Requirement

Responsible Individual/Department

Action

Status

Accessibility Policy

Develop, implement and maintain polices governing how Primont achieves or will achieve accessibility through meeting the requirements of the IAS.

Statement of organizational commitment to meeting the accessibility needs of persons with disabilities in a timely manner.

Prepare one or more written documents describing the policies and make the policies publicly available and provide them in an accessible format upon request.

Human Resources

Primont has developed and implemented an “Integrated Accessibility Standards Policy” and will provide training on the Policy. The Policy includes a Statement of Commitment.

Notification about the availability of the Integrated Accessibility Standards Policy is posted on Primont’s website.

Complete and ongoing

Multi-Year Accessibility Plan

Establish, implement, maintain and document a multi-year accessibility plan, which outlines the organization's strategy to

Human Resources

Primont has developed a Multi- Year Accessibility Plan.

Complete and ongoing

prevent and remove barriers and meet its requirements under this Regulation

Post the accessibility plan on the website and provide the plan in an accessible format upon request.

Review and update the accessibility plan at least once every five years.

The Multi-Year Accessibility Plan is posted on Primont’s website.

The Multi-Year Accessibility Plan will be reviewed in 2028 unless an earlier review is required due to amendments to the AODA or the IAS or because of changes to Primont’s policies.

Training

Provide training to all existing employees, volunteers and all persons who participate in the development of AODA Policies.

Training must include:

i. the requirements of the IAS; the Human Rights Code as it pertains to persons with disabilities; and

ii. the AODA Policies as required by the IAS.

Keep a record of the training provided, including the dates on which the training is provided and the number of individuals to whom it is provided.

Ensure that contractors providing goods, services and/or facilities on its behalf have received the training required under the IAS.

Human Resources

Primont will provide training to existing employees, volunteers and any third parties who provide goods, services or facilities on behalf of Primont, as well as all persons who participate in the development of Primont’s policies.

Primont will provide training to new employees as part of the onboarding process.

Human Resources will maintain records of the training provided.

Ongoing

Self-Service Kiosks

Have regard to the accessibility for persons with disabilities when designing, procuring or acquiring self-service kiosks.

Primont will consider the accessibility needs of persons with disabilities when designing, procuring or acquiring a self-service kiosk.

Complete and ongoing

Requirement

Responsible Individual/Department

Action

Status

Emergency Plans, Procedures or Public Safety Information

Provide any emergency plans, procedures or public safety information that it makes available to the public in an Accessible Format or with appropriate Communication Supports, as soon as practicable, upon request.

Human Resources

Primont will prepare emergency plans, procedures or public safety information and makes the information available to the public. Upon request, the information provided will be made accessible through the provision of Accessible Formats and Communication Supports.

Ongoing

Feedback

Ensure that processes for receiving and responding to feedback are accessible to persons with disabilities by providing or arranging for the provision of Accessible Formats and Communications Supports, upon request.

Notify the public that Accessible Formats and Communications Supports are available in respect of its feedback procedures

Human Resources

Accessible formats and communication supports will be provided in respect of Primont’s feedback procedures, upon request.

Notification about the availability of accessible formats and communications supports in respect of any processes for receiving and/or responding to feedback is posted on Primont’s website and is included in its policies.

Complete and ongoing

Accessible Formats and Communication Supports

Upon request, provide or arrange for the provision of Accessible Formats and Communication Supports in order to make its

Human Resources

Upon request, information about Primont’s goods, services and facilities will be

provided in an Accessible

Complete and ongoing

communications or information about the goods, services and/or facilities it offers accessible to persons with disabilities.

Provide Accessible Formats and Communication Supports in a timely manner at a cost that is no more than the regular cost charged to other persons and in a manner that takes account the person’s accessibility needs due to disability.

Consult with the person making the request when determining the suitability of an Accessible Format or Communication Support and notify the public of the availability of same.

Format or with a Communication Support.

Employees will receive training on the obligation to provide this information in an Accessible Format or with a Communication Support.

Notification about the availability of Accessible Formats and Communication Supports is provided on Primont’s website and is included in its policies.

Accessible Websites and Web Content

Ensure that, where practicable, a New Internet Website and web content on such site(s) conforms with WCAG 2.0 Level A.

By January 1, 2021 ensure that, where practicable, any website or content on that site(s) published after January 1, 2012 conforms with WCAG 2.0 Level AA to the extent required by the IAS.

Human Resources

Primont is in the process of updating its website to be compliant with WCAG 2.0 Level AA to the extent required by the IAS.

Ongoing

Requirement

Responsible Individual/Department

Action

Status

Recruitment

Notify the public and employees about the availability of accommodation for applicants with disabilities in its recruitment processes

Human Resources

Notification about the availability of accommodation during the recruitment process will be posted in job postings on Primont’s website and the online platform it utilizes to recruit employees.

Ongoing

Recruitment, assessment or selection process

Notify job applicants, when they are individually selected to participate in an assessment or selection process that accommodations are available upon request in relation to the materials or processes to be used.

Consult with an applicant requesting accommodation to provide or arrange for the provision of a suitable accommodation in a manner that takes into account the applicant's accessibility needs due to disability

Human Resources

Notification about the availability of accommodation in respect of the recruitment, assessment or selection process will be included in the communication sent to applicants who are selected to participate in an interview.

Ongoing

Notice to successful applicants

Notify successful applicants of Organization Name’s policies for accommodating employees with disabilities.

Human Resources

Information about Primont’s policies for accommodating employees with disabilities is included in the employment contract, which will be provided to new employees upon hire, and will be posted on ADP.

Complete and ongoing

Informing employees of supports

Inform employees of policies used to support employees with disabilities, including policies on the provision of job accommodations that take into account an employee’s accessibility needs due to disability.

Provided to new employees as soon as practicable after commencing employment

Provide employees with updated information whenever there is a material change to its policies on the provision of job accommodations for employees with disabilities

Human Resources

Information about Primont’s policies for accommodating employees with disabilities included in the employment contract, which will be provided to new employees upon hire, and will be posted on ADP.

Primont will advise employees when there is a material change to any of these policies.

Complete and ongoing

Accessible Formats and Communication Supports for employees

Upon the request of an employee with a disability, provide or arrange for the provision of Accessible Formats and Communication Supports in order to ensure that (i) information required by the employee to perform his/her job; and (ii) information generally available to employees in the workplace, is accessible to the employee with a disability.

Consult with the employee making the request to determine the suitability of any Accessible Format or Communication Support. However where the needs of an employee with a disability may be accommodated in various different ways, Organization Name reserves the right to determine the type Accessible Format or Communication Support that will be provided in the circumstances.

Human Resources

Accessible Formats and Communication Supports will be provided to employees upon request and, where necessary, will be included as part of an employee’s individual accommodation plan.

Managers will receive training on the obligation to provide Accessible Formats and Communication Supports and the obligation to consult with employees prior to doing so.

Complete and ongoing

Workplace emergency response information

Provide individualized workplace emergency response information to employees who have a disability, if the disability is such that the individualized information is necessary, and if Organization Name is aware of the need for accommodation due to the employee’s disability.

Provide this information as soon as practicable after becoming aware of the need for accommodation.

With the consent of the employee, provide the workplace emergency response information to the person designated by Primont to provide assistance to the employee if the employee needs assistance by reason of disability

Review individualized workplace emergency response information when the employee moves to a different location in the organization, when the employee’s overall accommodation needs or plans are reviewed and when the Primont reviews its general emergency response policies.

Human Resources

Notification about the availability of individualized emergency response information will be posted on ADP.

Managers will receive training on the obligation to provide individualized emergency response information and the requirement that this information be updated as required under the IAS.

Complete and ongoing

Documented individual accommodation plans

Have in place a written process for the development of documented individual accommodation plans for employees with disabilities. The process must include the following elements:

i. The manner in which an employee requesting accommodation can participate in the development of the individual accommodation plan.

ii. The means by which the employee is assessed on an individual basis.

iii. The manner in which Primont can request an evaluation by an outside medical or other expert, at its own expense, to assist in determining if accommodation can be achieved and, if so, how accommodation can be achieved.

iv. The manner in which the employee can request the participation of a representative from his or her bargaining agent, where the employee is represented by a bargaining agent, or other representative from the workplace, where the employee is not represented by a bargaining agent, in the development of the accommodation plan.

v. The steps Primont will take to protect the privacy of the employee’s personal information.

vi. The frequency with which the individual accommodation plan will be reviewed and updated and the manner in which it will be done.

Human Resources

A policy on the provision of documented individual accommodation and return-to- work plans has been developed and implemented.

Managers will receive training on how it is to be implemented when required.

Complete and ongoing

vii. If an individual accommodation plan is denied, the manner in which the reasons for the denial will be provided to the employee.

viii. The means of providing the individual accommodation plan in a format that takes into account the employee’s accessibility needs due to disability.

Where requested, an employee’s individual accommodation plan will include any information regarding the provision of Accessible Formats and Communications Supports.

Where required, an employee’s individual accommodation plan will include individualized workplace emergency response information.

Return to Work Process

Have in place a documented a return to work process for employees who have been absent from work due to a disability and who require disability-related accommodations in order to return to work.

The return to work process must outline the steps Primont will take to facilitate the employee’s return to work and will include documented individual accommodation plans as part of the process

Human Resources

A policy on the provision of documented individual accommodation and return-to- work plans has been developed and implemented.

Managers will receive training on how it is to be implemented when required.

Complete and ongoing

Performance management

Take into account the accessibility needs of employees with disabilities, as well as individual accommodation plans, when using its performance management process in respect of employees with disabilities.

Human Resources

Primont has developed and implemented an “Integrated Accessibility Standards Policy” which addresses this.

Managers will receive training on the requirement to take accessibility needs into account when engaging in performance management.

Complete and ongoing

Career development and advancement

Take into account the accessibility needs of employees with disabilities as well as any individual accommodation plans when providing career development and advancement to employees with disabilities.

Human Resources

Primont has developed and implemented an “Integrated Accessibility Standards Policy” which addresses this.

Managers will receive training on the requirement to take accessibility needs into account when providing career development and/or advancement opportunities to employees.

Complete and ongoing

Redeployment

Take into account the accessibility needs of employees with disabilities, as well as individual accommodation plans, when redeploying employees with disabilities.

Human Resources

Primont has developed and implemented an “Integrated Accessibility Standards Policy” which addresses this.

Managers will receive training on the requirement to take accessibility needs into account when engaging in redeployment.

Complete and ongoing

Description

Responsible Individual/Department

Action

Status

Exterior Paths of Travel

Ensure that any exterior paths of travel, such as outdoor sidewalks and walkways, ramps, stairs and curb ramps that it constructs or redevelops and intends to maintain meet the technical requirements of the Design of Public Places Standards.

Planning Department

Primont has developed and implemented the Integrated Accessibility Standards Policy, which outlines the organization’s obligations under the Design of Public Spaces Standard.

Primont is generally not responsible for the design or planning of any public spaces covered by the Design of Public Spaces Standard.

However, Primont is aware of the exterior paths of travel requirements should it be responsible for the construction or redevelopment of any public space covered by the Design of Public Spaces Standard in future.

Complete and ongoing

Off-Street Parking

Ensure that when Primont constructs new or redevelops off-street parking facilities that it intends to maintain, the off-street parking facilities meet the requirements of the Design of Public Places Standards.

Off-street parking is a space where you can park your vehicle temporarily that is not on a public road or street.

Planning Department

Primont has developed and implemented the Integrated Accessibility Standards Policy, which outlines the organization’s obligations under the Design of Public Spaces Standard.

Primont is generally not responsible for the design or planning of any public spaces covered by the Design of Public Spaces Standard.

However, Primont is aware of the off-street parking requirements should it be responsible for the construction or redevelopment of any public space covered by the Design of Public Spaces Standard in future.

Complete and ongoing

Obtaining Services

Ensure that Primont meets the requirements of the Design of Public Places Standards in respect of the following:

1. All newly constructed service counters and fixed queuing guides.

2. All newly constructed or redeveloped waiting areas.

Planning Department

Primont has developed and implemented the Integrated Accessibility Standards Policy, which outlines the organization’s obligations under the Design of Public Spaces Standard.

Primont is generally not responsible for the design or planning of any public spaces covered by the Design of Public Spaces Standard.

However, Primont is aware of the requirements with respect to service counters, fixed queuing guidelines and waiting areas Primont is aware of the off-street parking requirements should it be responsible for the construction or redevelopment of any public space covered by the Design of Public Spaces Standard in future.

Complete and ongoing

Maintenance

Ensure accessibility plans include:

1. Procedures for preventative and emergency maintenance of the accessible elements in public spaces.

Planning Department

Primont has developed and implemented the Integrated Accessibility Standards Policy, which outlines the organization’s obligations under the Design of Public Spaces Standard.

Complete and ongoing

2. Procedures for dealing with temporary disruptions when accessible elements required are not in working order.

Primont is generally not responsible for the design or planning of any public spaces covered by the Design of Public Spaces Standard.

However, Primont is aware of the maintenance requirement should Primont is aware of the off-street parking requirements should it be responsible for the construction or redevelopment of any public space covered by the Design of Public Spaces Standard in future.

Requirement

Responsible Individual/Department

Action

Status

Customer Service Policy

Develop, implement and maintain polices governing how Primont provides goods, services or facilities to persons with disabilities in compliance with the requirements of the Customer Service Standard.

Ensure policies address use of assistive devices by persons with disabilities to obtain, use or benefit from the goods, services or facilities or with the availability of other measures, if any, which enable them to do so.

Prepare one or more written documents describing the policies and on request, give a copy of any such document to any such person.

Human Resources

Primont has developed and implemented an “Accessible Customer Service Policy” and will provide training on this Policy.

Notification about the availability of the Accessible Customer Service Policy is posted on Primont’s website.

Complete and ongoing

Notify persons to whom it provides goods, services or facilities that the documents are available upon request.

Service Animals

Allow a person with a disability to be accompanied by a service animal while on organization’s premises and to keep the animal with him or her, unless the animal is otherwise excluded by law.

If service animal is excluded by law, ensure other measures are available to enable a person with a disability to obtain, use or benefit from the organization’s goods, services or facilities.

Prepare one or more written documents describing the policies and on request, give a copy of any such document to any such person.

Notify persons to whom it provides goods, services or facilities that the documents are available upon request.

Human Resources

Primont’s Accessible Customer Service Policy addresses the organization’s obligations with respect to service animals and guide dogs. Employees will receive training with respect to these obligations.

Notification about the availability of the Accessible Customer Service Policy is posted on Primont’s website.

Complete and ongoing

Support Persons

Permit a person with a disability to be accompanied by their support person and that the person with a disability is not prevented from having access to the support person while on the premises.

Provide advance notice of fees charged for support person.

Before requiring the presence of a support person, consult with person with a disability and consider the health and safety implications based on available evidence. If requiring presence of support person, waive fees for support person.

Prepare one or more written documents describing the policies and on request, give a copy of any such document to any such person.

Human Resources

Primont’s Accessible Customer Service Policy addresses the organization’s obligations with respect to support persons. Employees will receive training with respect to these obligations.

Notification about the availability of the Accessible Customer Service Policy is posted on Primont’s website.

Complete and ongoing

Notify persons to whom it provides goods, services or facilities that the documents are available upon request.

Notice of Temporary Disruptions

Provide notice of temporary disruptions to facilities or services used by persons with disabilities to access organization’s goods, services or facilities.

Notice of the disruption must include the reason for the disruption, its anticipated duration and a description of alternative facilities or services, if any, that are available.

Prepare one or more written documents describing the policies and on request, give a copy of any such document to any such person.

Notify persons to whom it provides goods, services or facilities that the documents are available upon request.

Human Resources

Primont’s Accessible Customer Service Policy addresses the organization’s obligations with respect to notifying of temporary disruptions. Employees will receive training with respect to these obligations.

Notification about the availability of the Accessible Customer Service Policy is posted on Primont’s website.

Complete and ongoing

Training

Ensure training on the provision of goods, services or facilities to persons with disabilities is provided to everyone who:

• is an employee or volunteer

• provides goods, services or facilities on organization’s behalf;

• participates in developing organization’s policies

Ensure training includes review of purpose of AODA, requirements of the Customer Service Standard and instruction on:

• how to interact and communicate with persons with various types of disability

• how to interact with persons using assistive devices or requiring the assistance of a service animal or support person

Human Resources

Primont will provide training to existing employees, volunteers, and any third parties who provide goods, services, or facilities on behalf of Primont, as well as all persons who participate in the development of Primont’s policies.

Primont will provide training to new employees as part of the onboarding process.

Primont’s Accessible Customer Service Policy addresses the organization’s

Complete and ongoing

• how to use equipment or devices available on premises or provided by organization that may help with the provision of goods, services or facilities to a person with a disability

• what to do if person with a particular type of disability is having difficulty accessing the organization’s goods, services or facilities

Prepare a document describing organization’s training, and on request give a copy of document(s) to any person.

Notify persons to whom the organization provides goods, services or facilities of the availability of same upon request.

Maintain records of when and to whom training is provided.

obligations with respect to training.

Notification about the availability of the Accessible Customer Service Policy is posted on Primont’s website.

Primont will maintain records of the training provided.

Feedback Process

Establish a process for receiving and responding to feedback about the manner in which organization provides goods, services or facilities to persons with disabilities.

Process must be accessible to persons with disabilities by providing, or arranging for the provision of, accessible formats and communication supports upon request.

Make feedback process available to the public.

Prepare one or more written documents describing the policies and on request, give a copy of any such document to any such person.

Notify persons to whom it provides goods, services or facilities that the documents are available upon request.

Human Resources

Primont has established a feedback process, as detailed in its Accessible Customer Service Policy.

Employees will receive training on the Policy and feedback process.

Notification about the feedback process is posted on Primont’s website.

Complete and ongoing

Accessible Formats & Communication Supports

Human Resources

Primont’s Accessible

Customer Service Policy addresses the organization’s

Complete and ongoing

Provide, or arrange for the provision of, information in document(s) describing policies with respect to the Customer Service Standards in an accessible format or with communication supports upon request in a timely manner that takes into account the person’s accessibility needs and at no additional cost.

Consult with person to determine suitability of format or support.

obligations with respect to Accessible Formats and Communication Supports.

Employees will receive training with respect to these obligations.