ACCESSIBILITY POLICY AND MULTI-YEAR ACCESSIBILITY PLAN
Purpose
This Accessibility Policy and Multi-Year Accessibility Plan (the “Policy”) outlines the policies, practices and actions that Jam City, Inc. (“Jam City” or the “Company”) have or will implement in its Ontario operations to improve accessibility for individuals with disabilities. The Policy also incorporates and references the Company’s existing accessibility policies and practices, where applicable.
Statement of Commitment
Jam City is committed to treating all people, including individuals with disabilities, in a manner that respects their dignity and independence. The Company believes in integration and equal opportunity. To this end, the Company is committed to meeting the needs of individuals with disabilities in a timely manner and will endeavor to identify and remove barriers to accessibility in all aspects of the Company’s operations. The Company is also committed to ensuring compliance with the accessibility requirements contained in the Accessibility for Ontarians with Disabilities Act, 2005 (“AODA”).
Definitions
Accessible formats include but are not limited to large print, recorded audio and electronic formats, braille, and other formats usable by persons with disabilities.
Assistive Device is a technical aid, communication device, or other instrument that is used to maintain or improve the functional abilities of people with disabilities.
Communication Supports are captioning, alternative and augmentative communication supports, plain language, sign language, and other supports that facilitate effective communications.
Conversion-ready is an electronic or digital format that facilitates conversion into an acceptable format.
Disability is any condition of the body or mind (impairment) that makes it more difficult for the person with the condition to do certain activities (activity limitation) and interact with the world around them (participation restrictions).
Service animal is an animal that can be recognized by visual indicators such as a vest or harness that is being used by an individual with a disability for reasons relating to the person’s disability.
Support person is another person who accompanies an individual with a disability in order to help with communication, mobility, personal care, medical needs, or access to goods and services.
PART I – EMPLOYMENT
Jam City will make every effort to identify, remove, and prevent barriers in employment by developing inclusive employment procedures that support persons with disabilities throughout the employment life cycle, including during the recruitment phase. Where barriers continue to exist, Jam City is committed to a collaborative approach to accommodation solutions.
All accommodation requests will be taken seriously and dealt with in accordance with this Policy, as promptly as possible in light of individual circumstances. No employee or prospective employee will be penalized for making an accommodation request.
Recruitment and Hiring
The Company understands that improving workplace accessibility and ensuring an accessible recruitment and selection process for applicants with disabilities is important. Upon request, the Company will provide candidates with reasonable accommodations during the recruitment process. Where an accommodation is requested and approved, the Company will consult with the applicant to arrange suitable accommodations, up to the point of Undue Hardship (as defined below).
The Company’s interview process will focus on experience and skills and will not discriminate against candidates who have a disability or require an accommodation. Jam City is committed to hiring decisions that are unbiased and based on qualifications and past experience. Successful candidates will be made aware of policies and supports for accommodations upon completion of the recruitment process.
Training and Development
Jam City recognizes that skills development and career planning can enrich the employment experience, increase engagement, and reduce turnover for individuals with disabilities. As such, the Company will align training and development programs to meet the needs of employees with disabilities and provide training as soon as reasonably practicable upon the person being assigned to applicable duties.
Training programs will be designed with flexibility to allow customization for the individual requirements of the employee, such as providing training materials in accessible or conversion-ready formats that take into account the need of the employee.
The Company will also consider employee barriers when implementing performance management processes, or when offering career development, employment support, or advancement opportunities.
Communication Support
The Company will provide or arrange for additional accessible formats and communication support for employees, upon request. The Company will consult with the employee to determine the specific barrier and the best way to provide support.
When communicating with or providing information to an employee who requires accommodation or assistance due to a disability, the Company will ensure that all communication with the individual is completed in a manner that takes into account the individual’s disability. Where an assistive device is used, the Company will reasonably accommodate the use of the device.
Emergency Response
If necessary or if requested, Jam City will create individualized workplace emergency response plans for employees with disabilities. The emergency response plan will consider the specific challenges created by the individual’s disability and the physical nature of the workplace and will be created in consultation with the employee. If an employee with a disability requires assistance from a support person during an emergency, the Company will designate a fellow employee to act as such.
Customized emergency response plans will be reviewed and revised if needed, in the following circumstances:
• The employee moves to a different physical location in the Company;
• The employee’s overall accommodation needs, or plans are reviewed; or
• The Company reviews general emergency response policies.
Accommodation
Jam City will provide individual accommodations to support the needs of employees who require such accommodations. Personalized accommodation plans will be designed to allow employees to contribute and participate in job related functions and activities to the best of their abilities. The process of accommodating individuals will take a consultative approach and is a shared obligation of the Company, the employee, and any applicable professionals required to assist the employee throughout the process.
Accommodation requests can be made directly to the Benefits team at benefits@jamcity.com. Requests for accommodation should, wherever possible, be made in writing and include the ground with respect to which accommodation is being requested (e.g., disability), the limitations of the employee having regard to their job duties, and any other information relevant to Jam City assessment of the accommodation request and requirements.
Upon receipt of an accommodation request, the Company may request additional information as necessary, including but not limited to, information from the employee’s doctor outlining their functional limitations. In certain circumstances, including, but not limited to, where medical or other information provided by the employee is inconsistent or inconclusive, the Company may request that the employee be evaluated by a third party medical or other expert to assist the company in determining if and how accommodation can be achieved. Any such evaluation will be at the Company’s expense.
Return to Work Process
Jam City is committed to a supportive return-to-work program and will develop and implement return-to-work processes for employees who are absent from work due to a disability and require accommodations in order to return to work. The Company will work with the employee to develop an individualized return-to-work plan and support the employee in the transition period by addressing any barriers. The return-to-work plan will outline, among other things, the steps the Company will take to facilitate the employee’s return to work and the employee’s individual accommodation plans.
Redeployment
If an employee cannot be accommodated in their current position, Jam City will consider redeployment by placing the employee in an alternative position within the Company to the point of Undue Hardship (as defined below). The Company will work with the employee to determine whether there is another available position. If the accommodation requires a substantial change in the position, involving duties or hours, the position may be redesigned.
Undue Hardship
Jam City will provide workplace accommodation up to the point of Undue Hardship. Without limitation, Undue Hardship may occur where it is established that no forms of appropriate accommodation exist, or where the creation of accommodation would create a health and safety hazard or cause unreasonable costs for the Company.
PART II – CUSTOMER SERVICE
Jam City is committed to providing high quality service to all of its customers and clients, including customers and clients with disabilities.
It is the Company’s objective to provide customer service in a manner that respects the dignity and independence of individuals with disabilities. This means that the Company will take steps to ensure that its goods and services are provided in an accessible manner and, to the fullest extent possible, allow individuals with disabilities to access goods and services in the same way as all other customers and clients.
Communication
The Company is committed to communicating with individuals with disabilities in a manner that takes into account their disabilities, and the Company will train our staff who communicate with customers and clients accordingly. The Company recognizes that disabilities and any accommodations required by individuals with disabilities are not always obvious or apparent. The Company is committed to being guided by the principles of respect, dignity and independence in interacting with all individuals, including individuals with disabilities.
The Company’s commitment to communicating effectively with individuals with disabilities applies to all aspects of communications with clients and customers (and potential clients and customers), including face to face interactions, telephone and electronic communications, and written documents, including without limitation, presentations, contracts, and billings.
Assistive Devices, Support Persons, and Service Animals
The Company is committed to welcoming individuals with disabilities into its premises and ensuring that they can access our goods and services. Individuals who use assistive devices will be able to obtain, use and benefit from our goods and services. To the greatest extent possible, the Company will ensure that staff are familiar with various assistive devices that may be used by customers and clients to access the Company’s services. If the Company maintains assistive devices that may be used by customers and clients, the Company will ensure staff is trained with respect to their use.
Subject to applicable laws, individuals with disabilities who are required to be accompanied by a service animal on the parts of our premises open to the public and other third parties, will be permitted to do so. The Company is similarly committed to welcoming individuals with disabilities who are accompanied by a support person. At no time will an individual who requires a support person be prevented from having access to that person while on our premises.
Notice of Temporary Disruptions
The Company will provide customers and clients with notice in the event of a planned or unexpected disruption of the facilities or services usually used by individuals with disabilities in accessing the Company’s premises or goods and services.
The notice will include information regarding the reason for the disruption, its anticipated duration, and a description of any alternative facilities or services for use, if available. The notice will be brought to the attention of individuals with disabilities in a manner reasonable in the circumstances, for example, by posting the notice in the Company’s premises, on its website or in another manner.
Training of Staff
The Company will ensure that employees, volunteers, and others who deal with the public or other third parties on its behalf, and all those who are involved in the development and approval of customer services policies, practices and procedures, receive training in compliance with applicable laws, including AODA.
Training will include, at minimum, the following:
· An explanation of the purposes of AODA and the customer service standards enacted under AODA.
· Information regarding how to interact and communicate with individuals with various types of disabilities.
· Information regarding how to interact and communicate with individuals who use an assistive device or require the assistance of a service animal or a support person.
· Information regarding how to use any assistive device or other equipment or material available at the Company that may help with the provision of goods and services to individuals with disabilities.
· Instruction on what to do if an individual with a disability is having difficulty accessing the Company’s goods or services.
· Information regarding the Company’s policies, practices and procedures relating to customer service for individuals with disabilities, including this Policy.
Feedback Process
The overall objective of the Company is to meet and surpass customer and client expectations in all respects, including in the Company’s service to individuals with disabilities. Comments regarding how well those expectations are being met are vital, welcome, and appreciated. Jam City recognizes that feedback can make the Company’s customer service better.
Feedback regarding the way the Company provides goods and services to customers and clients (and potential customers and clients) with disabilities can be made verbally, by email, by letter or otherwise. All feedback will be directed to the Company’s People team at people@jamcity.com for consideration. Complaints and other feedback requiring a response will be addressed promptly and according to the Company’s existing policies and procedures regarding customer and client feedback.