Accessibility

Purpose

BentallGreenOak (Canada) Limited Partnership ("BGO") is committed to providing excellent service and accessibility to our employees and 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 BGO can achieve service and employment excellence for people with disabilities in accordance with various provincial and federal legislation in Canada.

Scope

The scope of this policy includes our commitment to accessibility in our employment and customer service standards.

Employment Standard

BGO is committed to providing a respectful, welcoming and inclusive environment to all our employees with disabilities. Our employment standards will incorporate best practice and regulatory requirements throughout the employment experience.

Customer Service Standard

Working closely with the building owners, BGO 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 BGO.

Definitions

Barrier

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.

Disability

For the purpose of this policy, the term "disability" includes:

1. 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 coordination, 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,
2. a condition of mental impairment or a developmental disability;
3. a learning disability, or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language;
4. a mental disorder; or
5. an injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997.

Employee

For the purposes of this policy, the term "employee" refers to any person regarding whom BGO 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.

Service Animal

For the purposes of this policy, an animal is a service animal for a person with a disability if:

1. it is readily apparent that the animal is used by the person for reasons relating to his or her disability; or
2. the person provides a letter from a physician or nurse confirming that the person requires the animal for reasons relating to the disability.

Support Person

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.

Policy Statement - Customer Service Standard

BGO 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.

Communication

When communicating with persons with a disability, BGO employees will take into account the particular individual's needs and circumstances upon request. All communication will be provided in a manner that respects the dignity and independence of persons with disabilities.

Assistive Devices

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 upon request.

Telephone Services

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.

Billing

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.

Service Animals

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.

Support Persons

We welcome persons with disabilities who are accompanied by an identified 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

BGO will ensure that all employees, agents and third parties who interact with customers on its behalf receive customer service training as required to meet service standards and regulatory requirements. This 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:

1. An overview of the regulatory requirements for Customer Service and Human Rights Code standards in the provision of services to people with disabilities;
2. Training on how to interact and communicate with people with various types of disabilities;
3. 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;
4. Training on how to use equipment or assistive devices available or otherwise provided by BGO that may help with the provision of goods or services to a person with a disability;
5. Training on what to do if a person with a disability is having difficulty in accessing our services;

Policy Statement - Employment Standard

BGO is committed to providing accessible employment to people with disabilities in a manner consistent with the principles of dignity, independence, integration and equal opportunity.

Recruitment, Assessment & Selection and at Hiring

BGO will notify its employees and the public about the availability of accommodation for applicants with disabilities in its recruitment, assessment and selection processes. If a request is made, the applicant will be consulted and provision of a suitable accommodation will be provided or arranged in a manner that takes into account the applicants accessibility needs due to disability.

Informing Employees of Supports

We will inform our employees of our policies to support our employees with disabilities that will include the provision of job accommodation due to a disability. Employees will also be provided updated information whenever there is a change to existing policies on job accommodation. For new employees we will provide this information as soon as practicable.

Accessible Formats and Communication Supports for Employees

When an employee with a disability so requests it, BGO will consult with the employee to provide or arrange for the provision of accessible formats and communication support for information that is needed for the employee to do their job, for information that is readily available to employees in the workplace and consult with the employee making the request to determine the suitability of the accessible format or communication support.

Performance Management

For the purpose of this policy, "Performance Management" is defined as activities related to assessing and improving employee performance, productivity and effectiveness, with the goal of facilitating employee success.

Performance Management processes at BGO will take into account the accessibility needs of employees with disabilities and individual accommodation plans, if applicable, in respect of employees with disabilities.

Career Development and Advancement

For the purposes of this policy, "Career Development and Advancement" includes providing additional responsibilities within an employee's current position and the movement of an employee from one job to another in BGO that may be higher in pay, provide greater responsibility or be at a higher level in BGO, or any combination of them. The additional responsibilities and employee movement will usually be based on merit or seniority or a combination.

In providing Career Development and Advancement to employees with disabilities as well as any individual accommodation plans.

Redeployment

For the purposes of this policy, "Redeployment" is defined as the reassignment of employees to other departments or jobs within BGO as an alternative to layoff, when a particular job or department has been eliminated by BGO.

If redeployment of an employee with a disability is required, BGO will take into account the accessibility needs and the individual accommodation plan of the employee

Workplace Emergency Response Information

BGO will provide individualized workplace emergency response information to employees who have a disability, if the disability is such that the individualized information is necessary and the employer is aware of the need for accommodation due to the employee’s disability. Any employee who requires a Workplace Emergency Response Information Plan is required to request one.

Consent of the employee is required prior to BGO sharing workplace emergency response information with the person designated by the employer to provide assistance to the employee, Once consent is received, BGO shall provide the workplace emergency response information to the person designated to provide emergency assistance.

This information will be kept current as the employees overall needs for accommodation is changed and as BGO reviews its general emergency response policies.

Documented Individual Accommodation Plans

BGO has developed a written process for the development of individual accommodation plans, if required, for employees with disabilities.

All requests for workplace accommodation due to disability will be taken seriously. Each request will be considered individually and on a case-by-case basis when determining appropriate and reasonable accommodation measures. The principles of independence, dignity, integration and equality of opportunity will be applied throughout the process. All parties are expected to share in the responsibility of working together towards accommodation solutions.

Process for Development of Individual Accommodation Plans

1. The need for accommodation on account of disability may arise in many ways. All requests for accommodation and/or requests for an individual accommodation plan should be directed to the employee's manager or their People and Talent Business Partner.
2. Once a request for accommodation and/or a request for an individualized accommodation plan is received, the employee will be required to provide appropriate medical documentation to BGO, if this has not already been provided. All requests for accommodation must be supported by appropriate medical documentation which includes the following:
   1. confirmation that the employee has a disability that interferes with his or her ability to do the job or otherwise impacts his or her ability to fully participate in the workplace;
   2. the specific restrictions and limitations that need to be accommodated; and
   3. the anticipated duration of the accommodation.
   The appropriate medical documentation does not require the employee to disclose the specific diagnosis or ailment. The appropriate medical documentation only requires that the employee disclose those aspects of the disability as far as they are related to accommodation and job performance.
3. If additional medical information is required, BGO will provide the employee with a written request for further information from the employee's doctor, medical specialist or other health care provider.
   
   BGO may also require an evaluation by an outside medical or other expert to determine if and how accommodation can be achieved. If such evaluation is requested, the employee will be asked to provide written consent to allow the release of information to BGO. The costs associated with obtaining the evaluation will be covered by BGO.
4. The employee's manager will be informed about the employee's request for accommodation, the employee's limitations, restrictions and accommodation needs. No medical information will be shared with the employee's manager beyond that information which may be reasonably necessary to provide the accommodation.
5. The employee, his or her manager and other BGO management will work together to make reasonable efforts to identify appropriate accommodation measures that will enable the employee to fulfill the essential duties of the job.
   
   During this process, it will also be determined whether the employee requires individualized workplace response information as a result of the disability. If workplace response information has already been completed for the employee, the plan will be reviewed and revised as required. The persons who have been designated to provide assistance in an emergency will be notified.
6. An accommodation meeting involving the employee and the employee's manager will be held to discuss the restrictions and limitations, the accommodation options, the duration of the accommodation, and any other issues that may impact on the success of the accommodation, as well as to cooperatively develop an accommodation plan.
   
   As required by the AODA, the employee can request the participation of a representative from the workplace to assist in the development of the accommodation plan. The decision regarding such request shall be at the sole discretion of BGO.
   
   It will be understood by all parties that while many accommodation measures may be canvassed, no accommodation measure will be implemented which may result in undue hardship to BGO.
7. Once the appropriate accommodations have been determined, a written accommodation plan outlining the nature of the accommodations, the accommodations agreed upon, information regarding accessible formats and communications supports (if applicable) and individualized workplace emergency response information (if applicable) will be prepared. The plan will be signed by the employee and the employee's manager. All employees for whom an individual accommodation plan is developed will receive a copy of the plan in writing or in an alternate format that takes into account his or her accessibility needs due to the disability.
8. Once the plan is in place, the employee and his or her manager are responsible for ensuring that the measures outlined in the accommodation plan are implemented.
9. It is important that individual accommodation plans remain effective and up-to-date. As such, the employee and/or manager may request a review or revision to the accommodation plan. Individual accommodation plans will be reviewed and updated as follows:
   1. Individualized accommodation plans should be reviewed at least once annually and/or if any of the following occurs:
      • An employee changes his or her job within BGO.
      • The employee's accommodation needs change.
      • BGO's policies and practices change.
      • The employee is transferred to a different work location or department.
      • The employee's job responsibilities change.
   2. The employee's manager will conduct ongoing monitoring and assessment of the accommodation plan during the period of accommodation. Employees with individual accommodation plans are encouraged to raise any issues with the accommodation plan to their managers as issues arise.
   3. BGO may request updated medical information from time-to-time to ensure that the restrictions or limitations have not changed to support ongoing accommodations. Plans may require amendment based on such revised medical information.
   4. If the accommodation plan is no longer appropriate, the employee and his or her manager will work together to gather relevant information and reassess the employee's needs and modify or end the individual accommodation plan.
10. There are some circumstances in which an accommodation request may be denied. For example, a denial may occur if there is no measure for accommodation available or all possible accommodation measures would result in undue hardship for BGO. In the event that an accommodation request is denied, the employee will be provided with written documentation outlining the reasons for the denial. In the event that the accommodation or any part thereof is denied, reasons for the denial will be provided in an alternate format that takes into account the employee's accommodation needs upon request.

At all times during the process, steps will be taken to protect the privacy of the employee's personal information. Documents will be kept in a secure location. With the exception of sharing information with the employee's manager and senior management at BGO in order to develop or implement the individual accommodation plan, no information will be shared without the prior written consent of the employee.

Return to Work Process

BGO is committed to providing an accessible working environment for its employees. As part of this commitment, and in accordance with BGO's responsibilities under the AODA, BGO has developed a written process for the return to work of employees who have been absent from work due to a disability and require disability-related accommodations in order to return to work.

In order to facilitate the return to work of employees who were absent because their disability required them to be away from work or because they need some form of disability-related accommodation to return to work, BGO will follow the following process:

1. The return to work process will be initiated when BGO receives notification that the employees is ready to return to work.
2. Notification regarding the return to work requirements for employees who were absent from work due to disability-related needs must be received prior to the employee's return to the workplace.
3. Any recommendations regarding the return to work will be reviewed by BGO. If clarification on the requirements is required, such clarification will be sought from the appropriate source.
4. The employee and the employee's manager will work together to create a return to work plan which will be included in the employee's individual accommodation plan, if applicable.
5. The employee and the employee's manager will monitor and assess the effectiveness of the return to work plan on an ongoing basis until the plan is complete. If issues arise with the plan, it will be modified to address ths issues.

Feedback on Accessibility Practices

We welcome questions and feedback about how we deliver services to people with disabilities. Customers and Employees can submit feedback and questions in person, at the building in question or by email, in writing or by any other means, to the People and Talent Team at BGO.

BGO
People and Talent Team
1 York Street, Suite 1100
Toronto, ON, M5J 0B6

Telephone: +1-416-681-3400
Fax: +1-416-681-3418
Email: PeopleAndTalentTeam@bentallgreenoak.com

If the feedback raises serious concerns with respect to the delivery of services or employment practices 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.

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 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 and employment standards that respect and promote the dignity and independence of people with disabilities. All BGO 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 Managing Director and Co-Head, People and Talent is responsible for this policy. The People and Talent Team will provide advice and assistance in the interpretation and administration of this policy.

Appendix A: Multi-Year Accessibility Plan

Scope

This Multi-Year Accessibility Plan aligns to the requirements for Ontario's AODA (Accessibility for Ontarians with Disabilities Act).

Statement of Commitment

BGO 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

BGO 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.

Training

BGO will provide training to Ontario employees to meet the requirements of Ontario's accessibility laws and 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.

BGO has taken and will continue taking the following steps to ensure Ontario employees are provided with the training needed to meet Ontario's accessible laws:

1. Training as it relates to accessibility and the Human Rights Code will be provided to all Ontario staff members through an online format or other strategy as needed.
2. All existing employees will be required to complete this training.
3. New employees to BGO will be required to complete this training, as they are hired.

Information and Communication

BGO is committed to meeting the communication needs of people with disabilities.

BGO has taken and will continue taking the following steps to ensure existing feedback processes are accessible to people with disabilities in Ontario upon request:

1. Upon request, we will administer our feedback processes in accessible formats and make communication supports available.

BGO has taken and will continue taking the following steps to make sure all publically available information in Ontario is made accessible upon request:

1. Upon request, we will provide information and communications in accessible formats and with communication supports to people with disabilities in a timely manner.

BGO has taken and will continue taking the following steps to make all websites and content conform to WCAG 2.0, Level AA:

1. 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, meets the WCAG 2.0 Level AA standard.

Employment

BGO is committed to fair and accessible employment practices.

We have taken and will continue taking the following steps to notify the public and staff that, when requested, BGO will accommodate people with disabilities during the recruitment and assessment processes and when people are hired:

1. 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 BGO.

BGO has taken and will continue taking the following steps 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:

1. A standard template for the development of individual accommodation plans and return-to-work programs will be developed by Human Resources.

We have taken and will continue taking 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:

1. 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

BGO 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:

1. Recreational trails/beach access routes
2. Outdoor public eating areas like rest stops or picnic areas
3. Outdoor play spaces, like playgrounds in provincial parks and local communities
4. Outdoor paths of travel, like sidewalks, ramps, stairs, curb ramps, rest areas and accessible pedestrian signals
5. Accessible off street parking
6. Service-related elements like service counters, fixed queuing lines and waiting areas

BGO 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.

In accordance with the AODA legislation, this Multi-Year Accessibility Plan will be updated once every five years.

This document is available to the public and in alternate format and accessible communication supports upon request.

Multi-Year Accessibliity Plan Revised: June 14, 2022