TJX Canada Integrated Accessibility Standard Policies & Multi-Year Accessibility Plan 2014
Table of Contents 1. Purpose. 3 2. Scope and Responsibilities 3 3. Policy Statement and Organizational Commitment 3 4. Definitions. 4 5. General Provisions.. 5 5.1 Multi-Year Accessibility Plan... 5 5.2 Training... 5 6. Information and Communications Standard 5 6.1 Accessible Emergency Information 6 6.2 Feedback, Accessible Formats and Communication Supports. 6 6.3 Website Accessibility 6 7. Employment Standard 7 7.1 Recruitment 7 7.2 Associate Notification... 7 7.3 Accessible Formats and Communication Supports... 8 7.4 Individual Accommodation Plan (IAP) and Return to Work 8 7.5 Performance Management, Career Development, and Redeployment...8 7.6 Workplace Emergency Response Information. 9 8. Public Spaces..9 9. Contact.. 9 TJX Canada: Integrated Accessibility Standard Policies & Multi-Year Accessibility Plan Page 2
1. Purpose Under the Accessibility for Ontarians with Disabilities Act (AODA), 2005, all public and private sector organizations must meet the requirements of accessibility standards established by the regulation. This policy establishes the Integrated Accessibility Standards Regulation (IASR) in the areas of Employment, Information & Communications, and Public Spaces for TJX Canada in accordance with Ontario Regulation 191/11, Ontario Regulation 413/12 and with the Ministry of Economic Development, Trade and Employment s intent to streamline, align and phase-in accessibility requirements and allow for progress on accessibility and reduce the regulatory burden for obligated organizations. The IASR came into force on July 1, 2011. 2. Scope and Responsibilities This plan has been drafted in accordance with the Regulation and addresses how TJX Canada achieves accessibility through meeting the Regulation s requirements. It provides the overall strategic direction that will be followed to provide accessibility supports to Ontarians with disabilities. The requirements of the Regulation include the following four items: I. Establishment, implementation, maintenance and documentation of a multi-year accessibility plan, which outlines the organization s strategy to prevent and remove barriers and meet its requirements under the Regulation. II. III. IV. Incorporation of accessibility criteria and features when procuring or acquiring goods, services, or facilities. Training. Other specific requirements under the Information & Communications, Employment, and Public Spaces standards. 3. Policy Statement and Organizational Commitment TJX Canada is committed to being a Retailer of Choice, Neighbour of Choice and an Employer of Choice. We embrace diversity and inclusion as seriously as any business imperative, as specifically set out in the Canadian Charter of Rights and Freedoms, and the Accessibility for Ontarians with Disabilities Act, 2005. As an organization, we strive to meet the needs of people with disabilities, specifically all Associates in Ontario, through the implementation of this policy and accessibility plan. TJX Canada: Integrated Accessibility Standard Policies & Multi-Year Accessibility Plan Page 3
4. Definitions Below is a list of definitions in alphabetical order, which can be found throughout this document: Accessible Formats may include, but are not limited to, large print, recorded audio and electronic formats, braille and other formats usable by persons with disabilities. Accommodation means the special arrangement made or assistance provided so that persons with disabilities can participate in the experiences available to persons without disabilities. Accommodation will vary depending on the person s unique needs. Associates refers to TJX Canada employees (Ontario based). Communications means the interaction between two or more persons or entities, or any combination of them, where information is provided, sent or received. Communication Supports may include, but are not limited to, captioning, alternative and augmentative communication supports, plain language, sign language and other supports that facilitate effective communications. IAP means Individualized Accommodation Plan. Information includes data, facts and knowledge that exists in any format, including text, audio, digital or images, which conveys meaning. Internet Website means a collection of related web pages, images, videos or other digital assets that are addressed relative to a common Uniform Resource Identifier (URI) and is accessible to the public. Maintenance of Public Spaces means activities that are intended to keep existing public spaces and elements in existing public spaces in good working order or to restore the spaces or elements to their original condition, examples of which include painting and minor repairs. New Internet Website means either a website with a new domain name or a website with an existing domain name undergoing a significant refresh. Redeployment means the reassignment of employees to other departments or jobs within the organization. Unconvertible means if it is not technically feasible to convert the information or communications. It also means if the technology to convert the information or communications is not readily available. Web Content Accessibility Guidelines means the World Wide Web consortium recommendation, dated December 2008, entitled Web Content Accessibility Guidelines (WCAG) 2.0. TJX Canada: Integrated Accessibility Standard Policies & Multi-Year Accessibility Plan Page 4
5. General Provisions This section covers the general requirements of the Integrated Accessibility Standards Regulation (IASR). 5.1 Multi-Year Accessibility Plan This Multi-Year Accessibility Plan outlines a phased-in strategy to prevent and remove barriers and addresses the current and future requirements of the AODA. TJX Canada will report annually on the progress and implementation of this plan, post the information on our website and will provide it in alternative formats upon request. This plan will be reviewed and updated at least once every five years. 5.2 Training TJX Canada will ensure training is provided on the requirements of the accessibility standards referred to in the Regulation and in the Human Rights Code as it pertains to persons with disabilities. This training will be provided to all Ontario based Associates initially, including volunteers, and third party contractors, who provide goods and services on TJX Canada s behalf, as well to those who develop the Organization s policies. Our plan is to train nationally as soon as practicable. If any changes are made to this policy or the requirements, additional training will be provided. TJX Canada will maintain a record of the dates when training is provided and the number of individuals who were trained. Required Legislative Compliance Date: January 1, 2015 6. Information and Communications Standard TJX Canada will create, provide and receive information and communications in ways that are accessible to people with disabilities. If TJX Canada determines it is not feasible to convert the information or communications or that the technology to convert the information or communications is not readily available, an explanation will be provided as to why the information or communications are unconvertible. TJX Canada: Integrated Accessibility Standard Policies & Multi-Year Accessibility Plan Page 5
6.1 Accessible Emergency Information TJX Canada has implemented the following as it relates to accessible emergency information: Emergency procedures and public safety information prepared by TJX Canada are available in accessible formats and with appropriate communication supports, upon request. Associates trained on emergency procedures are available to support those who require assistance during emergency situations. All Associates complete annual Emergency Preparedness Training. Required Legislative Compliance Date: January 1, 2012 Completion Date: January 1, 2012 6.2 Feedback, Accessible Formats and Communication Supports TJX Canada has a policy and process in place for receiving and responding to feedback and will ensure that those processes are provided in accessible formats and with communication supports upon request. In accordance with the IASR, TJX Canada will consult with the person making the request and determine suitability of an accessible format or communication support. This will be done in a timely manner and at no additional cost (reasonably). Required Legislative Compliance Date: Feedback - January 1, 2015 Accessible Formats & Communication Supports Compliance Date: January 1, 2016 Completion Date: January 1, 2012 6.3 Website Accessibility TJX Canada shall take the following steps to make its internet website and web content conform with the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0 initially at Level A and increasing to Level AA: Ensure that any web content developed internally or externally meets the Information and Communication Standard and that content developers/vendors have the necessary expertise to develop such content. Ensure that by January 1, 2021 all internet website and web content backdated to 2012 conforms with WCAG 2.0 Level AA. TJX Canada: Integrated Accessibility Standard Policies & Multi-Year Accessibility Plan Page 6
Required Legislative Compliance Date: New Content (WCAG 2.0 Level A) January 1, 2014 All Content (WCAG 2.0 Level AA), except for exclusions set out in the IASR - January 1, 2021 Completion Date: New content January 1, 2014. All content in progress. 7. Employment Standard TJX Canada is committed to fair and accessible employment practices. The Employment Standard builds upon the existing requirements under the Ontario Human Rights Code in relation to how accessibility throughout the entire employment cycle is provided. 7.1 Recruitment TJX Canada shall notify Associates and the public about our accommodation policies and the availability of accommodations for applicants with disabilities throughout the selection process. If a selected applicant requests accommodation, TJX Canada shall consult with the applicant and provide or arrange for the provision of a suitable accommodation that takes into account the applicant s disability. Required Legislative Compliance Date: January 1, 2016 7.2 Associate Notification TJX Canada will review and, as necessary, modify existing orientation and on-boarding processes to ensure new Associates are provided information about TJX Canada s accessibility policies as soon as practicable after employment commences, including a description of same in new hire information. In addition, TJX Canada will develop and integrate procedures for documenting changes to accessibility policies. Required Legislative Compliance Date: January 1, 2016 TJX Canada: Integrated Accessibility Standard Policies & Multi-Year Accessibility Plan Page 7
7.3 Accessible Formats and Communication Supports Upon request, TJX Canada will consult with an Associate, who has a disability, to provide or arrange for the provision of accessible formats and communication supports as outlined below: Information that is needed in order to perform the Associate s job. Information that is generally available to Associates in the workplace. Required Legislative Compliance Date: January 1, 2016 7.4 Individual Accommodation Plan (IAP) and Return to Work TJX Canada will take the necessary steps to develop and implement a process for documenting and updating, as required, Individual Accommodation Plans and Return to Work Plans. In addition, TJX Canada will continue to develop and provide appropriate training to Managers and Associates responsible for supporting both the Individualized Accommodation Plan and Return to Work Plan processes on a continuous basis. Required Legislative Compliance Date: January 1, 2016 7.5 Performance Management, Career Development, and Redeployment TJX Canada will ensure the following steps: Review internal policies and procedures to ensure they are in compliance with the IASR, in particular as it relates to performance management, career development and redeployment processes to ensure the accessibility needs and individual accommodation plans of Associates with disabilities are taken into account. Develop and provide appropriate training to Managers and other Associates responsible for supporting or impacting performance management, career development, and redeployment processes, and a training schedule for same that will ensure compliance with the processes on a continuous basis. Required Legislative Compliance Date: January 1, 2016 TJX Canada: Integrated Accessibility Standard Policies & Multi-Year Accessibility Plan Page 8
7.6 Workplace Emergency Response Information TJX Canada shall provide / review individualized workplace emergency response information for Associates who have a disability: i. If the disability is such that the individualized information is necessary and the employer is aware of the need for accommodation due to the Associate s disability. ii. iii. iv. If the Associate who receives individual workplace emergency response information requires assistance and with the Associate s consent, TJX Canada shall provide the workplace emergency information to the person designated by TJX Canada to provide assistance to the Associate. As soon as practicable after becoming aware of the need for accommodation due to the Associate s disability. When the Associate moves to a different location in the Organization; when overall accommodation needs or plans are reviewed; and when the employer reviews its general emergency response policies. Required Legislative Compliance Date: January 1, 2012 Completion Date: January 1, 2012 8. Public Spaces TJX Canada shall incorporate accessibility into public spaces on its premises that are newly constructed or redeveloped on and after January 1, 2017 as follows: Ensure existing requirements stated under the Design of Public Spaces are adhered to. Provide maintenance and restoration of public spaces by ensuring procedures are in place for preventative and emergency maintenance of accessible elements in public spaces and that procedures are in place for dealing with temporary disruptions when accessible elements required under this section are not in working order. Required Legislative Compliance Date: January 1, 2017 Completion Date: In Progress 9. Contact TJX Canada welcomes feedback about this plan or how it provides goods or services to persons with disabilities. Members of the public may communicate in the manner deemed most convenient to them, including in person, by telephone, in writing, via Teletypewriter (TTY), or by email or other electronic format. TJX Canada: Integrated Accessibility Standard Policies & Multi-Year Accessibility Plan Page 9
Feedback or request for documents available in alternative formats can be made through our Customer Service department: TJX Canada Customer Services Department 6715 Airport Road Mississauga, Ontario L4V 1Y2 Email: cservice_department@tjxcanada.ca; Phone: 1-800-646-9466; Fax: 905-405-2384 TJX Canada: Integrated Accessibility Standard Policies & Multi-Year Accessibility Plan Page 10