Accessibility.

UPDATED DECEMBER 2020

TABLE OF CONTENTS

Accessibility Policies and Multi-Year Accessibility Plan

1. Statement of Commitment
2. Multi-Year Accessibility Plan Overview
3. Accessible Emergency Information and Workplace Emergency Response
4. Training
5. Kiosks
6. Information and Communications
7. Accessible Websites and Web Content
8. Feedback Process
9. Employment
10. Individual Associate Accommodation Plan and Return to Work Policy
11. Performance Management, Career Development and Redeployment
12. Other Accessibility Barriers
13. Design of Public Spaces
14. Feedback Process and Request for Information
15. Definitions
16. Accessibility Policies and Multi-Year Accessibility Plan Revision History
17. Accessibility Compliance Report

1. STATEMENT OF COMMITMENT

SmartCentres is committed to providing equitable access and high-quality facilities and/or services by meeting the needs of our diverse and valued Associates and customers. To this end, SmartCentres will ensure that it is compliant with the Accessibility for Ontarians with Disabilities Act (AODA), 2005, which aims to remove barriers that impact individuals with a disability. Through compliance, SmartCentres will endeavour to provide all individuals with equal access to our facilities and/or services while allowing individuals with a disability to maintain their independence, dignity, and integration.

2. MULTI-YEAR ACCESSIBILITY PLAN OVERVIEW

SmartCentres has developed a strong foundation of accessibility planning in order to remove barriers and ensure real and effective change for people with disabilities, and is eager to carry this commitment forward with the implementation of our Multi-Year Accessibility Plan.

Our Multi-Year Accessibility Plan provides the opportunity to demonstrate our current achievements and establish an implementation framework and future priority initiatives. Objectives identified within the Plan are both long term and short-term; many are ongoing actions or could require implementation over several years. The plan is available on the intranet and external website, and will be provided in an accessible format, upon request. Regular monitoring is necessary to ensure that initiatives are included in the Plan and that progress is identified. The Multi-Year Accessibility Plan’s progress will be reviewed and reported every 3 years and a comprehensive review will be conducted every five years (2024).

3. ACCESSIBLE EMERGENCY INFORMATION AND WORKPLACE EMERGENCY RESPONSE

SmartCentres is committed to providing our customers and our Associates with publicly available emergency information in accessible formats upon request.

Upon request, Human Resources and Corporate Services will work together with the Associates to develop an individualized emergency response information/plan that will meet their needs in an emergency situation.

Project Title	Description	Department Responsibility	Start Date	Completion Date
Employment Initiatives – Emergency Procedures	Individualized workplace emergency response information will be provided upon request in an accessible format when the need is communicated. The individualized workplace emergency response information will be reviewed when: the Associate moves to a different location within the Company; the Associate’s overall accommodation needs or plans are reviewed; SmartCentres reviews general emergency response policies.	Human Resources, Corporate Services	Dec 2011	Jan 2012
Employment Initiatives – Emergency Procedures	Create a standard template document to be used to develop individual workplace emergency response plans taking into consideration individual accommodation needs.	Human Resources, Corporate Services	Jan 2014	May 2014

4. TRAINING

SmartCentres will provide training to all Ontario Associates on the Ontario’s accessibility laws and on the Human Rights Code as it relates to persons with disabilities. Training will be tailored to Associate’s responsibilities and duties and it will be provided in a format that best suits the Associate. The training will also be provided to every Ontario Associate who participates in developing SmartCentres’ policies.

SmartCentres has taken the following steps to ensure Associates are provided with the training needed to meet Ontario’s accessible laws since August 2011.

Project Title	Description	Department Responsibility	Start Date	Completion Date
Training Initiatives	Develop Accessibility Standards for Customer Service Policy and training in various formats for all Ontario Associates.	Human Resources	Sep 2011	Training completed for current Associates.
Training Initiatives	Continue to conduct, access and review accessible customer service training for all Ontario Associates.	Human Resources	Aug 2011	Completed research in Sep 2012. Ongoing
Training Initiatives	Conduct and review Human Rights Code and the Accessibility for Ontarians with Disabilities Act training for all Ontario Associates. Updated the Quiz in July 2016	Human Resources	Nov 2014	Training completed for current Associates.
Training Initiatives	Provide training to all new Ontario Associates within 6 months of hire.	Human Resources	Aug 2011	Ongoing
Training Initiatives	Provide periodic training in connection with changes to this Multi-Year Plan and its related practices and procedures.	Human Resources	May 2011	Ongoing
Training Initiatives	Research and provide training for Ontario’s accessibility laws and Human Rights Code training in multiple formats.	Human Resources	Jan 2014	Ongoing

5. KIOSKS

SmartCentres is committed to incorporating accessibility features when designing, procuring or acquiring self-service kiosks.

6. INFORMATION AND COMMUNICATIONS

SmartCentres is committed to meeting the communication needs of persons with disabilities. We will consult with persons with disabilities to determine their information and communication needs and accommodate where possible. SmartCentres has taken the following steps to ensure that all publicly available information in Ontario is made accessible upon request since January 2013.

Project Title	Description	Department Responsibility	Start Date	Completion Date
Information & Communication Initiatives	AODA statement of commitment sign has been posted at the front reception of SmartCentres’ Home Office. AODA- Customer Service Policy is made available in large font at Reception.	Human Resources	Dec 2011	Jan 2013
Information & Communication Initiatives	Provide all tenants with a letter advising them of their responsibilities under the AODA- Customer Service Standard. This letter is included in the tenant welcome kit.	Operations Property Management	Mar 2012	Apr 2012 and ongoing
Information & Communication Initiatives	Continued implementation of a communication campaign to increase awareness of accessibility issues and to inform Associates about issues related to persons with disabilities. Ongoing ideas to be implemented such as intranet information, information in Town Halls.	Human Resources Marketing	June 2012	Ongoing
Information & Communication Initiatives	Provide information and communications in accessible formats and with communication supports to people with disabilities upon request. This will be provided in a timely manner and at a cost that is no more than the regular cost charged to other people.	Human Resources Marketing	Sep 2015	Ongoing

7. ACCESSIBLE WEBSITES AND WEB CONTENT

SmartCentres will take the following steps to make our websites and content conform to the Web Content Accessibility Guidelines (WCAG) 2.0 Level AA Standards, by January 1, 2021.

Project Title	Description	Department Responsibility	Start Date	Completion Date
Information & Communication Initiatives	AODA statement of commitment sign has been posted at the front reception of SmartCentres’ Home Office. AODA- Customer Service Policy is made available in large font at Reception.	Human Resources	Dec 2012	Jan 2013
Information & Communication Initiatives	Provide all tenants with a letter advising them of their responsibilities under the AODA- Customer Service Standard. This letter is included in the tenant welcome kit.	Operations Property Management	Mar 2012	Apr 2012 and ongoing
Information & Communication Initiatives	Continued implementation of a communication campaign to increase awareness of accessibility issues and to inform Associates about issues related to persons with disabilities. Ongoing ideas to be implemented such as intranet information, information in Town Halls.	Human Resources Marketing	June 2012	Ongoing

8. FEEDBACK PROCESS

SmartCentres has taken the following steps to ensure that our existing feedback process is accessible to persons with disabilities upon request since June 2012.

Project Title	Description	Department Responsibility	Start Date	Completion Date
Information & Communication Initiatives	AODA statement of commitment sign has been posted at the front reception of SmartCentres’ Home Office. AODA- Customer Service Policy is made available in large font at Reception.	Human Resources	Dec 2012	Jan 2013
Information & Communication Initiatives	Provide all tenants with a letter advising them of their responsibilities under the AODA- Customer Service Standard. This letter is included in the tenant welcome kit.	Operations Property Management	Mar 2012	Apr 2012 and ongoing
Information & Communication Initiatives	Continued implementation of a communication campaign to increase awareness of accessibility issues and to inform Associates about issues related to persons with disabilities. Ongoing ideas to be implemented such as intranet information, information in Town Halls.	Human Resources Marketing	June 2012	Ongoing

9. EMPLOYMENT

SmartCentres is committed to fair and accessible employment practices.

Since January 2014, SmartCentres has taken the following steps to notify the public and our Associates that we will accommodate people with disabilities during the recruitment and assessment process and when candidates are hired.

Project Title	Description	Department Responsibility	Start Date	Completion Date
Information & Communication Initiatives	AODA statement of commitment sign has been posted at the front reception of SmartCentres’ Home Office. AODA- Customer Service Policy is made available in large font at Reception.	Human Resources	Dec 2012	Jan 2013
Information & Communication Initiatives	Provide all tenants with a letter advising them of their responsibilities under the AODA- Customer Service Standard. This letter is included in the tenant welcome kit.	Operations Property Management	Mar 2012	Apr 2012 and ongoing

10. INDIVIDUAL ASSOCIATE ACCOMMODATION PLAN AND RETURN TO WORK POLICY

SmartCentres has established and implemented a Return to Work Policy and Procedure for developing individual accommodation plans for Associates that have been absent due to a disability.

Project Title	Description	Department Responsibility	Start Date	Completion Date
Information & Communication Initiatives	AODA statement of commitment sign has been posted at the front reception of SmartCentres’ Home Office. AODA- Customer Service Policy is made available in large font at Reception.	Human Resources	Dec 2012	Jan 2013
Information & Communication Initiatives	Provide all tenants with a letter advising them of their responsibilities under the AODA- Customer Service Standard. This letter is included in the tenant welcome kit.	Operations Property Management	Mar 2012	Apr 2012 and ongoing

11. PERFORMANCE MANAGEMENT, CAREER DEVELOPMENT AND REDEPLOYMENT

Since April 2016, we have taken the following steps to ensure the accessibility needs of our Associates with disabilities are taken into account for our performance management, career development and redeployment processes.

Project Title	Description	Department Responsibility	Start Date	Completion Date
Information & Communication Initiatives	AODA statement of commitment sign has been posted at the front reception of SmartCentres’ Home Office. AODA- Customer Service Policy is made available in large font at Reception.	Human Resources	Dec 2012	Jan 2013
Information & Communication Initiatives	Provide all tenants with a letter advising them of their responsibilities under the AODA- Customer Service Standard. This letter is included in the tenant welcome kit.	Operations Property Management	Mar 2012	Apr 2012 and ongoing

12. OTHER ACCESSIBILITY BARRIERS

SmartCentres has taken the following steps to prevent and remove other accessibility barriers identified.

Project Title	Description	Department Responsibility	Start Date	Completion Date
Information & Communication Initiatives	AODA statement of commitment sign has been posted at the front reception of SmartCentres’ Home Office. AODA- Customer Service Policy is made available in large font at Reception.	Human Resources	Dec 2012	Jan 2013
Information & Communication Initiatives	Provide all tenants with a letter advising them of their responsibilities under the AODA- Customer Service Standard. This letter is included in the tenant welcome kit.	Operations Property Management	Mar 2012	Apr 2012 and ongoing

13. DESIGN OF PUBLIC SPACES

Since January 2017, SmartCentres has met the Accessibility Standards for the Design of Public Spaces when building or making major modifications to public spaces in Ontario. Public spaces including:

Trails and beach routes
Service counters and waiting areas
Outdoor public eating areas
Outdoor play spaces
Outdoor paths
Off-street parking
Maintaining areas of accessible parts of our public spaces
Accessibility in buildings
Any other space that SmartCentres deems necessary
SmartCentres has implemented 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.

14. FEEDBACK PROCESS AND REQUEST FOR INFORMATION

Any individual who requires additional information regarding SmartCentres’ Accessibility Policies and/or our Multi-Year Accessibility Plan can do so in person, by e-mail, or in writing or by any other means, as required. We can arrange for accessible feedback and alternate formats upon request. Accessible formats of our Accessibility Policies and our Multi-Year Accessibility Plan will be made available free upon request. SmartCentres commits to responding to all requests for information in a timely manner.

Please direct any Accessibility related enquiries to:

Shelley Philippe, Senior Director Human Resources
3200 Highway 7
Vaughan, Ontario, L4K 5Z5

Email: [email protected]
Phone: 647-697-9616
Fax: 905-760-6207

15. DEFINITIONS

Associate: employees of SmartCentres
Customer: a member of the public
Disability: defined by the Accessibility for Ontarians with Disabilities Act, 2005, and the Ontario Human Rights Code, refers to the following:

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 other remedial appliance or device;
A learning disability, or dysfunction in one of 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 the Workplace Safety and Insurance Act, 1997.

16. ACCESSIBILITY POLICIES AND MULTI-YEAR ACCESSIBILITY PLAN REVISION HISTORY

Project Title	Description	Department Responsibility	Start Date	Completion Date
Information & Communication Initiatives	AODA statement of commitment sign has been posted at the front reception of SmartCentres’ Home Office. AODA- Customer Service Policy is made available in large font at Reception.	Human Resources	Dec 2012	Jan 2013
Information & Communication Initiatives	Provide all tenants with a letter advising them of their responsibilities under the AODA- Customer Service Standard. This letter is included in the tenant welcome kit.	Operations Property Management	Mar 2012	Apr 2012 and ongoing

17. ACCESSIBILITY COMPLIANCE REPORT

Click here to view SmartCentres REIT’s 2023 Accessibility Compliance Report.