Tonal
Accessibility Policy

Last Updated: February 2021

The purpose of this document is to affirm the commitment of Tonal Systems Canada, ULC (“Tonal”) to meet the diverse needs of people with disabilities and to set forth our policy and multi-year accessibility plan for compliance with the requirements of the Integrated Accessibility Standards (the “IAS”) under the Accessibility for Ontarians with Disabilities Act, 2005 (the “AODA”). Tonal has also implemented a separate policy dealing with the Customer Service Standards under Part IV.2 of the IAS detailed in section two of this document.

PART 1 – Integrated Accessibility Standards Policy Statement of Commitment and Multi-Year Accessibility Plan

1. DEFINITIONS

“ Accessible formats ” includes, but is not limited to, large print, recorded audio and electronic formats, Braille and other formats usable by persons with disabilities.

“ Barriers ” means any obstacle that impedes or prevents a person with a disability from fully participating in all aspects of society and includes, but is not limited to, attitudinal barriers, information or communications barriers, technological barriers, organizational barriers, and architectural and/or physical barriers.

“ Communication supports ” includes, but is not limited to, captioning, alternative and augmentative communication supports, plain language, sign language and other supports that facilitate effective communications.

“ Disability ” means the corresponding definitions in section 2 of the Accessibility for Ontarians with Disabilities Act, 2005 and section 10(1) of the Ontario Human Rights Code , which include the followings impairments, conditions and disorders:

(a) 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 impairment, muteness or speech impediment, or physical reliance on a guide dog or other animal or on a wheelchair or other remedial appliance or device,

(b) a condition of mental impairment or a developmental disability,

(c) a learning disability, or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language,

(d) a mental disorder, or

(e) an injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997 .

2. STATEMENT OF COMMITMENT

Tonal is committed to meeting the diverse needs of people with disabilities in a timely manner that is consistent with the principles of independence, dignity, integration and equality of opportunity, and will do so by striving to identify, prevent and remove barriers to accessibility wherever possible as well as by meeting the accessibility requirements under the AODA.

3. SCOPE

This policy applies to all Ontario-based staff of Tonal and its affiliates and subsidiaries. The policy – with the exception of the “Employment Requirements” set out under section 5, part (iii) – also applies to all Ontario-based volunteers of Tonal as well as all non-Ontario-based staff and volunteers of Tonal’s affiliates and subsidiaries that deal with members of the public or other third parties in Ontario on behalf of Tonal (if applicable).

4. MULTI-YEAR ACCESSIBILITY PLAN

Tonal is committed to complying with the accessibility requirements under the IAS and to reviewing and updating our accessibility plan as set out in this policy at least once every 5 years.

The following is a summary of the accessibility requirements under the IAS that apply or may in the future apply to Tonal, and the associated timelines for compliance under the IAS. The summary is intended only as a guide to inform and assist Tonal in our accessibility compliance initiatives, please refer to Tonal’s Multi-Year Accessibility Plan for more detailed information.

(i) GENERAL REQUIREMENTS

SELF-SERVICE KIOSKS

If and when Tonal designs, procures or acquires “self-service kiosks”, we will consider what, if any, accessibility features could be built into the kiosks to best meet the needs of customers and clients with disabilities – having regard to the accessibility needs, preferences and abilities of the widest range of users – and we will strive to include accessibility features in the self-service kiosks being designed, procured or acquired where possible.

A “self-service kiosk” means an interactive electronic terminal, including a point-of-sale device, intended for public use that allows users to access one or more services or products or both.

TRAINING

Tonal will ensure that all employees and volunteers in Ontario, and any other persons who provide goods, services or facilities to the public or other third parties in Ontario on behalf of Tonal or who participate in developing Tonal’s policies on the provision of goods, services or facilities to the public or other third parties in Ontario, will receive training on the requirements of the IAS and on the Ontario Human Rights Code as it pertains to persons with disabilities.

Training will be provided in a manner that is appropriate to the duties of the employees, volunteers and other persons, and will be provided as soon as practicable after staff or volunteers commence their duties and on an ongoing basis with respect to any changes to this policy.

Tonal will maintain a record of the training it provides to staff and volunteers, including the dates on which the training is provided and the number of individuals to whom it is provided.

(ii) INFORMATION AND COMMUNICATIONS REQUIREMENTS

NOTE : The following accessibility requirements related to information and communications do not apply to products and product labels, “unconvertible” information or communications, and information that Tonal does not control directly or indirectly through a contractual relationship.

Information and communications are considered “unconvertible” if it is not technically feasible to convert the information or communications, or the technology to do so is not readily available.

Wherever information and communications are determined to be “unconvertible”, Tonal will ensure that the person with a disability who is requesting the information or communication is provided with: (i) an explanation as to why the information or communication is unconvertible; and (ii) a summary of the unconvertible information or communication.

EMERGENCY PROCEDURE, PLANS OR PUBLIC SAFETY INFORMATION

Wherever Tonal prepares emergency procedures, plans or public safety information and makes the information available to the public, we are committed to providing the information in an accessible format or with appropriate communication support as soon as practicable upon request.

ACCESSIBLE WEBSITES AND WEB CONTENT

NOTE: The accessible website and web content requirements apply only with respect to:

(i) Tonal’s websites that are accessible to the public (i.e., excludes intranet websites but includes websites accessible only by customers);

(ii) websites and web content, including web-based applications, that Tonal controls directly or through a contractual relationship that allows for modification of the product; and

(iii) web content published on a website after January 1, 2012.

Tonal will ensure that all “new internet websites and web content” conform with the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0 Level A requirements, except where doing so is not practicable having regard to, among other things, the availability of commercial software or tools or both, and any significant impact on an implementation timeline that was planned or initiated before January 1, 2012.

“New internet websites and web content” means either a website with a new domain name or a website with an existing domain name undergoing a “significant refresh”.

A “significant refresh” means changing more than 50% of the content, design or technology of the website, such as:

(i) creating, rewriting or reorganizing more than 50%of the website’s content, including graphics, text, widgets, etc.;

(ii) changing more than 50% of the design elements, including layout, navigation, placement and style; or
(iii) changing more than 50% of the web publishing platform/model such as the content management system (CMS), Cascading Style Sheet (CSS) or HTML structure.

FEEDBACK

Wherever Tonal has existing processes for receiving and responding to feedback, we will provide or arrange for the provision of accessible formats and communication supports upon request in order to ensure that all such processes are accessible to people with disabilities.

ACCESSIBLE FORMATS AND COMMUNICATION SUPPORTS

Upon request, Tonal will take all reasonable steps to provide or arrange for the provision of accessible formats and communication supports in a timely manner so that people with disabilities can access our publicly available information. In each case, Tonal will take into account the accessibility needs of the person with a disability making the request and will consult with the person to determine the suitability of an accessible format or communication support.

Accessible formats and communication supports will be provided at no additional cost to the person with a disability making the request.

Tonal will notify the public of the availability of accessible formats and communication supports.

ACCESSIBLE WEBSITES AND WEB CONTENT

(iii) EMPLOYMENT REQUIREMENTS

NOTE : The following accessibility requirements apply only in respect of Tonal employees in Ontario and do not apply in respect of volunteers or other non-paid individuals.

WORKPLACE EMERGENCY RESPONSE INFORMATION

Wherever Tonal is aware of the need for individualized emergency response information due to an employee’s disability, we are committed to accommodating the employee by preparing and providing him or her with individualized emergency response information that is suitable in the circumstances.

If the employee with a disability who receives the individualized workplace emergency response information requires assistance and provides his or her consent, Tonal will provide the individualized workplace emergency response information to a person who is designated to assist the employee in case of an emergency.

RECRUITMENT

Tonal will notify the public and our employees in Ontario that, when requested, we will provide accommodation for applicants with disabilities who participate in our recruitment processes.

During the recruitment process, Tonal will notify all job applicants that are selected to participate in an assessment or selection process that we will provide reasonable accommodations, upon request, to a person with a disability in relation to the materials or processes to be used in the assessment or selection process. In any case where an applicant with a disability requests an accommodation, we will consult with the applicant and provide or arrange for the provision of a suitable accommodation in a manner that takes into account the applicant’s accessibility needs due to his or her disability.

As part of all offers of employment, Tonal will notify successful job applicants of our policies for accommodating employees with disabilities.

INFORMING EMPLOYEES OF DISABILITY-RELATED SUPPORTS

Tonal will notify our employees in Ontario of our existing policies in respect of employees with disabilities including, but not limited to, any policies regarding job accommodations that take into account an employee’s accessibility needs due to disability. We will also provide updated information to our employees in Ontario with respect to any changes to our existing policies regarding employees with disabilities and job accommodations for disability-related needs.

All new employees in Ontario will be notified of our existing policies in respect of employees with disabilities and job accommodations for disability-related needs as soon as practicable after beginning their employment.

ACCESSIBLE FORMATS AND COMMUNICATION SUPPORTS FOR EMPLOYEES

Upon request, Tonal will consult with an Ontario-based employee with a disability in order to provide or arrange for the provision of reasonable accessible formats and communication supports for the employee with respect to all: (i) information that is needed by the employee in order to perform his or her job; and (ii) information that is generally available to employees in the workplace.

Tonal will also consult with the employee requesting accessible formats or communication supports to determine the suitability of an accessible format or communication support.

INDIVIDUAL ACCOMMODATION PLANS

Tonal will develop and have in place a written process for the development of documented individual accommodation plans for employees with disabilities that have come to Tonal’s attention, which will include the following elements:

(i) the manner in which an employee requesting accommodation can participate in the development of the individual accommodation plan;

(ii) the means by which the employee is assessed on an individual basis;

(iii) the manner in which Tonal can request an evaluation by an outside medical or other expert, at Tonal’s expense, to assist Tonal in determining if accommodation can be achieved and, if so, how accommodation can be achieved;

(iv) the manner in which the employee can request the participation of a representative from their bargaining agent, where the employee is represented by a bargaining agent, or other representative from the workplace, where the employee is not represented by a bargaining agent, in the development of the accommodation plan;

(v) the steps taken to protect the privacy of the employee’s personal information;

(vi) the frequency with which the individual accommodation plan will be reviewed and updated and the manner in which it will be done;

(vii) if an individual accommodation plan is denied, the manner in which the reasons for the denial will be provided to the employee;

(viii) the means of providing the individual accommodation plan in a format that takes into account the employee’s accessibility needs due to disability;

(ix) if requested, any other information regarding accessible formats and communication supports that the employee requires with respect to information needed by the employee to perform his or her job and any other information that Tonal generally makes available to employees in the workplace;

(x) if required in the circumstances, the individualized workplace emergency response information for the employee;

(xi) and any other accommodations that will be provided to the employee.

RETURN TO WORK PROCESS

Tonal will develop and have in place a documented return to work process for employees in Ontario who have been absent from work due to a disability and who require disability-related accommodations in order to return to work.

The return to work process will outline the steps that Tonal will take to facilitate the return to work of employees who have been absent from work due to disability and will incorporate the use of individual accommodation plans as part of the process.

PERFORMANCE MANAGEMENT, CAREER DEVELOPMENT AND ADVANCEMENT, & REDEPLOYMENT

Wherever Tonal uses “performance management” or “redeployment” in respect of our employees, or provides “career development and advancement” to our employees, we will take into account the accessibility needs of employees with disabilities as well as their individual accommodation plans.

“Performance management” means any activity related to assessing and improving employee performance, productivity and effectiveness, with the goal of facilitating employee success.

“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 within Tonal that may be higher in pay, provide greater responsibility or be at a higher level in the organization, or any combination thereof, and is usually based on merit and/or seniority.

“Redeployment” means the reassignment of employees to other departments or jobs within Tonal as an alternative to layoff, when a particular job or department has been eliminated.

(iv) COMPLIANCE STRATEGY

Tonal believes that our staff and customers are our best resources for assisting us to identify, prevent and remove barriers to accessibility and thereby ensure that the diverse needs of people with disabilities are met or exceeded.

For various reasons, barriers to accessibility can often be difficult to identify. Our staff and customers, including in particular those persons with disabilities, are often in the best position to recognize the existence of any accessibility barriers and their impact on people with disabilities, and to alert Tonal so that we can take appropriate action to prevent or remove the barriers wherever reasonably possible.

Accordingly, Tonal will take the following steps to facilitate the identification, prevention and removal of accessibility barriers wherever it is reasonably possible to do so:

in order to promote an understanding of and appreciation for the accessibility requirements under the IAS, as well as the importance of identifying, preventing and removing barriers to accessibility, Tonal will ensure that all staff in Ontario are provided with a copy of this policy and are encouraged to review the policy and to raise any questions that they may have regarding the policy with Human Resources;

Tonal will encourage, welcome and appreciate all feedback from staff and customers regarding any barriers to accessibility and more generally on how we can best achieve our goal of striving towards a barrier-free environment;

Tonal will take a proactive approach to accessibility wherever reasonably possible by striving to have regard to and incorporating disability-related needs and accessibility issues in general in all aspects of our business and decision-making; and

Tonal will strive to work cooperatively and consult with any person with a disability who brings to our attention an issue or concern regarding accessibility, and we will take all reasonable steps in the circumstances to address the disability-related needs of the individual.

PART 2 – Customer Service Policy Providing Goods, Services and Facilities to People With Disabilities

1. DEFINITIONS

“ Assistive Devices ” means any auxiliary aids, such as communication aids, cognition aids, personal mobility aids and medical aids, that are designed or adapted to assist people with disabilities to perform actions, tasks and activities.

(b) a condition of mental impairment or a developmental disability,

(c) a learning disability, or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language,

(d) a mental disorder, or

(e) an injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997 .

“ Service Animal ” means:

(a) any animal that is used by a person with a disability for reasons relating to his or her disability, or

(b) if it is not readily apparent that the animal satisfies (a), any animal for which a person with a disability provides a letter from a physician, nurse or other applicable regulated health professional confirming that the person requires the animal for reasons relating to his or her disability.

“ Support Person ” means any person, whether a paid professional, volunteer, family member, friend or otherwise, who accompanies a person with a disability in order to assist the person with a disability with communication, mobility, personal care, medical needs or accessing goods, services or facilities.

2. COMMITMENT

Tonal strives at all times to provide its goods, services and facilities in a way that respects the dignity and independence of people with disabilities. We are also committed to giving people with disabilities the same opportunity to access our goods, services and facilities and allowing them to benefit from the same goods, services, and facilities in the same place and in a similar way as other customers.

This policy applies to all staff and volunteers of Tonal and its affiliates and subsidiaries, and all other individuals that deal with members of the public or other third parties in Ontario on behalf of Tonal.

3. PROVIDING GOODS, SERVICES AND FACILITIES TO PEOPLE WITH DISABILITIES

Tonal is committed to excellence in serving all customers (which includes the employees of customers) including people with disabilities and we will carry out its functions and responsibilities in the following areas:

Communication

We will communicate with people with disabilities in ways that take into account their disability.

We will ensure that all individuals who communicate with members of the public or other third parties in Ontario on behalf of Tonal are trained on how to interact and communicate with people with various types of disabilities.

Telephone Services

We are committed to providing accessible telephone services to our customers. We will ensure that all individuals who communicate over the telephone with members of the public or other third parties in Ontario on behalf of Tonal are trained to communicate in clear and plain language and to speak clearly and slowly.

We will offer to communicate with members of the public or other third parties in Ontario by email or mail if telephone communication is not suitable to their communication needs or is not available. We will also strive to accommodate the needs of individuals who prefer to communicate with us in another format.

Assistive devices

We are committed to serving people with disabilities who use assistive devices to obtain, use or benefit from our goods, services and facilities. We will ensure that all individuals who deal with members of the public or other third parties in Ontario on behalf of Tonal are trained and familiar with various assistive devices that may be used by people with disabilities while accessing our goods, services and facilities.

It is our policy to allow individuals to use their personal assistive devices, including, but not limited to, wheelchairs, walkers, white canes, oxygen tanks, portable chalkboards and electronic communication devices, to access our goods, services and facilities.

We will also strive to offer alternative service methods to people with disabilities, such as assistance by an employee to complete a transaction and delivery of goods, services or facilities in another location. If customers desire alternate service methods, please direct their inquiry to the Account Manager handling the customer’s account.

Billing

We are committed to providing accessible invoices to all of our customers. For this reason, invoices will be provided in the following formats upon request: hard copy, large print, and email/electronic. We will also strive to accommodate customers that request invoices in formats that are not previously mentioned.

4. USE OF SERVICE ANIMALS AND SUPPORT PERSONS

We are committed to welcoming people with disabilities who are accompanied by a service animal on the parts of our premises that are open to the public and other third parties, except for those premises where the animal is otherwise excluded by law in which case we will ensure that other measures are available to enable the person with a disability to access our goods, services or facilities. We will also ensure that all staff, volunteers and others dealing with the public are properly trained in how to interact with people with disabilities who are accompanied by a service animal.

We are committed to welcoming people 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 enter our premises with his or her support person. At no time will a person with a disability who is accompanied by a support person be prevented from having access to his or her support person while on our premises.

5. NOTICE OF TEMPORARY DISRUPTION

We will provide the public with notice in the event of a planned or unexpected disruption in the facilities or services in Ontario usually used by people with disabilities. This notice will include information about the reason for the disruption, its anticipated duration, and a description of alternative facilities or services if available.

The notice will be placed at all public entrances on our premises in Ontario.

6. TRAINING FOR STAFF

We will ensure that all employees and volunteers, and others who deal with the public or other third parties in Ontario on our behalf, and all those who are involved in the development and approvals of customer service policies, practices and procedures, receive the training required by the Customer Service Standards under Part IV.2 of the Integrated Accessibility Standards .

This training will be provided as soon as practicable after staff commence their duties.

Training will include the following:

The purpose of the Accessibility for Ontarians with Disabilities Act, 2005 and the requirements of the customer service standard
How to interact and communicate with people of 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
How to use any assistive devices that Tonal Canada makes available on its premises or otherwise to assist with the provision of goods, services and facilities to people with disabilities.
What to do if a person with a disability is having difficulty in accessing Tonal’s goods, services and facilities
Tonal’s policies, practices and procedures relating to the customer service standard.

Applicable staff will be trained on policies, practices and procedures that affect the way goods, services and facilities are provided to people with disabilities. Staff will also be trained on an ongoing basis when changes are made to these policies, practices and procedures.

7. FEEDBACK PROCESS

The ultimate goal of Tonal is to meet the expectations of people with disabilities who seek to access Tonal’s goods, services and facilities. Comments on our services or facilities regarding how well those expectations are being met are welcome and appreciated.

Feedback regarding the way Tonal provides goods, services and facilities to individuals with disabilities can be made by telephone, email, in writing or by submitting an audio recording or electronic text on diskette at:

accessibility@tonal.com

We will also strive to accommodate the needs of people with disabilities who prefer to provide feedback in another format or by different means than those listed above.

Each situation will be assessed on a case-by-case basis and Tonal will take appropriate measures, if warranted, in the circumstances.

8. 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. Therefore, no changes will be made to this policy before considering the impact on people with disabilities. Any policy of Tonal that does not respect and promote the dignity and independence of people with disabilities will be modified or removed.

9. Requesting Documents in Accessible Formats

This policy and other documents referred to in this policy are available in multiple accessible formats upon request. The accessible formats include: hard copy, large print, email/electronic, and fax. We will also strive to accommodate customers that request invoices in formats that are not previously mentioned.

QUESTIONS ABOUT THIS POLICY

This policy exists to achieve service excellence to customers with disabilities. All questions regarding this policy, including with respect to the steps that Tonal intends to take in order to comply with its requirements under the IAS, should be referred to:

accessibility@tonal.com

Tonal Accessibility Policy

PART 1 – Integrated Accessibility Standards Policy Statement of Commitment and Multi-Year Accessibility Plan

1. DEFINITIONS

2. STATEMENT OF COMMITMENT

3. SCOPE

4. MULTI-YEAR ACCESSIBILITY PLAN

(i) GENERAL REQUIREMENTS

(ii) INFORMATION AND COMMUNICATIONS REQUIREMENTS

(iii) EMPLOYMENT REQUIREMENTS

(iv) COMPLIANCE STRATEGY

PART 2 – Customer Service Policy Providing Goods, Services and Facilities to People With Disabilities

1. DEFINITIONS

2. COMMITMENT

3. PROVIDING GOODS, SERVICES AND FACILITIES TO PEOPLE WITH DISABILITIES

4. USE OF SERVICE ANIMALS AND SUPPORT PERSONS

5. NOTICE OF TEMPORARY DISRUPTION

6. TRAINING FOR STAFF

7. FEEDBACK PROCESS

8. MODIFICATIONS TO THIS OR OTHER POLICIES

9. Requesting Documents in Accessible Formats

QUESTIONS ABOUT THIS POLICY

Tonal
Accessibility Policy