TD Insurance s Multi-Year Accessibility Plan
TABLE OF CONTENTS... 1 INTRODUCTION AND STATEMENT OF COMMITMENT... 1 OUR PLAN... 1 ACCESSIBILITY POLICIES...1 TRAINING...1 INFORMATION COMMUNICATION STANDARDS...2 1. Feedback, Accessible Frmats and Cmmunicatins Supprt... 2 2. Accessible Websites and Web Cntent... 3 3. Self-Service Kisks... 3 4. Temprary Disruptin... 4 EMPLOYMENT STANDARDS...4 5. Recruitment... 4 6. Infrming Emplyees f Supprts... 5 7. Dcumented Individual Accmmdatin Plans/Return t Wrk Prcess... 6 8. Perfrmance Management, Career Develpment and Redeplyment... 7
INTRODUCTION AND STATEMENT OF COMMITMENT In 2005, the Ontari gvernment passed the Accessibility fr Ontarians with Disabilities Act (AODA). The gal f the Ontari Gvernment is t ensure accessibility in Ontari by 2025. The Integrated Accessibility Standards Regulatins (IASR) under the AODA require that effective January 1 st 2014 TD Insurance establish, implement and maintain a multi-year accessibility plan which summarizes ur cmmitment t accessibility. Althugh the IASR is cnsidered an Ontari regulatin, TD Insurance has decided t implement natinally t ensure a cnsistent experience natinwide and align with their crprate respnsibility fcuses. This multi-year plan utlines TD Insurance s strategy t prevent and remve barriers in rder t fulfill TD Insurance s cmmitment t fster an inclusive envirnment as utline in the TD Insurance Accessibility Plicy. OUR PLAN ACCESSIBILITY POLICIES Diversity and inclusiveness plays a big part in TD Insurance s crprate respnsibility mdel. TD Insurance is cmmitted t being a welcming place fr all ur custmers and emplyees. Althugh TDI has implemented many plicies and prcesses relating t accessibility fr ur custmers and emplyees, we are cmmitted t reviewing these plicies and enhancing them as ur reality changes. Analysis f all current plicies and prcedures relating t accessibility; Establish a cmmittee with representatin frm key business units t ensure all plicies are cnsidered during ur review; Leverage plicies already in place alng with the IASR and the Ontari Human Rights Cde t ensure new plicies created are in line with the regulatin; Publish plicies n internal and external sites and ensure its availability in an accessible frmat ; Review and update the multi-year accessibility plan at least nce every five years. Required legislative cmpliance: January 1 st, 2014 Implemented timeframe: January 1 st, 2013 January 1 st, 2014 Cmpletin date: January 1 st, 2014 TRAINING 1
TD Insurance is cmmitted t implementing a prcess t ensure that all emplyees, vlunteers, thirdparty cntractrs and utsurced services are infrmed abut TDI s accessibility plicies and plans relating t the IASR and the Ontari Human Rights Cde. Establish key cntacts within ur Learning & Develpment Team fcused n develping the apprpriate training; Determine and ensure that apprpriate training n the requirements f the IASR and n the Ontari Human Rights Cde as it pertains t persns with disabilities is prvided in alignment with the legislatin; Keep and maintain recrds f the training prvided, including the dates the training was prvided and all the individuals wh cmpleted it; Ensure training requirement is added t all new hire and nbarding checklists; Ensure the training is kept up t date by reviewing materials and plicies n an n-ging basis; Ensure training is re-issued in alignment with the legislatin and/r TD Plicies shuld there be changes. Required legislative cmpliance: January 1 st, 2015 Implemented timeframe: January 1 st, 2014 January 1 st, 2015 Cmpletin date: January 1 st, 2015 INFORMATION COMMUNICATION STANDARDS TD Insurance is cmmitted t ensuring cmpany infrmatin and cmmunicatins are accessible t persns with disabilities. TD Insurance will develp and implement new accessibility requirements under the infrmatin and cmmunicatin standard t ensure that infrmatin and cmmunicatin systems and platfrms are accessible and are prvided in an accessible frmat that meet the needs f persns with disabilities. 1. Feedback, Accessible Frmats and Cmmunicatins Supprt TD Insurance will: Ensure that existing and new prcesses fr receiving and respnding t feedback are accessible t persns with disabilities by prviding r arranging fr the prvisin f an accessible frmat and cmmunicatin supprts, upn request and in a timely manner; 2
Mre bradly, as a general principal where accessible frmats and cmmunicatin supprts fr persns with disabilities are requested: Prvide r arrange fr the prvisin f such accessible frmats and cmmunicatins supprts; Cnsult with the persn making the request t determine the suitability f the accessible frmat r cmmunicatin supprt; Prvide r arrange fr the prvisin f accessible frmats and cmmunicatins supprts in a timely manner that takes int accunt the persn s accessibility needs due t disability, and at a cst n mre than the regular cst charge t ther persns; Ntify the public, emplyees, third-party cntractrs wh prvide gds, services and facilities n behalf f TD Insurance, and persns participating in the develpment and apprval f TD Insurance s plicies abut the availability f accessible frmats and cmmunicatin supprts. Required legislative cmpliance: Feedback January 1 st, 2015 Accessible Frmats & Cmmunicatins Supprt January 1 st 2016 Implemented timeframe: January 1 st, 2014 January 1 st, 2016 Cmpletin date: January 1 st, 2015 2. Accessible Websites and Web Cntent TD Insurance will make websites accessible t peple with disabilities by cnfrming t internatinal standards fr website accessibility: Wrld Wide Web Cnsrtium Web Cntent Accessibility Guidelines (WCAG) 2.0 Ensure that all new TD Insurance websites and cntent published n thse sites will be cmpliant with WCAG 2.0 level AA by January 1 st 2014; Ensure that TD Insurance websites and cntent n thse sites, published after January 1 st 2012 will be cmpliant with WCAG 2.0 level AA by January 1 st 2021; Required legislative cmpliance: New Internet websites and web cntent n thse sites WCAG 2.0 Level A January 1 st, 2014 All Internet websites and web cntent published after January 1 st, 2012, WCGA 2.0 Level AA January 1 st 2021 Implemented timeframe: January 1 st, 2013 January 1 st 2021 Cmpletin date: 3. Self-Service Kisks ACTION TAKEN: TD Insurance has ensured that all self-service kisks, including debit terminals, are accessible t custmers and emplyees by: 3
Tk inventry f all self-serve kisks and debit terminals at each f ur ffices Cnfirmed that all ffices used the same Merchant (TD Merchant Services) Cnfirmed that there was a standard mdel acrss the cuntry Perfrmed accessibility test by ensuring self-serve kisks and debit terminals culd accmmdate accessibility needs including visual impairments and mbility limitatins Required legislative cmpliance: January 1 st, 2014 Implemented timeframe: January 1 st, 2013 January 1 st, 2014 Cmpletin date: April 30 th, 2013 4. Temprary Disruptin In the event f a planned r unexpected disruptin in facilities r services, we will prvide infrmatin abut the reasn fr the disruptin, hw lng it is expected t last, and a descriptin f any alternative facilities r services available (where applicable). Required legislative cmpliance: January 1 st, 2017 Implemented timeframe: January 1 st, 2014 January 1 st, 2016 Cmpletin date: January 1 st, 2015 EMPLOYMENT STANDARDS 5. Recruitment At TD Insurance, we believe that diversity is key t ur success. We are cmmitted t fstering a unique and inclusive emplyee culture where we attract and retain the best talent which requires prviding accessibility at all stages f the emplyment cycle. TD Insurance will: Recruitment General TD Insurance will ntify emplyees and the public f the availability f accmmdatins fr applicants with disabilities in the recruitment prcess. This will include: A review, and, as necessary, mdificatin f existing recruitment plicies, prcedures and prcesses; 4
Specifying that accmmdatin is available fr applicants with disabilities, n TDI s websites and jb pstings; Wrking with suppliers t ensure external web pages and jb pstings are cmpliant with the Infrmatin and Cmmunicatin Standards under the IASR s requirements. Recruitment, assessment and selectin TD Insurance will ntify jb applicants, when they are individually selected t participate in an assessment r selectin prcess that accmmdatins are available upn request in relatin t the materials r prcesses t be used in the assessment/selectin prcess. This will include: A review, and, as necessary, mdificatins f existing recruitment plicies, prcedures and prcesses; Inclusin f accmmdatin ntice as part f the script in the scheduling f an interview and/r assessment; If a selected applicant requests an accmmdatin, cnsult with the applicant and arrange fr prvisin f suitable accmmdatins in a manner that takes int accunt the applicant s accessibility needs due t disability. Ntice t Successful Applicants When making ffers f emplyment, TD Insurance will ntify the successful applicant f its plicies fr accmmdating emplyees with disabilities. This will include: A review and, as necessary, mdificatin f existing recruitment plicies, prcedures and prcesses; Inclusin f TDI s plicies n accmmdating emplyees with disabilities in ffer f emplyment letters. Required legislative cmpliance: January 1 st, 2016 Implemented timeframe: January 1 st, 2013 January 1 st, 2016 Cmpletin date: January 1 st, 2015 6. Infrming Emplyees f Supprts TD Insurance will infrm all emplyees f plicies that supprt emplyees with disabilities, including, but nt limited t, plicies n the prvisin f jb accmmdatins that take int accunt an emplyee s accessibility needs due t a disability. This will include: Infrming current emplyees and new hires f TDI s plicies n the prvisin f jb accmmdatins that take int accunt an emplyee s need due t disability; Prviding infrmatin under this sectin as sn as practicable after the new emplyee begins emplyment, specifically during the nbarding prcess; 5
Keeping emplyees up t date n changes t existing plicies n jb accmmdatins with respect t disability; Where an emplyee with a disability s requests it, TDI will prvide r arrange fr prvisin f suitable accessible frmats and cmmunicatins supprts fr: Infrmatin that is needed in rder t perfrm the emplyee s jb; Infrmatin that is generally available t emplyees in the wrkplace. In meeting the bligatins t prvide the infrmatin that is set ut in the paragraph abve, TDI will cnsult with the requesting emplyee t determine the suitability f an accessible frmat r cmmunicatin supprt Required legislative cmpliance: January 1 st, 2016 Implemented timeframe: January 1 st, 2013 January 1 st 2016 Cmpletin date: January 1 st, 2015 7. Dcumented Individual Accmmdatin Plans/Return t Wrk Prcess TD Insurance will incrprate new accessibility requirements t ensure that barriers in accmmdatin and return t wrk prcesses are eliminated and crprate plicies surrunding accmmdatin and return t wrk are fllwed, where applicable. TD Insurance s existing plicies and prcesses include steps that TDI will take t accmmdate an emplyee with a disability and t facilitate an emplyee s return t wrk after absenteeism due t disability r injury. TDI will: Review and assess the existing plicies and prcesses t ensure that they include steps fr the develpment f a dcumented individual accmmdatin plan fr emplyees with a disability, if such plans are required. Ensure that the prcess fr the develpment f dcumented individual accmmdatin plans will include the fllwing: Hw emplyees requesting accmmdatins can participate in the develpment f the individual accmmdatin plan; Hw the emplyee is assessed n an individual basis; Hw TDI can request an evaluatin by an utside medical r ther expert, at the emplyer s expense, t assist the emplyer in determining if accmmdatin can be achieved, and if s, hw accmmdatins can be achieved; Steps taken t prtect the privacy f the emplyee s persnal infrmatin; 6
The frequency with which the individual accmmdatin plan will be reviewed and updated, and hw it will be dne; If an individual accmmdatin plan is denied, hw the reasns fr the denial will be prvided t the emplyee; The means f prviding the individual accmmdatin plan in a frmat that takes int accunt the emplyee s accessibility needs due t disability. Ensure the individual accmmdatin plan includes: Any infrmatin regarding accessible frmats and cmmunicatins supprts prvided by TDI, if requested; Individualized wrkplace emergency respnse infrmatin that is required; Any ther accmmdatin that is t be prvided. Ensure that the return t wrk prcess as set ut in existing plicies utlines the steps TDI will take t facilitate the emplyee s return t wrk after a disability-related absence r injury, utlines the develpment f a written individualized return t wrk plan fr such emplyees, and if required the use f individual accmmdatin plans, as discussed abve, in the return t wrk prcess. Required legislative cmpliance: January 1 st, 2016 Implemented timeframe: January 1 st, 2013 January 1 st, 2016 Cmpletin date: January 1 st, 2015 8. Perfrmance Management, Career Develpment and Redeplyment TD Insurance will take int accunt the accessibility needs f emplyees with disabilities, as well as individual accmmdatin plans when: Using its perfrmance management prcess in respect f emplyees with disabilities Prviding career develpment and advancement t its emplyees with disabilities Redeplying emplyees with disabilities TD Insurance will: Review, assess and, as necessary, mdify existing plicies, prcedures and practices t ensure the accessibility needs f emplyees with disabilities are met; Take the accessibility needs f emplyees with disabilities and, as applicable, their individualized accmmdatin plans int accunt when: 7
Assessing perfrmance Managing career develpment and advancement Redeplyment is required Review, assess and mdify if required existing prcesses t ensure that perfrmance management prcess and tls take int cnsideratin the accessibility needs f emplyees with disabilities. Take int accunt the accessibility needs f emplyees with disabilities when prviding career develpment and advancement t its emplyees with disabilities; Prvide peple managers with apprpriate supprt t assist in the career develpment f their emplyees with disabilities Develp and dcument redeplyment prcess fr emplyees with disability in cnjunctin with the individualized accmmdatin plans; Required legislative cmpliance: January 1 st, 2016 Implemented timeframe: January 1 st, 2013 January 1 st 2016 Cmpletin date: January 1 st, 2015 8