AODA – Integrated Accessibility Standards Regulation (IASR) Employment Policy

This policy is intended to meet the requirements of the Integrated Accessibility Standards, Ontario Regulation 191/11 for the Employment Standard set forth under the Accessibility for Ontarians with Disabilities Act, 2005. This policy applies to the provision of accessible employment services for persons with disabilities. All employment services provided by Starlight Group Property Holdings Inc. (“Starlight”) shall follow the principles of dignity, independence, integration and equal opportunity.

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. Communication Supports – Include but are not limited to captioning, alternative and augmentative communication supports, plain language, sign language and other supports that facilitate effective communications. Performance Management – Activities related to assessing and improving employee performance, productivity and effectiveness with the goal of facilitating employee success. Redeployment – The reassignment of employees to other departments or jobs within the organization as an alternative to layoff, when a particular job or department has been eliminated by the organization.

General Principles

In accordance with the Integrated Accessibility Standards, Ontario Regulation 191/11, this policy addresses the following: General Requirements Recruitment, Assessment and Selection Accessible Formats and Communication Supports for Employees Workplace Emergency Response Information Documented Individual Accommodation Plans Performance Management and Career Development and Advancement Return to Work Redeployment Review

A) General Requirements

General requirements that apply across Information & Communications and Employment are outlined as follows. Establishment of Accessibility Policies and Plans Starlight will develop, implement and maintain policies governing how it will achieve accessibility through these requirements. Starlight will include a statement of its commitment to meeting the accessibility needs of persons with disabilities in a timely manner in its policies. These documents will be made publicly available in an accessible format, upon request. Starlight will establish, implement, maintain and document a multi-year accessibility plan outlining its strategy to prevent and remove barriers and meet its requirements under the IASR. Accessibility plans will be made available in an accessible format, upon request, and will be posted on our website. Starlight will review and update its accessibility plan once every five (5) years and will establish, review and update our accessibility plans in consultation with persons with disabilities or an advisory committee. Annual status reports will be prepared that will report on the progress of the steps taken to implement Starlight's accessibility plan. This status report will be posted on our website. If requested, the report shall be created in an accessible format. Training Requirements Starlight will provide training for its employees regarding the IASR and the Ontario Human Rights Code as they pertain to individuals with disabilities. Training will also be provided to individuals who are responsible for developing Starlight's policies, and all other persons who provide goods, services or facilities on behalf of Starlight. Training will be provided as soon as is reasonably practicable, but no later than January 2016. Training will be provided on an ongoing basis to new employees and as changes to Starlight's accessibility policies occur. Records Starlight will maintain records on the training provided, when it was provided and the number of employees that were trained.

B) Recruitment, Assessment and Selection

Starlight, or recruiting agents acting on its behalf, will notify employees and the public about the availability of accommodation for job applicants who have disabilities. Applicants will be informed that these accommodations are available, upon request, for the interview process and for other candidate selection methods. Where an accommodation is requested, Starlight will consult with the applicant and provide or arrange for suitable accommodation. Successful applicants will be made aware of Starlight's policies and supports for accommodating people with disabilities.

C) Accessible Formats and Communication Supports for Employees

Starlight will ensure that employees are aware of our policies for employees with disabilities and any changes to these policies as they occur. If an employee with a disability requests it, Starlight will provide or arrange for the provision of accessible formats and communication supports for the following: Information needed in order to perform his/her job; and Information that is generally available to all employees in the workplace. Starlight will consult with the employee making the request to determine the best way to provide the accessible format or communication support.

D) Workplace Emergency Response Information

Where required, Starlight will create individual workplace emergency response information for employees with disabilities. This information will take into account the unique challenges created by the individual's disability and the physical nature of the workplace, and will be created in consultation with the employee. This information will be reviewed when: The employee moves to a different physical location in the organization; The employee's overall accommodation needs or plans are reviewed; and/or Starlight reviews general emergency response policies.

E) Documented Individual Accommodation Plans

Starlight must also develop and have in place written processes for documenting individual accommodation plans for employees with disabilities. The process for the development of these accommodation plans should include specific elements, including: The ways in which the employee can participate in the development of the plan; The means by which the employee is assessed on an individual basis; The ways that an employee can request an evaluation by an outside medical expert, or other experts (at the employer's expense) to determine if accommodation can be achieved, or how it can be achieved; The steps taken to protect the privacy of the employee's personal information; The frequency with which the individual accommodation plan should be reviewed or updated and how it should be done; and The means of providing the accommodation plan in an accessible format, based on the employee's accessibility needs.

F) Performance Management and Career Development and Advancement

Starlight will consider the accessibility needs of employees with disabilities when implementing performance management processes, or when offering career development or advancement opportunities.

G) Return to Work

Starlight will develop and implement return to work processes for employees who are absent from work due to a disability and require disability-related accommodation(s) in order to return to work. The return to work process will outline the steps Starlight will take to facilitate the employee's return to work and shall use documented individual accommodation plans (as described in section 28 of the regulation).

H) Redeployment

The accessibility needs of employees with disabilities will be taken into account in the event of redeployment. Individual accommodation plans will be consulted, as required.

I) Review

This policy will be reviewed regularly to ensure that it is reflective of Starlight's current practices as well as legislative requirements.

Disclaimer: The information provided on this Website is derived from sources that Starlight Group Property Holdings Inc. believes are reliable. However, Starlight Group Property Holdings Inc. does not guarantee the accuracy of the information, nor do we assume any responsibility or liability whatsoever for publishing it herein. This Website is not to be construed as a form of promotion, an offer to sell securities nor as a solicitation to purchase our securities. This Website has been produced as a source of general information only.

The Princess Margaret Cancer Foundation

www.thepmcf.ca

The Princess Margaret Cancer Foundation began raising funds for cancer research at Princess Margaret Cancer Centre in 1982. Since then, the Foundation has raised well over $1 billion for one of the world's top 5 cancer research centres. The Foundation has pioneered many successful types of fundraising including mega lotteries and large-scale events recruiting thousands of participants/fundraisers such as the Rexall OneWalk to Conquer Cancer and Enbridge Ride to Conquer Cancer, to name a few.

Starlight is honored to be the official breakfast sponsor for the Princess Margaret Cancer Foundation Run/Walk for six years running. As the official Breakfast sponsors, Starlight hosts thousands of participants in a post-race celebration which includes a healthy breakfast, entertainment and fun! Starlight employees participate on the day of the Run/Walk by volunteering as breakfast hosts and by joining their co-workers and family members on our corporate Cancer Fighting Team to run or walk the 1, 3 or 5 kilometre course.

Starlight Children's Foundation Canada

www.starlightcanada.org

The Starlight Children's Foundation Canada is a charitable organization dedicated to bringing laughter, joy and hope back into the lives of children with serious illnesses offering both in-hospital and out-of-hospital programs, the latter of which includes Great Escapes, Day Brighteners and Wish Adventures.

Starlight has been supporting the Foundation for over four years by creating unique Day Brightener experiences such as; private movie screenings & visits from Santa, for the foundation’s children and their families.

Children's Breakfast Club

breakfastclubs.ca

The Children's Breakfast Club is a non-profit charitable organization that believes every child is entitled to a nutritious breakfast. An estimated 4,000 meals are served each week in the clubs across the Greater Toronto Area. The Children's Breakfast Club relies solely on the generosity and support of corporations and individuals to operate each club.

Starlight is proud to support the Children’s Breakfast Clubs across the Greater Toronto Area with various fundraising and volunteer based initiatives.

Ronald McDonald House Charities Toronto

www.rmhc.org

Established in 1981, Ronald McDonald House Charities (RMHC) Toronto provides a "home away from home" for seriously ill children and their families. RMHC Toronto encompasses a House for 81 families in downtown Toronto and Family Rooms in hospitals across the Greater Toronto Area. The families served – 5,139 last year alone – come from throughout Ontario, across Canada and around the world. RMHC Toronto is an independent charity, governed by a volunteer Board of Directors, and operated by staff and volunteers. The first and largest House in Canada, is part of a network of more than 360Houses worldwide. RMHC Toronto keeps families close when they need each other the most.

Starlight has been a proud supporter of RMHC since 2016 through various initiatives including the Home for Dinner program, an initiative aimed at easing the stress and financial burden weighing on the guest families through a simple, homecooked meal, and their Adopt a Room program. The Adopt a Room program seeks to reduce the overwhelming emotional and financial burden placed on families with a seriously ill child by giving them a place to stay while they are away from home.

Daily Bread Food Bank

www.dailybread.ca

The Daily Bread Food Bank is a registered charity that is dedicated to fighting hunger in Toronto communities. Every year thousands of people across Toronto rely on the support of food banks. As a distribution hub, Daily Bread provides food and support to almost 200 food programs across Toronto and is the largest provider of food relief in the GTA.

Starlight is involved on an ongoing basis with Daily Bread through onsite volunteering and various fundraising initiatives.

Earth Day Canada

earthday.ca

Founded in 1990, Earth Day Canada (EDC) is a national charity that inspires and supports people across the country to connect with nature and build resilient communities. EDC leads an annual Earth Day campaign in conjunction with free, year-round, award-winning programs that get people of all ages outside, interacting with the natural environment — this, in turn, fosters an intrinsically motivated, enduring commitment to stewardship and conservation.

EDC works closely with school-aged children and youth through the renowned EcoKids program and new EarthPLAY initiative and recognizes via the Hometown Heroes Awards those who are leading the way in making our planet healthier. EDC engages diverse communities in the environmental NGO sector with their Tapestry program and helps corporate partners achieve their sustainability goals with the growing employee engagement platform.

Starlight participates annually in the Earth Day “Clean Toronto Together” event that engages businesses around the GTA to help clean up local green spaces where they live and work.

Children's Wish Foundation

www.childrenswish.ca

Children’s Wish Foundation of Canada is the largest and only all-Canadian wish granting charity dedicated to granting wishes to Canadian children between the ages of 3 and 17 who are diagnosed with a life-threatening illness. For more than 30 years, Children’s Wish has worked tirelessly to grant heartfelt wishes to nearly 25,000 children and their families – that’s three wishes each and every day, all year long!

World Wildlife Foundation

www.worldwildlife.org

World Wildlife Foundation (WWF) is a global conservation organization. WWF works to conserve species at risk, protect threatened habitats and address global threats. Using the best available scientific knowledge, WWF works to preserve the diversity and abundance of life in Canada and around the world. WWF finds long-term solutions that benefit both people and nature.

Starlight supports the WWF in the Climb it for Change: Ultimate Climb Challenge where participants climb the CN Tower to raise awareness about the future outlook of our nature and wildlife. Starlight employees participated by fundraising and taking on this physically demanding challenge.

The George Hull Centre for Children and Families

www.georgehullcentre.on.ca

The George Hull Centre for Children and Families is an accredited children’s mental health centre that serves children from birth to age eighteen and their families. By working together with families, and by providing the best possible help, The George Hull Centre makes a difference in the lives of children as they grow and develop into valued members of society.

In support of children’s mental health, Starlight is proud to be an Open Mic sponsor at their annual LOL event.