modifications to this or other policies
administration and interpretation
multi-year accessibility plan
Bentall Kennedy (Canada) Limited Partnership is committed to providing excellent service to all our clients including tenants, prospective tenants, members of the public and third parties. The purpose of this policy is to provide a framework through which Bentall Kennedy can achieve service excellence for people with disabilities in accordance with various legislation including but not limited to the Accessibility for Ontarians with Disabilities Act, 2005, S.O. 2005, c. 11 (the "AODA") and Ontario Regulation 429/07 (the "Customer Service Standard").
Working closely with the building owners, Bentall Kennedy is committed to providing a respectful, welcoming and inclusive environment to all individuals who seek access to the buildings we manage and the services we provide. All employees are expected to comply with the spirit and intent of this policy when providing services to our customers or otherwise representing or conducting business on behalf of Bentall Kennedy.
As defined by the Accessibility for Ontarians with Disabilities Act, a barrier is anything that prevents a person with a disability from fully participating in all aspects of society because of his or her disability, including a physical barrier, an architectural barrier, information or communications barrier, an attitudinal barrier, a technological barrier, a policy or practice.
For the purpose of this policy, the term "disability" includes:
- 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 co-ordination, blindness or visual impediment, deafness or hearing impediment, muteness or speech impediment, or physical reliance on a guide dog or other animal or on a wheelchair or other remedial appliance or device,
- a condition of mental impairment or a developmental disability;
- a learning disability, or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language;
- a mental disorder; or
- an injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997.
For the purposes of this policy, the term "employee" refers to any person regarding whom Bentall Kennedy pays wages or a salary, has control over their assigned work and has a right to control the details of their work. This includes, but is not limited to fulltime, part-time, seasonal and contract employees.
For the purposes of this policy, an animal is a service animal for a person with a disability if:
- it is readily apparent that the animal is used by the person for reasons relating to his or her disability; or
- the person provides a letter from a physician or nurse confirming that the person requires the animal for reasons relating to the disability.
For the purposes of this policy, a "support person" is a person who accompanies a person with a disability in order to help with communication, mobility, personal care or medical needs or with access to goods or services.
Bentall Kennedy is committed to providing accessible customer service to people with disabilities in a manner consistent with the principles of dignity, independence, integration and equal opportunity.
When communicating with persons with a disability, Bentall Kennedy employees will take into account the particular individual's needs and circumstances. All communication will be provided in a manner that respects the dignity and independence of persons with disabilities.
Persons with disabilities will be permitted to obtain, use or benefit from goods or services through the use of their own assistive devices. In the event a person with a disability is hindered from accessing any goods or services offered, we will use our best efforts to deliver the same service in another way.
We are committed to providing accessible telephone service to our customers. If telephone communication provides a barrier to a person with a disability, we will offer to communicate by e-mail or fax.
We are committed to providing accessible invoices and we will provide our invoices in an alternative accessible format upon request. We will answer any questions customers may have about the content of invoices in person, by telephone or email.
We welcome persons with disabilities who are accompanied by a service animal. If a service animal is excluded by law, we will suggest appropriate alternatives and provide assistance to ensure that the person is able to access, obtain, use or benefit from our services where possible.
We welcome persons with disabilities who are accompanied by a Support Person. Any person with a disability who is accompanied by a Support Person will be allowed to access any of our services and facilities with his or her Support Person.
Notice of Temporary Disruptions
We are aware that persons with disabilities rely on certain services and facilities we provide. Temporary disruptions in services and facilities will occur from time to time. We will provide notice when there is a temporary disruption in those services or facilities that people with disabilities usually rely upon. This notice will include information about the reason for the disruption, its anticipated duration, and, if applicable, a description of alternative facilities or services that may be available. Notice of service disruptions will be provided as soon as practical after we become aware of the disruption, or in advance in the case of planned disruptions.
Notice will be provided by a variety of methods, depending on the circumstances, and may include postings in conspicuous places such as in the entrances, lobbies and elevator banks of our managed buildings.
Training for Staff
Bentall Kennedy will ensure that all employees, agents and third parties who interact with customers on its behalf receive AODA Customer Service Standard Training. Training shall be provided on an ongoing basis whenever changes are made to this Policy to ensure that this Policy is properly implemented at all times. An electronic record of the training will be kept in an online database.
Training will include the following:
- An overview of the purposes of the Accessibility for Ontarians with Disabilities Act, 2005 and the requirements of the Customer Service Standard;
- Training on how to interact and communicate with people with various types of disabilities;
- Training on how to interact with people with disabilities who use an assistive device or require the assistance of a service animal or a support person;
- Training on how to use equipment or assistive devices available or otherwise provided by Bentall Kennedy that may help with the provision of goods or services to a person with a disability;
- Training on what to do if a person with a disability is having difficulty in accessing our services;
We welcome questions and feedback about how we deliver services to people with disabilities. Customers can submit feedback and questions in person, by e-mail, or in writing or by any other means, to the Human Resources Department.
Human Resources Department
55 University Avenue, Suite 300
Toronto, ON, M5J 2H7
If the feedback raises serious concerns with respect to the delivery of services to persons with disabilities, we will provide a response to the concerns in a timely manner. The author of the feedback will be provided a response in the format requested (or the most appropriate format where no request was made) outlining corrective actions we will or will have taken. We will make our best efforts to respond to feedback within ten (10) business days.
This Policy and any corresponding practices and procedures will be made available to any person on request. We will post notice of the availability of these documents on our website.
Upon request, we will provide this Policy and any other forms created pursuant to the Customer Service Standard in a format that takes into account the disability of the person submitting the request.
Modifications to this or other policies
We are committed to developing customer service policies that respect and promote the dignity and independence of people with disabilities. All Bentall Kennedy policies and procedures will be developed or updated in such a manner as to respect and promote the dignity and independence of persons with disabilities.
Administration & Interpretation
The Vice-President, Human Resources is responsible for this policy. The Human Resources Department will provide advice and assistance in the interpretation and administration of this policy.
This document is available to the public and in alternate format and accessible communication supports upon request.
Statement of Commitment
Bentall Kennedy is committed to treating all people in a way that allows them to maintain their dignity and independence. We believe in integration and equal opportunity. We are committed to meeting the needs of people with disabilities in a timely manner, and will do so by preventing and removing barriers to accessibility and meeting accessibility requirements under the Accessibility for Ontarians with Disabilities Act.
Accessible Emergency Information
Bentall Kennedy is committed to providing the customers and clients with publicly available information in an accessible way upon request. We will also provide employees with disabilities with individualized emergency response information when necessary.
Bentall Kennedy will provide training to Ontario staff on Ontario's accessibility laws and on the Human Rights Code as it relates to people with disabilities. Training will be provided in a way that best suits the duties of staff members.
Bentall Kennedy will take the following steps to ensure Ontario employees are provided with the training needed to meet Ontario's accessible laws by January 1, 2015:
- Training as it relates to accessibility and the Human Rights Code will be provided to all Ontario staff members through an online format.
- All existing employees will be required to complete this training.
- New employees to Bentall Kennedy will be required to complete this training, in addition to the Customer Service training, within 30 days of their start date.
Information and Communication
Bentall Kennedy is committed to meeting the communication needs of people with disabilities.
Bentall Kennedy will take the following steps to ensure existing feedback processes are accessible to people with disabilities in Ontario upon request by January 1, 2015:
- Upon request, we will administer our feedback processes in accessible formats and make communication supports available.
Bentall Kennedy will take the following steps to make sure all publically available information in Ontario is made accessible upon request by January 1, 2016:
- Upon request, we will provide information and communications in accessible formats and with communication supports to people with disabilities in a timely manner.
Bentall Kennedy will take the following steps to make all websites and content conform with WCAG 2.0, Level AA by January 1, 2021:
- We will ensure that all websites and web content, including web-based applications, that we control directly or indirectly through a contractual relationship that allows for modification of the product, meet the WCAG 2.0 Level AA standard.
Bentall Kennedy is committed to fair and accessible employment practices.
We will take the following steps to notify the public and staff that, when requested, Bentall Kennedy will accommodate people with disabilities during the recruitment and assessment processes and when people are hired:
- On all of our job descriptions, we will include a statement to notify all applicants and employees that, upon request, persons with disabilities will be accommodated throughout the recruitment and selection process and for the duration of employment with Bentall Kennedy.
Bentall Kennedy will take the following steps by January 1, 2016 to develop and put in place a process for developing individual accommodation plans and return-to-work policies for employees in Ontario that have been absent due to a disability:
- A standard template for the development of individual accommodation plans and return-to-work programs will be developed by Human Resources.
We will take the following steps to ensure the accessibility needs of employees with disabilities in Ontario are taken into account in performance management, career development and redeployment processes:
- A plan, which includes consideration for performance management, career development and redeployment processes, will be developed by Human Resources, in conjunction with the employee, for staff members with disabilities.
Design of Public Spaces
Bentall Kennedy will meet the Accessibility Standards for the Design of Public Space when building or making major modifications to public spaces in Ontario. Public spaces include:
- Recreational trails/beach access routes
- Outdoor public eating areas like rest stops or picnic areas
- Outdoor play spaces, like playgrounds in provincial parks and local communities
- Outdoor paths of travel, like sidewalks, ramps, stairs, curb ramps, rest areas and accessible pedestrian signals
- Accessible off street parking
- Service-related elements like service counters, fixed queuing lines and waiting areas
Bentall Kennedy will put procedures in place to prevent service disruptions to its accessible parts of its public spaces.
In the event of a service disruption to the accessible parts of public spaces, we will notify the public of the service disruption and alternatives available.
This policy will be updated once every five years.