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Accessibility Policy and Plan

Effective date: November 30, 2019

Index:
Accessibility Policy and Plan
Accessibility Policy Customer Service Standard

Introduction

Vanguard is committed to treating all people in a manner that allows them to maintain their dignity and independence. We believe in integration and equal opportunity. We are committed to meeting the needs of people with disabilities in a timely manner, and will do so by identifying, preventing and removing barriers to accessibility and meeting the accessibility requirements under the Accessibility for Ontarians with Disabilities Act, 2005 (AODA). 

The purpose of Vanguard's Accessibility Policies and Plans is to outline the commitment of Vanguard Investments Canada Inc. (Vanguard) to improving accessibility for our clients and crew members, and our strategy to identify, prevent and remove barriers to accessibility for persons with disabilities. Vanguard will update this Policy and Plan at least every five years to reflect progress and will consult with crew members and other stakeholders in the development and implementation of this Accessibility Policy and Plan.

Vanguard's Accessibility Policies and Plans are intended to meet the requirements of the Customer Service Standard, Ontario Regulation 429/07 and Integrated Accessibility Standards, Ontario Regulation 191/11 (IASR) made pursuant to AODA. This document will be posted on Vanguard's external website and internal intranet website for Ontario, and it is available upon request in an accessible format.

This policy applies to Canada. It was last reviewed November 2019 and last updated November 2019.

Policy requirements

Employment Standard

Vanguard is committed to fair and equitable employment practices. If a crew member identifies any barrier to accessibility, Vanguard will evaluate and partner with the crew member to identify any reasonable and appropriate accommodation in accordance with the AODA and the Human Rights Code.

Training

Vanguard is committed to training Ontario crew on Ontario's accessibility laws, including customer service standards and the requirements of the Integrated Accessibility Standards Regulation (IASR) and the Ontario Human Rights Code, as it relates to individuals with disabilities. 

Training will be provided in a way that best suits the duties of crew members and volunteers (if applicable). 

Vanguard will take the following steps to ensure crew are provided with the training needed to meet Ontario's accessibility laws:

  • Assess duties and specific training needs of crew members.
  • Deliver training modules for all crew members in accordance with the AODA's customer service standard (the "Customer Service Training").
  • Deliver training modules on the accessibility requirements under the AODA, IASR and the Ontario Human Rights Code (the "IASR Training") as required to crew members.
  • Conduct the Customer Service Training and IASR Training for new crew members, when changes are made to their role that will trigger additional training, or there are updates to Vanguard's accessibility policy and plan.
  • Determine an appropriate mechanism for managing and tracking completion of training by crew members. 

Recruitment, assessment, selection and onboarding process

Vanguard will take the following steps to notify the public, job applicants and its crew members that Vanguard will accommodate applicants with disabilities during the recruitment, assessment, selection and onboarding process:

  • Review job posting mechanisms for positions in Ontario.
  • Incorporate language into all job postings for positions in Ontario notifying applicants that Vanguard will accommodate disabilities during the recruitment and selection process.
  • Incorporate language into all notifications to applicants for interviews in Ontario that accommodation is available upon request.
  • Ensure that any job applicants self-identifying as requiring accommodation in the recruitment process are consulted with to determine their individual accommodation needs.
  • Review the current hiring process (assessments, interview rooms) to ensure barriers may be removed or accessible features provided, upon request.
  • Review employment policies and procedures to ensure they reflect our commitment to employment practices which attract and retain crew members with disabilities.
  • Complete training on Vanguard's accessibility policy and plan during onboarding (i.e. during first 30 days of hire)

Providing accessible formats and communication support 

Vanguard will provide crew members with accessible formats and communication support for workplace information, including policies and other information needed by the crew member to perform their job, when requested.  To make a request, crew members must contact Crew Relations and identify the specific workplace information at issue and the accessible format or communication support being requested. 

Documented individual accommodation

Vanguard will take the following steps for developing individual accommodation plans for crew members self-identifying as having a disability:

  • Consult with crew members to determine accommodation needs.
  • Ensure individualized accommodation plans are developed for crew members in accordance with the elements of such plans outlined in the AODA, using Vanguard's accommodation plan form.
  • Where necessary, coordinate the above with any steps currently taken by any applicable benefits providers. 

Return to Work Process and Plan

Vanguard will take the following steps for developing return-to-work process and plan for crew members that have been absent due to a disability:

  • Consult with crew members to determine accommodation needs.
  • Ensure return-to-work processes and plans are developed for crew members who are absent from work due to a disability.
  • Where necessary, coordinate the above with any steps currently taken by any applicable benefits providers.

Performance management, career development and advancement

Vanguard will take the following steps to ensure the accessibility needs of crew members with disabilities are taken into account if Vanguard is using performance management, career development and/or redeployment processes:

  • Assess current performance review, career development and/or redeployment processes to ensure accessibility features are incorporated and accessibility needs are considered.
  • Consult with any individualized accommodation plans when performing assessments of performance, managing career development or redeploying crew members.
  • Ensure career development and advancement practices and processes take into account individualized accommodation plans.
  • Ensure equal opportunities for crew members with disabilities to undertake professional development, such as attending courses or seminars.

Workplace emergency response information

Vanguard encourages any crew who have a disability that requires accommodation in the event of a workplace emergency to contact Crew Relations. Vanguard will provide individualized workplace emergency response information to crew members who have a disability if the disability is such that individualized information is necessary and Vanguard is aware of the need for accommodation.

Vanguard will take the following steps to ensure individualized workplace emergency response plans are in place:

  • Develop and implement a process for consulting with crew members to determine accommodation needs.
  • Where accommodation needs are identified, work with crew members requiring accommodation to develop an individualized workplace emergency response plan.
  • Ensure consent is obtained from the crew member(s) to share information with those designated to provide assistance to the crew member in the event of an emergency.

Reporting compliance

Vanguard will file accessibility reports with Ontario's Ministry of Economic Development, Employment and Infrastructure as required under the AODA.

Feedback process

Crew members who wish to provide feedback on the way Vanguard provides goods and services to people with disabilities can contact Vanguard via email, phone or mail at:

Email: HR_Americas@vanguard.com

Phone: 416-263-7100

Mail:
Vanguard Investments Canada Inc.
Bay Adelaide Centre
22 Adelaide St. West
Suite 2500
Toronto, ON M5H 4E3

Vanguard will take the following steps to ensure our existing feedback process is accessible to people with disabilities upon request:

  • Conduct an assessment of the feedback process to ensure feedback mechanisms are accessible. Where possible, consult with the person making the request or providing the feedback as to the suitability of feedback mechanisms are accessible.
  • As needed, provide alternative formats for crew members to provide feedback.

Definitions

Term

Definition

Accessible formats

Accessible formats may include, but are not limited to, large print, recorded audio and electronic formats and other formats usable by persons with disabilities.

Communication supports

Communication supports may include, but are not limited to, captioning, alternative and augmentative communication supports, plain language, sign language and other supports that facilitate effective communications.

Disability

Disability can be defined as follows:

  • 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 a 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.

Accessibility Policy and Plan - Clients

Effective date: November 30, 2019

Introduction

Vanguard is committed to treating all people in a manner that allows them to maintain their dignity and independence. We believe in integration and equal opportunity. We are committed to meeting the needs of people with disabilities in a timely manner, and will do so by identifying, preventing and removing barriers to accessibility and meeting the accessibility requirements under the Accessibility for Ontarians with Disabilities Act, 2005 (AODA).

The purpose of Vanguard's Accessibility Policies and Plans is to outline the commitment of Vanguard Investments Canada Inc. (Vanguard) to improving accessibility for our clients and crew members, and our strategy to identify, prevent and remove barriers to accessibility for persons with disabilities. Vanguard will update this Policy and Plan at least every five years to reflect progress and will consult with crew members and other stakeholders in the development and implementation of this Accessibility Policy and Plan.

Vanguard's Accessibility Policies and Plans are intended to meet the requirements of the Customer Service Standard, Ontario Regulation 429/07 and Integrated Accessibility Standards, Ontario Regulation 191/11 (IASR) made pursuant to AODA. This document will be posted on Vanguard's external website and internal intranet website for Ontario, and it is available upon request in an accessible format.

This policy applies to Canada. It was last reviewed November 2019 and last updated November 2019.

Customer Service Standard

In accordance with this Policy and Plan, reasonable efforts will be made to ensure that:

  • Persons with disabilities are provided equal opportunity to obtain, use and benefit from Vanguard's goods and services.
  • Goods and services are provided in a manner that respects the dignity and independence of persons with disabilities.
  • The goods and services provided to persons with disabilities are integrated with the provision to others unless an alternative measure is necessary to allow a person with a disability to benefit. The alternative measure may be temporary or permanent.
  • Communications with a person with a disability are conducted in a manner that takes the person's disabilities into account.

Persons with disabilities may use assistive devices, service animals and support persons as is necessary to access Vanguard's goods and services unless superseded by other legislation.

Assistive devices

Vanguard welcomes all assistive devices on our premises while accessing our goods and services.

Service animals

Vanguard welcomes people with disabilities and their service animals. Service animals are allowed on the parts of our premises that are open to the public.

Support persons

A client with a disability who is accompanied by a support person will be allowed to have that person accompany them on our premises.

Notice of temporary disruption

In the event of a planned or unexpected disruption to services or facilities for clients with disabilities, Vanguard will notify affected persons promptly. This notice will include information about the reason for the disruption, its anticipated length of time, and a description of alternative facilities or services, if available. The notice will be clearly placed at the main entrances of our facilities, as well as where the disruption is taking place.

Information and Communication Standard

Feedback process

Individuals who wish to provide feedback on the way Vanguard provides goods and services to people with disabilities can contact Vanguard via email, phone or mail at:

Email: HR_Americas@vanguard.com

Phone: 416-263-7100

Mail:
Vanguard Investments Canada Inc.
Bay Adelaide Centre
22 Adelaide St. West
Suite 2500
Toronto, ON M5H 4E3 

Vanguard will take the following steps to ensure our existing feedback process is accessible to people with disabilities upon request:

  • Conduct an assessment of the feedback process to ensure feedback mechanisms are accessible. Where possible, consult with the person making the request or providing the feedback as to the suitability of feedback mechanisms are accessible.
  • As needed, provide alternative formats for customers to provide feedback.

Accessible formats and communication supports

Vanguard is committed to meeting the communication needs of all people. When requested and where possible, Vanguard will provide publicly available information and communications materials in accessible formats or with communication supports in a timely manner and at no additional cost to the requestor.

This includes publicly available information about our goods, services and facilities, as well as publicly available emergency information. Vanguard will consult with people to determine their information and communication needs.

Vanguard will take the following steps to make sure all publicly available information is made accessible upon request:

  • Review accessible formats and communication supports currently available at Vanguard.
  • Review the current process in place for requesting accessible formats and communication supports.
  • Where practical, update the current process for requesting accessible formats and communication supports.
  • Where practical, create additional accessible formats and communication supports for publicly available information.
  • Develop a process for responding to, approving or declining a request.
  • Where practical, incorporate language in marketing materials and on Vanguard's external website to advise that, in accordance with AODA, accessible format may be made available upon request.

Request process

Individuals who need to request publicly available information and communications materials in accessible formats can contact Vanguard via email, phone or mail at:

Email: accessibility@vanguard.com

Phone: 416-263-7100

Mail:
Vanguard Investments Canada Inc.
Bay Adelaide Centre
22 Adelaide St. West
Suite 2500
Toronto, ON M5H 4E3

The response for approving or declining a request will be shared in the same way the requestor initiated the process.

Accessible websites and web content

Vanguard strives to ensure that online content is accessible.

Where practical, Vanguard will strive to ensure that any new websites and content on any new websites conforms with level A and level AA of the Web Content Accessibility Guidelines (WCAG) version 2.0 as recommended by the World Wide Web Consortium (W3C).

By January 1, 2021, where practical, Vanguard will take the following steps to make websites and content conform with WCAG 2.0, Level A and Level AA:

  • Ensure IT and Marketing are aware of the Integrated Accessibility Standards, Ontario Regulation (IASR) requirements with respect to accessible websites and web content
  • Ensure IT and Marketing conduct an assessment of current web functionality on new websites to ensure compliance and adequate accessibility features are in place by 2021.