AODA – Integrated Accessibility Standards Regulation (IASR) Employment Policy

This policy is intended to meet the requirements of the Integrated Accessibility Standards, Ontario Regulation 19111 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.


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 19111, 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.