Linamar Corporation's Accessible Customer Service Plan Providing Good and Services to People with Disabilities

Introduction

This plan addresses the requirements of the Accessible Customer Service Standard and the Integrated Accessibility Standards, Ontario Regulation 429/07, Ontario Regulation 191/11 and Ontario Regulation 413/12 under the Accessibility for Ontarians with Disabilities Act (AODA), 2005.

This legislation aims to achieve full accessibility in the Province of Ontario by 2025. Linamar Corporation is committed to excellence in serving all customers including people with disabilities. Thus, we have created this Multi-Year Accessibility Plan with will outline the compliance requirements from 2012-2017. After 2017, this plan will be reviewed and updated.

This document is available to the public and can be provided in an alternate format for accessibility purposes upon request.

Notice of availability

Linamar Corporation will notify the public that our policies are available upon request through our website. Linamar Corporation’s policies will also be posted in a visible place at the Corporate Office.

Legislation Deadline: January 1, 2012

1. Employment Standard

Individualized Workplace Emergency Response

Regulation Requirement(s)

O. Reg. 191/11- 27 (1-4)

Individualized workplace emergency response information must be provided upon request and in accessible formats when need is articulated by employee. Individualized workplace emergency response information shall be reviewed when: the employee moves to different location in organization, the employee’s overall accommodation needs or plans are reviewed and when the employer reviews general emergency response policies.

Linamar’s Action Plan

1. Communication Plan:
   1. Inform employees of Emergency Response assistance.

2. Emergency Response Plan Template:
   1. Create Emergency Response Plan template and distribute to Ontario locations and Ontarian subsidiaries.

Status Report

Complete

Legislation Deadline: January 1, 2012

2.Customer Service Standard

All Requirements under the Customer Service Standard

Regulation Requirement(s)

O. Reg. 429/07 and amendment O. Reg. 415/12

Organizations must be in compliance with the above regulations in their entirety on and after January 1, 2012. This Regulation establishes accessibility standards for customer service and it applies to every designated public sector organization and to every other person or organization that provides goods or services to members of the public or other third parties and that has at least one employee in Ontario.

Linamar’s Action Plan

1. Establishment of Policies, Practices and Procedures:
   1. Linamar will promote an inclusive culture through the development of accessibility policies, practices and procedures.
   2. Please view action plan for “Accessibility Plans and Policies” under “Requirements for 2014”.

2. Use of Service Animals, Support Persons and Assistive Devices:
   1. Service animals are allowed on the parts of Linamar premises that are open to the general public.
   2. A person with a disability who is accompanied by a support person will be allowed to have that person accompany them on our premises.
   3. Ensure that all necessary employees are trained and familiar with various on-site assistive devices or other devices that may be used by customers with disabilities while accessing Linamar’s goods or services.
   4. These stipulations will be outlined in our Accessibility Policy.

3. Notice of Temporary Disruptions:
   1. In the event of a planned or unexpected disruption to services or facilities for customers with disabilities at Linamar Corporation or its related subsidiaries in Ontario, Linamar will notify customers promptly.
   2. Linamar will clearly post notice that includes information about the reason for the disruption, its anticipated length of time, and a description of alternative facilities or services, if available.
   3. These stipulations will be outlined in our Accessibility Policy.

4. Training for Staff:
   1. Please view action plan for “Integrated Accessibility Standards Training” under “Requirements for 2015”.
   2. Staff will also receive training specific to that outlined the Customer Service Standard.
   3. These stipulations will be outlined in our Accessibility Policy.

5. Feedback Process for Providers of Goods and Services:
   1. Please view action plan for “Feedback Process” under “Requirements for 2015”.

6. Notice of Availability of Documents and Format of Documents:
   1. Please view action plan for “Accessible Formats and Communication Supports” under “Requirements for 2016”.
   2. A copy of the accessible documents required under this Regulation will take into account the requestor’s disability.

7. Accessibility Report:
   1. Accessibility reports will be filed in timely compliance with this Regulation. Linamar has designated internal Human Resources staff to ensure compliance.

Status Report

Complete

Legislation Deadline: January 1, 2014

1.0 General Requirements

Accessibility Plans and Policies

Regulation Requirement(s)

O. Reg. 191/11- 4 (1-4)

Create an Accessibility Plan to outline the organization’s strategy to prevent and remove barriers and meet its Regulation requirements. The Plan must be posted to the company’s website (if applicable) upon completion. The Plan must be reviewed and updated every 5 years.

Linamar’s Action Plan

1. Plan Development:
   1. Develop Linamar’s Multi-Year Accessibility Plan and Accessibility Policy.
   2. Set date for re-evaluation of Accessibility Plan.

2. Communication Plan:
   1. Post completed Plan and Policy to company website.
   2. Ensure accessible formats of both documents are available upon request.

Status Report

Complete

Legislation Deadline: January 1, 2014

2.0  Information and Communication Standard

Accessible Web Sites and Web Content

Regulation Requirement(s)

O. Reg. 191/11 – 14 (1-7)

New websites and web content on those sites must conform to WCAG 2.0 Level A. Except where not practicable, this applies to:

• Websites;
• Web content published on a website after January 1, 2012;
• Web-based applications; that an organization controls directly or through a contractual relationship that allows for modification of a product.

Linamar’s Action Plan

1. Website and Application Review:
   1. Conduct website accessibility audit.
   2. Review compliance with corporate website in relation to the WCAG 2.0 Level A standards.
   3. Begin preparations for compliance with WCAG 2.0 Level AA by January 1, 2021.

Status Report

Completed

Legislation Deadline: January 1, 2015

1.0  General Requirements

Integrated Accessibility Standards Training

Regulation Requirement(s)

O. Reg. 191/11 – 7 (1-6)

Employers shall provide training regarding Integrated Accessibility Regulation to all employees and volunteers, persons who participate in developing organizational policy and other persons who provide goods, services or facilities on behalf of the organization.

Training should take place as soon as practicable and include any changes to policies on an ongoing basis. A record of training is mandatory, and must include the number of participants receiving the training in addition to the date when the training occurred.

Linamar’s Action Plan

1. Training Plan Development:
   1. Linamar will develop its training plan, which will include:
      1. An overview of the Accessibility for Ontarians with Disabilities Act, 2005 and the requirements of the customer service standard;
      2. Linamar Corporation’s plan related to the customer service standard;
      3. How to interact and communicate with people with various types of disabilities;
      4. How to interact with people with disabilities who use an assistive device or require the assistance of a service animal or a support person;
      5. How to use and interact with various assistive devices, available on-site or otherwise that may help Linamar Corporation provide our goods and services to people with disabilities ;
      6. What to do if a person with a disability is having difficulty in accessing Linamar Corporation’s goods and services.
   2. Ongoing training will be provided to applicable employees with respect to any changes in Linamar Corporation’s existing accessible customer service plan and policies.
   3. This training will be provided to applicable employees as soon as practicable after their hiring. The training will meet compliance standards as well as the needs of employees.

2. Employee Identification:
   1. Identify employees that require training under the Standard. Individuals who fit the following criteria will be trained:
      1. Employees who receive wages or salaries, or volunteers, and who interact with the public or third parties on behalf of Linamar Corporation to deliver our goods and services.

3. Training Record-Keeping:
   1. Records of training will be kept and will indicate the date the training was provided, and the number of employees that participated in the training.

Status Report

Completed

Legislation Deadline: January 1, 2015

2.0  Information and Communication Standard

Feedback Process

Regulation Requirement(s)

O. Reg. 191/11 – 11 (1-4)

Ensure there is an accessible feedback mechanism in relation to areas covered under the AODA. Every obligated organization shall notify the public about the availability of accessible formats and communication supports for delivering feedback, upon request.

Linamar’s Action Plan

1. Create Feedback Template:
   1. Develop a feedback template for parties that wish to provide Linamar with feedback relating to Standards compliance, our plans and policies, and other AODA-related feedback.
      1. Feedback can be presented to Linamar by the following means:
         1. By e-mail;
         2. By phone;
         3. By mail;
         4. In-person;
         5. Another accessible format, upon request.

2. Develop Feedback Process:
   1. Develop internal process for handling and responding to AODA-related feedback.
   2. Ensure responses are available in an accessible format, upon request.

Status Report

Complete

Legislation Deadline: January 1, 2016

1.0       Employment Standard

Recruitment

Regulation Requirement(s)

O. Reg. 191/11 – 22

Notice shall be provided to employees and the public about the availability of accommodation for applicants with disabilities in the organization’s recruitment process.

O. Reg. 191/11 – 23(1-2)

Accommodation shall be provided to applicants selected to participate in assessment or selection process, upon request. Suitable accommodation shall be provided in manner that takes into account the applicant’s accessibility needs.

Linamar’s Action Plan

1. Inform Applicants:
   1. Internal and external applicants will be informed of the availability of accommodations throughout the recruitment process through job postings or other alternate and appropriate method.

2. Implement Accommodations:
   1. Upon consultation with the prospective applicant, appropriate accommodations will be implemented throughout the recruitment process.
   2. Establish internal procedure for implementing accommodations pertaining to the recruitment process.

Status Report

In progress

Legislation Deadline: January 1, 2016

1.0       Employment Standard

Accommodation Information for Employees

Regulation Requirement(s)

O. Reg. 191/11 - 24

The successful applicant shall be informed of the availability of accommodation and shall be provided with the accommodation policy when making offer of employment.

O. Reg. 191/11 – 25 (1-3)

The accommodation policy should be provided to all employees, and updates should be provided whenever changes are made.

Linamar’s Action Plan

1. Update Employment Letter Policy:
   1. Update the initial employment letter and package to include Linamar’s Accessibility Policy.
   2. Update the initial employment letter and package to inform the new employee of the availability of accommodations, where applicable.

2. Implement New Procedure(s):
   1. Provide all employees with our accommodation policy at their next review, until all existing employees have been made aware of the policy.
   2. Provide updates to employees when required.

Status Report

In progress

Legislation Deadline: January 1, 2016

1. Employment Standard

Process to Accommodate Employees

Regulation Requirement(s)

O. Reg. 191/11 – 26 (1-2)

Every employer shall consult and provide or arrange for the employee that has requested accessible formats and communication supports. The alternate formats provided to employees with disabilities upon request include information needed to perform employee’s job and information generally available in workplace. The employer will consult with the employee to determine the suitability of the accessible format provided.

O. Reg. 191/11 – 28 (1-2)

Individual Accommodation Plans (IAPs) will be provided to employees with disabilities of which the organization has been made aware of.

O. Reg. 191/11 – 29 (1-3)

Documented Return-to-Work process will be established, and will include disability-related accommodations.

O. Reg. 191/11 – 30 (1-2); 31 (1-2); 32 (1-2)

Performance management, career development and advancement and redeployment/reassignment processes must include accessibility accommodation and communications provided in alternate format where applicable.

Linamar’s Action Plan

1. Inform and Consult with Employees:
   1. Inform employees of the availability of alternate formats.
   2. Consult with employees who have requested accessible formats and supports to ensure they are provided with appropriate and suitable resources.

2. Establish Procedure:
   1. Develop an internal procedure for consulting with employees and determining accommodations.

3. Individual Accommodation Plan Templates and Implementation:
   1. Develop Individual Accommodation templates.
   2. Distribute the templates to Ontario locations and Ontarian subsidies.

4. Return-to-Work Accommodation Templates and Implementation:
   3. Develop Return-to-Work Accommodation templates.
   4. Distribute the templates to Ontario locations and Ontarian subsidies.

5. Performance Management:
   5. Ensure all supervisors and managers are aware of our policy and commitment to an inclusive culture.

6. Career Development and Advancement:
   6. Establish procedure to address all accommodation needs in advance of training sessions with employees with a disability.

7. Redeployment/Reassignment:
   7. Evaluate the redeployment to ensure the accommodation needs can be met at the new facility or within the new role.
      1. Reassess the Individual Accommodation Plan and/or Workplace Emergency Response Form if applicable.
   8. Ensure all supervisors, managers and other relevant persons receive all documentation and continue to provide appropriate accommodations, while also ensuring employee confidentiality.

Status Report

In progress

Legislation Deadline: January 1, 2016

2. Information and Communication Standard

Accessible Formats and Communication Supports

Regulation Requirement(s)

O. Reg. 191/11 - 12 (1)

Except as otherwise provided, every obligated organization shall upon request provide or arrange for the provision of accessible formats and communication supports for persons with disabilities in a timely manner that takes into account the person’s accessibility needs, in consultation with the person making the request, and at a cost that is no more than the regular cost charged to other persons if applicable.

Linamar’s Action Plan

1. Implement Accessible Format Policy:
   1. Create a policy for providing accessible information.
2. Alternate Format Consult:
   1. Consult with requestor to provide documentation in an appropriate and accessible format.
   2. Establish internal procedures for processing requests for alternate formats where applicable to ensure the information is provided in a timely fashion.
3. Accessible Material Training:
   1. We will communicate with people with disabilities in ways that take into account their disability. Our training to all applicable persons will include various means to communicate with persons with varying disabilities, including communicating with accessible materials.

Status Report

Completed

Legislation Deadline: January 1, 2017

1.0       Design of Public Spaces Standard

Planned Future Design of Public Spaces

Regulation Requirement(s)

O. Reg. 413/12

Due consideration and consultation must be given to ensure public spaces are accessible for persons with disabilities. The standard applies to new construction or major renovations being designed for the following facilities or elements:

• Recreational trails
• Outdoor public eating areas
• Outdoor play spaces
• Exterior paths of travel
• Off-street parking
• Service counters and waiting areas (indoor and outdoor)

Linamar’s Action Plan

1. Implement Design of Public Spaces Standard:
   1. Ensure Linamar Corporation meets the Design of Public Spaces Standard criteria when creating designated public space under the Standard.

Status Report

Completed