodation:

Where the accommodation required necessitates an investment in materials, equipment or increased budget for the position, requests for financing must be directed to the Hotel’s General Manager.

Undue Hardship:

The Company shall work to provide workplace accommodation up to the point of undue hardship. Undue hardship may occur where it is established that no forms of appropriate accommodation exists, or where the creation of accommodation would cause excessive costs that create undue hardship for the organization, or where the accommodation would create a health and safety hazard.

iii. Performance Management

The Company will consider the accessibility needs of team members with disabilities and the documented Individual Accommodation Plan during all performance management processes.

iv. Career Development and Advancement

The Company will consider the accessibility needs of team members as well as the documented Individual Plan when providing career development and advancement.

v. Accessible Formats and Communication Support for Team Members

The Hotel will inform its team members of policies developed for those with a disability. This information will be provided to new team members as soon as practicable after they begin their employment. Any changes to policies will be communicated through communication channels or through formats that consider the team member’s disability.

vi. Workplace Emergency Response Information

The Hotel will provide individualized workplace emergency response information to team members who have a disability, if the disability is such that the individualized information is necessary, and if the Hotel is aware of the need for accommodation due to the team member’s disability, We will provide this information as soon as practicable after becoming aware of an accommodation request.

Where the team member requires assistance, and following receipt of consent of the team member, the Hotel will provide the workplace emergency response information and accommodation support needs to the person designated by the Hotel to provide assistance to the Team Member in the event of a workplace emergency. We will review the individualized workplace emergency response information if the team member moves to a different location or position within the organization, and when the Team Member’s overall accommodations needs or plans or the Hotel’s general emergency response policies are reviewed or revised.

D. CUSTOMER SERVICE

Customer Service Standards are addressed in the separate Silver Hotel Group AODA- Customer Service Policy.

i. Self-Serving Kiosk

The Company and some select Hotels may offer services through self-service kiosks at this time. If so, the Company will consider accessibility features that could be built into self-service kiosks to best meet the needs of its customers. We will ensure compliance when designing, procuring, or adding self-serve kiosks to fulfill future needs.

E. TRANSPORTATION

While the Company is not primarily in the business of transportation, we periodically provide or arrange for transportation services for guests. Accessible transportation or equivalent services are provided (upon request) for persons with disabilities and is provided at no additional cost. Individuals must contact the Guest Services department or the Event’s Coordinator to request this accommodation.

F. DESIGN OF PUBLIC SPACES

Silver Hotel Group shall incorporate accessibility into public spaces that are newly constructed or redeveloped on and after January 1, 2016. Our Hotels will ensure that existing requirements stated under the Design of Public Spaces Standards (Accessibility Standards for the Built Environment) are followed for accessible parking, and service-related elements. Our hotels shall also provide maintenance and restoration of public spaces, where applicable, by ensuring the Multi-Year Accessibility plan includes procedures for preventative and emergency maintenance of accessible elements in public spaces and procedures for dealing with temporary disruptions when accessible elements required under this section are not in working order.

Modifications to this or Other Policies

Any policy of Silver Hotel Group that does not respect and promote the principles of respect, dignity, independence, integration, and equal opportunity for people with disabilities will be modified or removed. This Integrated Accessibility Standard Policy is available in alternative formats upon request. We will consult with the person making the request to determine the suitability of the format or communication support. We will provide the accessible format in a timely manner, and at no additional cost.

At minimum, this policy will be reviewed annually by Human Resources and the Operations Team. As per the Multi-Year plan, this policy will be reviewed annually by the Advisory Committee once established.. The review process, however, may be affected by AODA Regulations as they are announced. The policy may be reviewed and modified to ensure full compliance with the AODA, 2005.

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.