AODA - ACCESSIBILITY STANDARDS FOR CUSTOMER SERVICE POLICY

This policy is intended to meet the requirements of Accessibility Standards for Customer Service, Ontario Regulation 429/07 under the Accessibility for Ontarians with Disabilities Act, 2005, and applies to the provision of goods and services to the public or other third parties, not to the goods themselves.

All goods and services provided by Starlight Group Property Holdings Inc. (“Starlight”) shall follow the principles of dignity, independence, integration and equal opportunity.

Scope

This policy applies to the provision of goods and services at premises owned or asset managed by Starlight.
This policy applies to all employees who deal with the public.
The section of this policy that addresses the use of guide dogs, service animals and service dogs only applies to the provision of goods and services that take place at premises owned or asset managed by Starlight.
This policy shall also apply to all persons who participate in the development of Starlight’s policies, practices and procedures governing the provision of goods and services to members of the public or third parties.
For the purpose of this policy, customer and client are interchangeable.

Definitions

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. Personal assistive devices are typically devices that customers bring with them such as a wheelchair, walker or a personal oxygen tank that might assist in hearing, seeing, communicating, moving, breathing, remembering and/or reading.

Disability - the term disability as defined by the Accessibility for Ontarians with Disabilities Act, 2005, and the Ontario Human Rights Code, refers to:

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 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 the Workplace Safety and Insurance Act, 1997.

Guide Dog - is a highly-trained working dog that has been trained at one of the facilities listed in Ontario Regulation 58 under the Blind Persons’ Rights Act, to provide mobility, safety and increased independence for people who are blind.

Service Animal - as reflected in Ontario Regulation 429/07, an animal is a service animal for a person with a disability if:

it is readily apparent that the animal is used by the person for reasons relating to his or her disability; or

if the person provides a letter from a physician or nurse confirming that the person requires the animal for reasons relating to the disability.

Service Dog - as reflected in the Health Protection and Promotion Act, Ontario Regulation 562, is a dog other than a guide dog for the blind is a service dog if:

it is readily apparent to an average person that the dog functions as a service dog for a person with a medical disability; or

the person who requires the dog can provide on request a letter from a physician or nurse confirming that the person requires a service dog.

Support Person - as reflected in Ontario Regulation 429/07, a support person means, in relation to a person with a disability, another person who accompanies him or her in order to help with communication, mobility, personal care, medical needs or access to goods and services.

General Principles

In accordance with the Accessibility Standards for Customer Service, Ontario Regulation 429/07, this policy addresses the following:

The Provision of Goods and Services to Persons with Disabilities
The Use of Assistive Devices
The Use of Guide Dogs, Service Animals and Service Dogs
The Use of Support Persons
Notice of Service Disruptions
Customer Feedback
Training
Notice of Availability and Format of Required Documents

A) The Provision of Goods and Services to Persons with Disabilities

Starlight will make every reasonable effort to ensure that its policies, practices and procedures are consistent with the principles of dignity, independence, integration and equal opportunity by:

ensuring that all customers receive the same value and quality;

allowing customers with disabilities to do things in their own ways, at their own pace when accessing goods and services as long as this does not present a safety risk;

using alternative methods when possible to ensure that customers with disabilities have access to the same services, in the same place and in a similar manner;

taking into account individual needs when providing goods and services; and

communicating in a manner that takes into account the customer's disability.

B) Assistive Devices

Customer’s own assistive device(s): Persons with disabilities may use their own assistive devices as required when accessing goods or services provided by Starlight. In cases where the assistive device presents a safety concern or where accessibility might be an issue, other reasonable measures will be used to ensure the access of goods and services. For example, where elevators are not present and where an individual requires assistive devices for the purposes of mobility, service will be provided in a location that meets the needs of the customer.

C) Guide Dogs, Service Animals and Service Dogs

A customer with a disability that is accompanied by guide dog, service animal or service dog will be allowed access to premises that are open to the public unless otherwise excluded by law. “No pet” policies do not apply to guide dogs, service animals and/or service dogs.

Recognizing a Guide Dog, Service Dog and/or Service Animal:

If it is not readily apparent that the animal is being used by the customer for reasons relating to his or her disability, Starlight may request verification from the customer. Verification may include:
a letter from a physician 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.

Care and Control of the Animal:

The customer that is accompanied by a guide dog, service dog and/or service animal is responsible for maintaining care and control of the animal at all time.

Allergies:

If a health and safety concern presents itself for example in the form of a severe allergy to the animal, Starlight will make all reasonable efforts to meet the needs of all individuals.

D) Support Persons

If a customer with a disability is accompanied by a support person, Starlight will ensure that both persons are allowed to enter the premises together and that the customer is not prevented from having access to the support person. In certain situations Starlight will make every reasonable attempt to resolve the issue.

In situations where confidential information might be discussed, consent will be obtained from the customer, prior to any conversation where confidential information might be discussed.

E) Notice of Disruptions in Service

Service disruptions may occur due to reasons that may or may not be within the control or knowledge of Starlight. In the event of any temporary disruptions to facilities or services that customer's with disabilities rely on to access or use Starlight’s goods or services, reasonable efforts will be made to provide advance notice. In some circumstances such as in the situation of unplanned temporary disruptions, advance notice may not be possible.

Notifications will Include:

In the event that a notification needs to be posted the following information will be included unless it is not readily available or known:

goods or services that are disrupted or unavailable;

reason for the disruption;

anticipated duration; and

a description of alternative services or options.

Notifications Options:

When disruptions occur, Starlight will provide notice by:

posting notices in conspicuous places including at the point of disruption, at the main entrance and the nearest accessible entrance to the service disruption -and/or through tenant memos;

contacting customers with appointments;

verbally notifying customers when they are making a reservation or appointment; or

by any other method that may be reasonable under the circumstances.

F) Feedback Process

Starlight will provide customers with the opportunity to provide feedback on the service provided to customers with disabilities. Information about the feedback process will be readily available to all customers and notice of the process will be made available at the Starlight website and through follow-up telephone calls/emails respectively. Methods of providing feedback such as verbally (by telephone at 416-234-8444) or written (hand written, delivered, website or email - info@starlightinvest.com) will be available upon request.

Submitting Feedback:

Customers can submit feedback to: Human Resources

1400- 3280 Bloor Street West, Centre Tower, Toronto, ON, M8X 2X3
(416) 234-8444
info@starlightinvest.com

Customers who provide formal feedback will receive acknowledgement of their feedback, along with any resulting actions based on concerns or complaints that were submitted.

G) Training

Training will be provided to:

all applicable employees who have direct contact and coordination with Starlight’s customers; and

those who are involved in the development and approval of customer service policies, practices and procedures.

Training Provisions:

As reflected in Ontario Regulation 429/07, regardless of the format, training will cover the following:

A review of the purpose of the Accessibility for Ontarians with Disabilities Act, 2005.

A review of the requirements of the Accessibility Standards for Customer Service, Ontario Regulation 429/07.

Instructions on how to interact and communicate with people with various types of disabilities.

Instructions on how to interact with people with disabilities who:

use assistive devices;

require the assistance of a guide dog, service dog or other service animal; or

require the use of a support person.

Instructions on what to do if a person with a disability is having difficulty accessing Starlight’s services.

Starlight’s policies, procedures and practices pertaining to providing accessible customer service to customers with disabilities.

Training Schedule:

Starlight will provide training as soon as practicable and where applicable. Training will be provided to new employees who deal with the public or act on our behalf within the first month of joining Starlight. Revised training will be provided in the event of changes to legislation, procedures and/or practices. Records of training and certificates will be kept

H) Notice of Availability and Format of Documents

Starlight will notify customers that the documents related to the Accessibility Standards for Customer Service are available upon request and in a format that takes into account the customer's disability. Notification will be given by posting the information in a conspicuous place owned or managed by Starlight, the Starlight corporate website and/or any other reasonable method.