Sinclair Dental Co. Ltd. (“Sinclair”) is committed to treating all people in a way that allows them to maintain their dignity and independence. Sinclair believes in integration and equal opportunity and is committed to meeting the needs of people with disabilities in a timely manner. Sinclair will do this by preventing and removing barriers to accessibility and meeting the required Provincial Accessibility Act, legislation and/or standards, including the Accessibility for Ontarians with Disabilities Act (“AODA”) where ever possible.

Sinclair is committed to fair and accessible employment practices across all stages of the employment cycle. Sinclair will take the necessary steps to meet the requirements of the Integrated Accessibility Standards Regulations (IASR), relating to recruitment, individual accommodation plans, return to work processes, performance management and career development.

Sinclair's commitment to this is demonstrated in the following areas:

• Communication: Sinclair will communicate in ways that take into account the needs of persons with disabilities.
• Assistive devices: Sinclair is committed to serving persons with disabilities who use assistive devices to obtain, use or benefit from our services. Our frontline employees who deal directly with customers and visitors are trained and familiar with various assistive devices.
• Service Animals: Sinclair welcomes people with disabilities and their service animals. Service animals are allowed on the parts of our premises that are open to the public.
• Support Persons: A person with a disability who is accompanied by a support person will be allowed to have that person accompany them on our premises.
• Accessibility Emergency Information: Sinclair is committed to providing our customers with publicly available emergency information in an accessible way upon request. Sinclair also provides employees with disabilities with individualized emergency response information when necessary.
• Employment: Sinclair is committed to fair and accessible employment practices. Sinclair will take steps to notify its employees and members of the public that, when requested.
• Training: Sinclair will provide training to employees who deal with the public. This training will be provided to employees within their first 3 months of employment.

Human Resource Department will be responsible for implementing and administering this policy.

Scope

This policy applies to all employees of Sinclair who interact with Sinclair’s current and prospective employees, agents, customers, clients, suppliers, and any other users of Sinclair’s services (“General Public”)..

Definitions

“Accessibility”: Can be viewed as the "ability to access" and benefit from some system or entity. The concept focuses on enabling access for people with disabilities, or enabling access through the use of assistive technology.

“Accessible formats”: Refers to formats that are alternative to standard print and are accessible to people with disabilities, such as large print, braille, DVDs and audio formats.

“Accommodation”: Where it is impossible to remove barriers without undue hardship, special arrangements so that persons with disabilities can fully participate within the required job duties or while in the workplace.

“Barrier”: Anything that prevents a person with a disability from fully participating in all aspects of society because of his or her disability”. In other words, barriers happen when places and activities that all people should have access to are designed in ways that limit this access.

“Communication supports”: Refers to methods that assist communication and access to information for people with disabilities. Examples include plain language formats, sign language, reading out loud, captioning or using written notes to communicate.

“Disability”: Long-term physical, mental, intellectual or sensory impairments which in interaction with various barriers may hinder a person’s ability to fully and effectively participate in society on an equal basis with others. All applicable provincial definitions are deemed to be reflected in this policy and are considered disability.

“Integrated Accessibility Standards Regulation (IASR)”: Establishes accessibility standards and introduces requirements for Information and Communications, Employment and Transportation. The Integrated Accessibility Standards Regulation also establishes the compliance framework for obligated Organizations.

“Provincial Legislation”: Are a set of laws and regulations referred to as legislation. These laws and regulations have been passed by both the federal and provincial governments together. An example of provincial legislation is the Accessibility for Ontarians with Disabilities Act, reflected in this policy.

“Supervisor”: An employee of Sinclair responsible for the productivity and actions of a group of Workers and are directly responsible for the health and safety of the Workers they direct or supervise (i.e. Team Lead, Supervisor, Manager, Vice President).

“Web Content Accessibility Guidelines (WCAG)”: Refers to Web Content Accessibility Guidelines, which are published by the World Wide Web Consortium's (W3C) Web Accessibility Initiative (WAI). The Web Content Accessibility Guidelines (WCAG) 2.0 provide recommendations for making Web content more accessible.
 

Responsibilities

It is everyone's responsibility to ensure an inclusive environment that respects the dignity and independence of persons with disabilities.

Employer:
It is the responsibility of Sinclair Dental Co. Ltd. to:

• Ensure this policy and the supporting program are implemented;
• Ensure all persons who, on behalf of Sinclair, deal with the public are trained to communicate and provide the best possible customer service to all customers, including persons with disabilities;
• Ensure employees are trained and familiar with various assistive devices that may be used by customers with disabilities who are accessing Sinclair’s’ goods or services;
• Ensure completion of accessibility training is tracked and recorded;
• Ensure customers and other third parties who are accompanied by service animals or support persons in areas of Sinclair that are open to the public are accommodated;
• Welcome customer feedback to improve the accessibility of products and services through multiple communications channels; and
• Ensure information is added to Sinclair’s website to communicate its accessible customer service policies

Supervisors:
It is the responsibility of the Supervisors to:

• Ensure an inclusive work environment in accordance for the Respectful Workplace policy;
• Deploy reasonable accommodation based on guidelines provided by Human Resources;
• Attend training related to this policy and its related accommodation and emergency plans;
• Ensure this policy is properly enforced and communicated to all Employees, and that members of their team who request accommodation are accommodated appropriately;
• Ensure employees have received trained on this policy and where appropriate have received the customer standards training;
• Participate with the Human Resources department on the development of an individual accommodation and/or emergency response plan upon request from employee;
• Ensure all required accommodations are in place prior to employee start, or upon completion of an individual accommodation and/or emergency response plan; and
• Review the individual accommodation and/or emergency response plan as needed with the employee

Human Resources Department:
It is the role of the Human Resources Department to:

• Ensure any new policies or changes to this policy are developed or updated so as to respect and promote the dignity and independence of persons with disabilities;
• Develop and provide adequate training materials associated with this policy and the Provincial legislative requirements on Accessibility;
• Facilitate the feedback process to members of the public and employees upon receipt of request;
• Facilitate the assessment and determination of a reasonable accommodation;
• Assess the medical information provided by the employee; and
• Facilitate with the development of the individual accommodation and/or emergency response plan;

Employees:
It is the responsibility of the Employees to:

• Acknowledge and comply with this policy and related procedures;
• Act respectfully towards other individuals while at work and while participating in any work-related activity in accordance with the Respectful Workplace policy;
• Inform their Supervisor or the Human Resources department if they require accommodation;
• Provide medical information where requested to facilitate an individual accommodation plan or emergency response plan;
• Work cooperatively with their Supervisor and the Human Resources department with the goal of finding reasonable accommodation and the development of an individual accommodation and/or individual emergency response plan;
• Inform their Supervisor or the Human Resources department if any modifications are required to their individual accommodation or emergency response plan; and
• Attend training and related activities.

Procedure

General Public Accessibility Standards

Sinclair is committed to excellence in serving all customers, including persons with disabilities, and it will carry out its functions in a manner which delivers an accessible customer service experience.

Customers who wish to provide feedback to Sinclair can do so through this feedback process:

• In person at the local Sinclair branch;
• Send an email to Human Resources;
• Send a written letter to Human Resources;
• Online via our website contact us form; or
• Via phone 1-800-663-7393

Human Resources Department
900 Harbourside Drive, North Vancouver BC, V7P 3T8
Email: hr@sinclairdental.com

All feedback, including complaints, will be dealt within a reasonable timeframe. Customers can expect a response within two weeks of receipt of the submission.

Sinclair is committed to providing its goods and services in a way that respects the dignity and independence of persons with disabilities. This commitment will be integrated wherever possible and will ensure that persons with disabilities will benefit from the same services, in the same place and in a similar way as other customers.

Sinclair will provide our customers with publicly available emergency information in an accessible way upon request. Sinclair will provide notice on our website when facilities or services that people with disabilities rely on are temporarily disrupted.
 

Employee Accommodation

Employees can submit a request for accommodation whether permanent or temporary via email or in person to Human Resources or their Supervisor. The request should include:

• A description of the limitation on the employee’s ability to perform the duties of their position caused by the disability;
• Description of any accommodation(s) sought; and
• Provide sufficient information to confirm the existence of a need for accommodation (such as a medical certificate).

If an employee is under a program of medical treatment which requires the consumption of prescription drugs, including medical marijuana, or over-the-counter drugs which are labelled or known to cause impairment, the employee is required to inform his or her manager about the program immediately so that the risk of impairment relative to the employee’s safe job performance can be considered.

Where Sinclair is aware that an employee has a disability and that there is a need for accommodation, individualized workplace emergency response information will be provided to the employee as soon as practicable if such information is necessary given the nature of the employee’s disability.

As per the Return to work procedures in the Incident Process, Sinclair will accommodate employees based on the requirements outlined by a medical professional. A medical note might be requested to get clarity on the employee’s restrictions and accommodation needs.

The following measures have been implemented by Sinclair:

• Workplace Emergency Response Information forms have been prepared for employees who have disclosed a disability and who are being accommodated according to their disabilities. On an ongoing and regular basis, and as per the applicable terms of the Integrated Accessibility Standards Regulation (IASR) Sinclair will review and assess general workplace emergency response procedures and individualized emergency plans to ensure accessibility issues are addressed.
• These individualized emergency plans have been communicated to the employees’ respective supervisors, on an ‘as needed’ basis

Information and Communication

Sinclair is committed to meeting the communication needs of people with disabilities. Sinclair has and will continue to incorporate new accessibility requirements under the information and communication standards to ensure that its information and communication systems are accessible and are provided in accessible formats that meet the needs of people with disabilities.

• Accessible formats and communications supports: If a person with a disability needs an accessible format, or help to communicate with us, Sinclair will work with the person to provide the format or support that will meet their needs — at no additional cost to them. If Sinclair is unable to meet the person's particular requirement in a reasonable timeframe, we will inform them and work with them to determine an alternate method or will provide a summary of the information or reasonable explanation as to why we are unable to provide the requested format.
• Accessible website and web content: Sinclair will take the following steps to make the website and content conform with Web Content Accessibility Guide (WCAG) 2.0, Level AA by January 1, 2021, as required by the AODA:
  • Ensure development of its next generation digital platform for public websites, in-store media and information technology infrastructure meet legal Information and Communication Standards and that partnering vendors have necessary expertise with such technology.
  • Conduct accessibility reviews of web site prior to launch.

Multi-Year Accessibility Plan

As part of Sinclair's commitment to meeting its accessibility obligations, Sinclair has developed a multi-year plan which outlines the strategies to prevent and remove barriers and meet its requirements under the provincial accessibility act, legislations and/or standards in regards to accessibility.

As part of this plan, Sinclair will provide training to employees who deal with the public. This training will be provided to employees within the first 3 months of employment. Training will include:

• An overview of the Accessibility for Ontarians with Disabilities Act (AODA), 2005;
• Sinclair Accessibility Policy;
• How to interact and communicate with people with various types of disabilities;
• How to interact with people with disabilities who use an assistive device or require the assistance of a service animal or a support person; and
• What to do if a person with a disability is having difficulty in accessing Sinclair goods and services

The current multi-Year plan does include but not limited:

• Ensure that appropriate training on the requirements as it pertains to persons with disabilities, is provided to employees.
• Incorporate the training into the employee orientation process for new employees.
• Ensure training is provided, on an ongoing basis, as it relates to any policies that have been revised pursuant to AODA.
• Continue to provide or arrange for the provision of such accessible formats and communication supports.
• Consult with the person making the request to determine the suitability of the accessible format or communication support.
• Continue to work with Vendors to meet the requirements of availability of accessible formats to provide to our customers upon request.
• Define requirements; outline roles and responsibilities in web content and development policies regarding content compliance for a new intranet site if one is found to be feasible for the organization.

Sinclair’s Multi-Year Accessibility Plan will be reviewed and updated by Sinclair at least once every five (5) years, or as required. A copy of the plan will be made available in an accessible format upon request.