Accessibility Policy

The purpose of this Accessibility Policy (this “Policy”) is to be proactive about the inclusion of people with disabilities in our service offerings and to align Definity with legislative requirements, such as the Accessibility for Ontarians with Disabilities Act, The Accessibility for Manitobans Act and corresponding regulations (collectively “Accessibility Legislation”). The purpose of Accessibility Legislation is to benefit all Canadians by developing, implementing and mandating accessibility standards to achieve accessibility with respect to goods, services, facilities, accommodation, employment, buildings, structures, and premises for persons with disabilities.

This Policy applies to Definity and its wholly-owned subsidiaries (collectively “Definity”).

Definity is committed to ensuring the services we provide are as accessible as possible to persons with disabilities, and are compliant with applicable Accessibility Legislation. To fulfil this commitment, Definity has developed inclusive policies and procedures that mirror the standards established by Accessibility Legislation. These policies and procedures will be regularly monitored and reviewed to ensure access and accommodation for all persons with disabilities.

The purpose of this Policy is to:

• identify, remove, and prevent barriers to accessing our services for people with disabilities
• build awareness within the Definity community of the rights of persons with disabilities and our responsibility to foster an accessible and inclusive environment
• provide equal access to services and facilities for all customers
• provide equal opportunity in employment
• monitor the continual improvement of access to our properties, facilities, and services
• define the development, publication, and review of the annual Accessibility Plan
• ensure quality in what and how we deliver services to all members of Definity community
• ensure compliance with applicable Accessibility Legislation

The objective of this Policy is to address the following with respect to service delivery to persons with disabilities:

• the provision of goods and services
• the use of assistive devices
• the use of guide dogs and service animals
• the use of support persons
• receiving customer feedback
• employee training
• notice of availability and format of required documents

Definity supports and promotes the rights of all persons with disabilities. Definity also affirms the rights of all persons, including those with disabilities, to have access to equal opportunity in employment or business dealings with Definity.

Definity strives to provide an accessible environment for all persons with disabilities who interact with us and affirms its commitment to promoting the following principles in all of its policies and interactions with persons with disabilities:

Dignity — Respecting the dignity of a person with a disability means treating them as valued customers, deserving of the same high quality and timely service as any other customer. Persons with disabilities are not treated as an afterthought or forced to accept lesser service, quality, or convenience. The delivery of goods and services must take into account how persons with disabilities can effectively access and use them.

Independence — In some instances, independence means freedom from control or influence of others; freedom to make one’s own choices. In other situations, it may mean the freedom to do things in one’s own way. Definity must allow persons with disabilities to take the time they need, without rushing or taking over a task from a person who prefers to do it themselves.

Integration — The provision of goods or services to persons with disabilities and others must be integrated to allow persons with disabilities to fully benefit from the same services, in the same place, and in the same or similar way as other customers. Integration means that policies, programs, and services, including practices and procedures, are designed to be accessible to everyone.

Equal opportunity — Persons with disabilities must be offered the same chances, options, benefits, and results to obtain, use, and benefit from the goods or services provided by Definity. They should not have to make significantly more effort to access or obtain services, or accept lesser quality of services.

Definity accountabilities

• Ensure all leaders and employees are aware of this Policy and its application
• Hold all leaders and employees accountable for their responsibilities in related program elements and obligations
• Advocate and support accessibility through assigning internal responsibility, and aligning the required resources and behaviours to targeted initiatives, programs, and policies
• Consider accessibility of people with disabilities as part of the regular development and ongoing review of existing policies and practices
• Amend existing policies as needed to comply with Accessibility Legislation

Leader accountabilities

• Communicate this Policy to all employees
• Inform employees of their obligations and accountabilities to adhere to the requirements of this Policy as an element of their work performance and a condition of employment
• Implement, monitor, and evaluate compliance to this Policy in their business unit
• Ensure employees are responding to requests for accommodation in a timely manner
• Ensure all complaints, or identified risks about accessibility, are dealt with in a timely manner

Human resources accountabilities

• Identify, develop, and deliver required training on this Policy
• Review this Policy and procedures related to accessibility on an annual basis
• Monitor developments of the accessibility standards and communicate these developments to the business

Employee accountabilities

• Support the implementation of accessibility standards in the workplace
• Participate in required training related to the accessibility and Definity policies and procedures
• Promote the principles of dignity, independence, integration, and equal opportunity when providing customer service
• Forward feedback from customers regarding accessibility to their leader

This Policy applies to the provision of goods and services at premises owned or operated by Definity, as well as any interactions with employees, customers, and clients via telephone, email, post, websites or through social media.

This Policy applies to employees, as well as volunteers, agents, and contractors who deal with the public or third parties that interact with the public on behalf of Definity.

For the purposes of this Policy, the terms ‘assistive device’, ‘barriers’, ‘customers’, ‘disability’, ‘guide dog’, ‘support person’ and ‘service animal’ shall have the meanings given to them in applicable Accessibility Legislation. In jurisdictions where there is no applicable Accessibility Legislation, or where such term is not defined, these terms shall have the following meanings:  

Assistive device — Any device used to assist persons with disabilities in carrying out activities or in accessing the services of our organization. This could include technical devices such as communication devices or personal assistive devices such as a walker.

Barriers — Barriers are anything that hinder a person with a disability from fully and effectively participating in all aspects of society on an equal basis because of his or her disability. There are several types of barriers such as:

• physical barrier
• architectural barrier
• information or communications barrier
• attitudinal barrier
• technological barrier
• policy, practice, or procedural barrier

Customers — Include direct customers and customers of third party providers that represent Definity (i.e., brokers).

Disability — Disability means:

• 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 applicable workers’ compensation legislation.

Guide dog — A highly-trained working dog that has been trained at one of the special facilities to provide mobility, safety, and increased independence for people with visual impairments.

Support person — An individual hired or chosen by a person with a disability to provide service or assistance with communication, mobility, personal care, medical needs, or access to goods or services.

Service animal — Any animal used by a person with a disability for reasons relating to the disability, where the person provides:

• a letter from a physician confirming that they require the animal for reasons relating to their disability, or
• a valid identification card signed by the Attorney General of Canada, or a certificate of training from a recognized guide dog or service animal training school.

Upon request, Definity will communicate with people with disabilities in ways that take into account each individual’s needs, in a timely manner at no additional cost to the person.

Accessible websites and web content

Definity internet websites and web content will conform to the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0, initially at Level A and increasing to Level AA, and shall do so in accordance with the schedule set out in Accessibility Legislation where applicable.

Public safety

In preparing emergency procedures, plans, and public safety information documents, Definity will ensure that all documents made available to the public will be made available in an accessible format or with appropriate communication supports, upon request.

The purpose of the employment standard is to integrate accessibility into a regular workplace process, and to ensure that Definity provides accessibility across all stages of the employment lifecycle. The employment standard applies only with respect to paid employees. This includes, but is not limited to, full-time and part-time employees and contract employees. The employment standard does not apply to volunteers or other unpaid staff.

Workplace emergency response information

Should any employee at Definity with a disability, whether permanent or temporary, require a personalized workplace emergency response plan, Definity will create such document as soon as the information is provided from the employee. Definity will work with the employee, their leader, and the Occupational Health and Safety committee for that location to ensure a plan is in place in the event of an emergency.

This information shall be reviewed if the employee moves to a different location in the organization, if the employee’s overall accommodation needs or plans change, and when Definity reviews its general emergency response policies. 

Recruitment

Definity will notify its employees and the public about the availability of accommodation for applicants with disabilities in its recruitment process.

Recruitment, assessment, and selection process

Definity will notify job applicants when they are selected to participate further in an assessment or selection process that accommodations are available upon request in relation to the materials or processes to be used.

If a selected applicant requests accommodation, Definity will consult with the applicant, and provide or arrange for the provision of suitable accommodation in a manner that takes into account the applicant’s accessibility needs due to disability.

Notice to successful applicants

When making offers of employment, Definity will notify the successful applicant of its policies for accommodating employees with disabilities.

Informing employees of supports

Definity will inform its employees of the policies used to support employees with disabilities, including but not limited to policies on the provision of job accommodation that take into account an employee’s accessibility needs due to disability. This information will be provided to new employees as soon as possible after commencing employment.

Accessible formats and communication supports for employees

Upon the request of an employee with a disability, Definity will consult with the employee to provide, or arrange for the provision of accessible formats and communication supports for information that is needs to perform the employee’s role, and information that is generally available to other employees.

Documented individual accommodation plans

Definity will maintain a written process for the development of documented individual accommodation plans for employees with disabilities.

If requested, information regarding accessible formats and the communications supports provided will also be included in individual accommodation plans.

In addition, the plans will include the individual’s workplace emergency response information (where required), and will identify any other accommodation that is to be provided.

For further information on our process for creating documented accommodation plans for employees with disabilities, please see our Accommodation Policy.

Return-to-work process

Definity is committed to supporting employees who have been absent from work due to illness, injury, or disability, and require accommodation in order to return-to-work. Definity will work with the returning employee and other stakeholders to create a return–to-work plan to ensure a successful reintegration of the employee into the workplace. If required, Definity will create an individual accommodation plan as per our Accommodation Policy.

Performance management, career development, advancement, and redeployment

Definity is committed to providing all employees equal opportunity for advancement. Definity will take into account the accessibility needs of its employees with disabilities, as well as individual accommodation plans (where they are in place), when undertaking performance management, and providing career development and advancement to employees with disabilities. When conducting any redeployment initiatives, Definity will also take into account the accessibility needs and individual accommodation plans (where they are in place).

Definity is committed to ensuring its buildings are accessible. Definity reviews the requirements associated with Accessibility Legislation on a regular basis.

Assistive devices

In such cases where a person with a disability requires the use of their own personal assistive devices in order to access the goods and services provided by Definity, they are welcome to do so. Assistive devices include, but are not limited to hearing aids, wheelchairs, electronic organizers, magnifying devices, and electronic voice synthesizers.

In cases where the assistive device presents a safety concern or where accessibility might be an issue, other reasonable measures will be used to facilitate access to goods and services.

Guide dogs and service animals

Persons with disabilities who rely on the use of guide dogs or service animals are welcome to bring such animals with them to Definity in order to access the goods and services provided. The only exception to this practice is where such animals are prohibited by law.

If a guide dog or service animal is excluded by law, Definity will make all reasonable efforts to offer alternative methods to enable the person with a disability to access goods and services.

Recognizing a guide dog and/or service animal

If it is not readily apparent that the animal is being used by the customer for reasons relating to a disability, Definity may request verification from the customer which should include

• a letter from a physician, therapist, or nurse confirming that the person requires the animal for reasons related to the disability,
• a valid identification card signed by the Attorney General of Canada, or
• a certificate of training from a recognized guide dog or service animal training school.

Support persons

If the use of a support person is required in order to access the goods and services provided by Definity, persons with disabilities are welcome to have the support person present when interacting with Definity. If necessary, Definity will request written authorization to validate that the support person can act on the customer’s behalf.

Definity recognizes that at times, a support person may be necessary for the health and safety of the person with the disability or for the health and safety of others on the premises.

All customer confidentiality requirements and practices will also apply to support person.

Communication

Definity will ensure all members of the organization strive to communicate with a person with a disability in a manner that takes into account their disability. All employees will be trained on how to interact and communicate with customers with disabilities. We will offer alternative communication and document formats that will meet the needs of customers with disabilities as promptly as feasible.

Training

Training will be provided to all employees and volunteers of Definity. Training will be provided as soon as practicable upon the individual being assigned the applicable duties, and on an ongoing basis as changes occur to Definity policies, procedures, and practices relating to the provision of services to persons with disabilities.

Definity will maintain a training policy and a record of training that includes a summary of the content of the training, the dates training was provided, the number of employees, and names of employees trained.

The training will be conducted in an online format and will include information on the purposes of Accessibility Legislation, how to communicate and interact with people with disabilities, how to interact with a service animal or support person, how to utilize assistive devices that are available on our premises, how to interact with persons with disabilities who use an assistive device or require assistance of a service animal or support person, what to do if a person with a disability has difficulty accessing Definity services or facilities, and our policies, procedures, and practices pertaining to accessibility.

Contractors and agents providing services to the public on behalf of Definity will also be required to ensure their staff has received appropriate training.

Disruption of service

Service disruptions may occur due to reasons that may or may not be within the control or knowledge of Definity. In the event of temporary disruption to facilities or services that customers with disabilities rely on, reasonable efforts will be made to provide advance notice. In some circumstances, such as an unplanned temporary disruption, advance notice may not be possible.

Notification will be given by posting the information in a conspicuous place that is owned and operated by Definity and on our website, or will be given by another reasonable method. In the event that a notification needs to be posted, the following information will be included, unless it is not readily available or known:

• the goods or services that are disrupted or unavailable
• the reasons for the disruption
• the anticipated duration
• description of alternative service or options

Feedback process

Customers will have an opportunity to provide feedback on how Definity provides goods or services to people with disabilities. This feedback will be received by the Definity human resources department, and feedback will be forwarded to the relevant business unit. Definity will respond to any feedback, take immediate action on any complaints and document its resulting actions. Feedback forms, along with alternate methods of providing feedback, such as verbally (in person or by telephone), or written (paper or electronic), will be made available upon request.

Availability and format of documents (alternative formats)

All documents required by Accessibility Legislation, as well as related policies, including the Accessibility Policy, notices of temporary disruptions, training policy, written feedback process and documentation of actions resulting for feedback, are available upon request. When providing these documents to a person with a disability, Definity will endeavour to provide the document, or the information contained in the document, in a format that takes the person’s disability into account.

All areas of Definity are accountable for ensuring that the principles of this policy are upheld. However, it is the responsibility of human resources to ensure that this policy is reviewed every three years, or as required, to ensure adherence to developing law (i.e., regulatory standards for accessibility). Should you have any questions or concerns about this policy or the related procedures, please contact Definity:

• Toll-free: 1-800-265-9996
• TTY (Ontario): 1-800-268-9242
• TTY (Quebec): 1-800-361-6476
• Email: accessibility@economical.com

At Definity, we strive to meet the needs of our customers, partners, and employees with disabilities, and are actively working to remove and prevent barriers to accessibility.

Definity is committed to ensuring the services we provide are as accessible as possible to people with disabilities and are compliant with applicable Accessibility Legislation including the Accessibility for Ontarians with Disabilities Act (AODA) and The Accessibility for Manitobans Act.

This multi-year accessibility plan outlines the steps Definity has taken, and is taking, to meet those requirements, and to create or improve opportunities for people with disabilities.  Our Accessibility Plan applies to Definity and its wholly-owned subsidiaries (collectively “Definity”).

The following represents a summary of the accessibility initiatives Definity has completed up to and including December 31, 2020.

Customer Service

Definity is committed to ensuring our customer service policies and practices meet or exceed the Customer Service Standard established by Accessible Legislation. We have done this by:

• Providing appropriate and timely training to all necessary persons that is aligned with the requirements of the accessibility standards referred to in the Integrated Accessibility Standards Regulation (IASR),and continuing to provide training Accessibility as it pertains to persons with disabilities. Appropriate records of training are maintained.
• Establishing processes for customers to provide feedback or request an accommodation through all channels including telephone, TTY service, email, and post. Through these processes, we have received customer requests to supply alternative formats and have worked with those customers to provide solutions that meet their needs in a timely fashion.

Information and Communication

Definity is committed to ensuring we meet or exceed the communication and information requirements of people with disabilities. We have done this by:

• Providing user experience and accessibility reviews and consultation through a dedicated resource – a Senior Digital Marketing specialist on our Content & Digital Marketing team, responsible for ensuring all external digital messaging and customer facing user interfaces are rigorously tested to comply with the WCAG 2.0 A standard or better ongoing, extensive testing using assistive technology devices on all digital properties to confirm compliance
• Identifying gaps in the WCAG Level A requirements and establishing an internal standard for all Definity digital properties that exceeds the compliance requirements to deliver an experience that is accessible to all users. To address these gaps, we have incorporated the following additional WCAG 2.0 Level AA criteria:
  • Colour contrast requirements for web and digital messaging
  • Focus position is identified on all interactive controls
  • Resize text 200% without reflow issues
  • Images of text all have alternative text relayed through screen reader
  • Multiple ways of finding content on digital properties (increased to three ways rather than the AA required two)
  • Descriptive headings and labels
  • Consistent navigation
  • Error prevention (legal, financial, data)
• Conducting internal training sessions as required for developers, designers, and content creators on meeting WCAG 2.0 Level A compliance and our internal AA criteria
• Conducting internal and third-party accessibility audits and user testing on external digital properties when new sites are launched
• Acquiring automated accessibility testing and reporting tool for our web properties
• Curating an extensive library of accessibility requirements, samples, and tools for development and content creation teams to reference and review
• All employees completed the AODA training course and is currently included in onboarding plans for new employees
• Document accessibility will be incorporated at the asset design phase.   -
• Automated accessibility reporting will be incorporated and integrated within development and design workflows - Digital and design marketing team members from Sonnet and Economical (now known as Definity) participated in training sessions to deepen accessibility knowledge and update processes to ensure greater rigour of execution.
• Document accessibility was incorporated at the asset design phase

Training

Definity is committed to ensuring our standards for accessibility training are in full compliance with applicable regulations. We have done this by:

• Mandatory Accessibility training for all new employees
• Transitioning our eLearning authoring tools for employee and partner audiences to one that allows HTML output, removing a dependency on Flash-based content (net new eLearning content is created using accessible technologies)
• Developing a learning module for customer-facing roles to address specific accommodation requests and customers with diverse needs.
• Implementing a training platform solution that provides a more robust accessible experience for all employees

Employment

Definity is committed to being an inclusive and accessible employer. We have done this by:

• Workplace emergency response information — Individual workplace emergency response plans have been developed, documented, and implemented for employees with disabilities.
• Recruitment — Open positions are posted on Economical.com and include notice of the availability of accommodation for applicants with disabilities in the recruitment process. In addition, applicants are notified when they are called for an interview about the availability of recruitment-related accommodations during the selection process.   
• Informing employees of support available — Definity advises potential employees of supports available during the offer process and is outlined in our employment offer letter.  Updated information on accommodations policies is provided to employees when changes occur.
• Individual accommodation plans — On request, we will consult with an employee with a disability to create an individual accommodation plan to determine which accessible formats or communication supports they require to perform the duties of their job. The plan will cover:
  • Providing individual accommodation plans in a format that meets the needs of the employee
  • Individualized workplace emergency response information, if required
  • Regular review and updates to the individual accommodation plan, where required
  • Return to work process to ensure successful re-integration to their role
  • Privacy considerations
• Performance management, career development, advancement, and redeployment — When undertaking performance management, and providing career development and advancement opportunities to employees with disabilities, we will take into account the accessibility needs as well as individual accommodation plans (where they are in place). We also regularly review and update our internal people practices and procedures.

Procurement

Definity is committed to ensuring our procurement processes prevent barriers to accessibility. We have done this by:

• Procurement and selection of third party digital tools meet accessibility compliance requirements
• Definity is committed to ensuring our procurement processes include accessibility checkpoints for all digital and physical products and services where applicable.
• Procurement for digital solutions will incorporate accessibility requirements as an integrated step in the sourcing and selection processes.

Other

• There are plans are in place to address the needs of our customers, partners, and employees with disabilities during times of service disruption
• Established Emergency evacuation and individual evacuation plans.
• Launched an Accessibility Working Group that meets quarterly, represented by various departments, to ensure the Accessibility Plan is implemented and updated and key risks
• Established a Diversity and Inclusion Advisory Committee and three employee resource groups.
• Updated our Accessibility Policy language to incorporate all jurisdictions across Canada with accessible legislation are represented under this plan and the policy.

The following represents a summary of the accessibility initiatives Definity is committed to pursuing in 2021 and beyond.

Customer Service

Definity is committed to providing ongoing accessible customer service, providing goods and services to people with disabilities with the same high quality and timeliness as others.

• Continue to source new resources and tools to support accessibility audits

Information and Communications

Definity is committed to making our information and communications accessible to people with disabilities.

• Definity is committed to delivering digital properties which meet or exceed WCAG 2.0 Level A requirements. Additionally, any significant, net new changes to our web properties will be designed and developed to meet WCAG 2.0 Level AA compliance.
• Establish a Digital Accessibility Centre of Excellence to promote consistency in execution of accessibility compliance across Definity’s Communication and Marketing functions, and continue to address any gaps in training, knowledge, or technology as they arise.

Training

Definity is committed to providing training in the requirements of Accessibility and Human Rights Laws as it applies to people with disabilities.

• All employees will continue to be required to complete Accessibility training
• Continue to offer a customer service representative specific training module available to employees related to interacting with users with diverse needs
• Finalize internal accessibility review process for developing accessible learning assets
• New eLearning content will be created using accessible technologies

Employment

Definity is committed to fair and accessible employment practices. 

Procurement

Definity is committed to ensuring our procurement processes include accessibility checkpoints for all digital and physical products and services where applicable.

• Procurement for digital solutions will incorporate accessibility requirements as an integrated step in the sourcing and selection processes.

Design of Public Spaces

Definity continues to meet accessibility laws when building or making major changes to public spaces.

• Work is nearing completion to reconstruct the employee entrance of the Definity head office. The construction incorporates changes to outdoor eating areas and outdoor paths of travel. Construction is planned for completion in 2021 and will meet the technical requirements for public space accessibility.
• If approved, the plan to renovate the servery area of the Westmount cafeteria; including lowering counters, more accessible self-service areas, etc. would be included in this project.  Please note this project may be deferred to a future year depending on pandemic circumstances.

For more information on this accessibility plan, please contact us at:

• Toll-free: 1-800-265-9996
• TTY (Ontario): 1-800-268-9242
• TTY (Quebec): 1-800-361-6476
• Email: accessibility@economical.com

You can also submit your comments through our online Customer Service Feedback form or contact us through our website or our social media channels:

• Website: economical.com
• LinkedIn: linkedin.com/company/14505/
• Twitter: twitter.com/economicalCA

Standard and accessible formats of this document are available on request from accessibility@economical.com.