Accessibility for Ontarians with Disabilities Act

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The following policy has been established by David's Canada Inc. operating as David's Bridal (David's Bridal) to govern the provision of services in accordance with Regulation 191/11, “Integrated Accessibility Standards” (“Regulation”) under the Accessibility for Ontarians with Disabilities Act, 2005. This policy is effective January 1, 2014.

This policy has been prepared in accordance with the Regulation and addresses how David's Bridal will achieve accessibility by meeting the Regulation's requirements. This policy provides the company's overall approach with respect to providing accessibility supports to people with disabilities. These standards are developed to break down barriers and increase accessibility for persons with disabilities in the areas of information communications and employment. David's Bridal is governed by this policy as well as the Accessibility Standards for Customer Service Policy and the Accessibility for Ontarians with Disabilities Act, 2005 in meeting the accessibility needs of persons with disabilities.

Commitment

David's Bridal is committed to treating all people in a way that allows them to maintain their dignity and independence. We believe in integration and equal opportunity. We are committed to meeting the needs of persons with disabilities in a timely manner, and will do so by preventing and removing barriers to accessibility and meeting accessibility requirements under the Accessibility for Ontarians with Disabilities Act.

This policy will be implemented in accordance with the time frames established by the Regulation.

Definitions

For the purpose of this policy, the following definitions shall apply:

"accessible formats" include those formats required by legislation, which formats may 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 those supports required by legislation, which 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" means,

(a) 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,

(b) a condition of mental impairment or a developmental disability,

(c) a learning disability, or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language,

(d) a mental disorder, or

(e) 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 Plan

David's Bridal will develop, implement, maintain and document an Accessibility Plan outlining the company's strategy to prevent and remove barriers from its workplace and to improve opportunities for persons with disabilities.

The Accessibility Plan, effective January 1, 2014, will be reviewed and updated at least once every five years, and will be posted on the company's website. Upon request, David's Bridal will provide a copy of the Accessibility Plan in an accessible format.

Training Employees

David's Bridal will ensure that training is provided on the requirements of the accessibility standards referred to in the Regulation and continue to provide training on the Human Rights Code as it pertains to persons with disabilities, to:

• all its employees and volunteers;
• all persons who participate in developing David's Bridal policies; and,
• all other persons who provide goods, services or facilities on behalf of the company.

The training will be appropriate to the duties of the employees and other persons and will be provided as soon as practicable.

Employees will be trained when changes are made to the accessibility policy. David's Bridal will keep a record of the training it provides, including the dates on which training is provided and the number of individuals to whom it is provided.

Accessibility Report

David's Bridal shall file an accessibility report with a director annually or as otherwise specified by the legislation.

Information and Communication Standards

Feedback

David's Bridal will ensure, by January 1, 2015, that its process for receiving and responding to feedback is accessible to persons with disabilities by providing, or arranging for the provision of, accessible formats and communications supports, upon request.

Accessible Formats and Communication Supports

Upon request starting as soon as possible and by January 1, 2016, David's Bridal will provide, or will arrange for the provision of accessible formats and communication supports for persons with disabilities in a timely manner that takes into account the person's accessibility needs due to disability and at a cost that is no more than the regular cost charged to other persons.

David's Bridal will consult with the person making the request in determining the suitability of an accessible format or communication support.

David's Bridal, as is necessary, will notify the public about the availability of accessible formats and communication supports upon request.

Emergency Procedure, Plans or Public Safety Information

If David's Bridal prepares emergency procedures, plans or public safety information and makes the information available to the public, the company will provide the information in an accessible format or with appropriate communication supports, as soon as practicable, upon request.

Accessible Websites and Web Content

By January 1, 2021 David's Bridal will ensure that our Internet websites, including web content, conform to the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0, at Level AA except where this is impracticable.

Employment Standards

Scope

The standards set out in this section (Employment Standards) apply in respect of employees only. They do not apply in respect of volunteers and other non-paid individuals.

Recruitment

David's Bridal will notify its employees and the public about the availability of accommodation for applicants with disabilities in its recruitment process by January 1, 2016.

Recruitment, Assessment or Selection Process

By January 1, 2016 David's Bridal will notify job applicants when they are individually selected to participate further in an assessment or selection process that accommodations are available upon request in relation to the materials or processes to be used.

If a selected applicant requests an accommodation, David's Bridal will consult with the applicant and provide, or arrange for the provision of, a suitable accommodation in a manner that takes into account the applicant's accessibility needs due to disability.

Notice to Successful Applicants

By January 1, 2016, when making offers of employment David's Bridal will notify the successful applicant of its policies for accommodating employees with disabilities.

Informing Employees of Supports

David's Bridal will continue to inform its employees of its policies (and any updates to those policies) used to support employees with disabilities, including policies on the provision of job accommodations that take into account an employee's accessibility needs due to disability. This information will be provided to new employees as soon as practicable after commencing employment.

Accessible Formats and Communication Supports for Employees

By January 1, 2016 and upon the request of an employee with a disability, David's Bridal will consult with the employee to provide, or arrange for the provision of, accessible formats and communication supports for information that is needed to perform his/her job, and information that is generally available to other employees.

In determining the suitability of an accessible format or communication support, David's Bridal will consult with the employee making the request.

Workplace Emergency Response Information

David's Bridal will continue to provide individualized workplace emergency response information to employees who have a disability, if the disability is such that the individualized information is necessary, and if David's Bridal is aware of the need for accommodation due to the employee's disability. David's Bridal will provide this information as soon as practicable after becoming aware of the need for accommodation.

Where the employee requires assistance, David's Bridal will, with the consent of the employee, provide the workplace emergency response information to the person designated by David's Bridal to provide assistance to the employee.

David's Bridal will provide the information required under this section as soon as practicable after it becomes aware of the need for accommodation due to an employee's disability.

David's Bridal will review the individualized workplace emergency response information when the employee moves to a different location in the organization, when the employee's overall accommodations needs or plans are reviewed and when the company reviews its general emergency response policies.

Documented Individual Accommodation Plans

By January 1, 2016, David's Bridal will maintain a written process for the development of documented individual accommodation plans for employees with disabilities. The process for the development of documented individual accommodation plans will include the following elements:

1. the manner in which the employee requesting accommodation can participate in the development of the plan;

2. the means by which the employee is assessed on an individual basis;

3. the manner in which the employer can request an evaluation by an outside medical or other expert, at the employer's expense, to assist the employer in determining if accommodation can be achieved and, if so, how accommodation can be achieved;

4. the steps taken to protect the privacy of the employee's personal information;

5. the frequency with which the individual accommodation plan will be reviewed and updated and the manner in which it will be done;

6. if an individual accommodation plan is denied, the manner in which the reasons for the denial will be provided to the employee; and

7. the means of providing the individual accommodation plan in a format that takes into account the employee's accessibility needs due to disability.

If requested, information regarding accessible formats and communications supports provided will also be included in individual accommodation plans.

In addition, the plans will include individualized workplace emergency response information (where required), and will identify any other accommodation that is to be provided.

Return to Work Process

David's Bridal will continue to maintain a documented return to work process for its employees who have been absent from work due to a disability and who require disability-related accommodations in order to return to work.

The return to work process outlines the steps David's Bridal will take to facilitate the return to work and will include documented individual accommodation plans as part of the process.

This return to work process will not replace or override any other return to work process created by or under any other statute (ie., the Workplace Safety Insurance Act, 1997).

Performance Management, Career Development and Advancement & Redeployment

David's Bridal will continue to take into account the accessibility needs of employees with disabilities, as well as individual accommodation plans, when conducting performance management, providing career development and advancement to employees, or when redeploying employees.

ACCESSIBLE PUBLIC SPACES

Where David's Bridal engaged in the new construction or redevelopment of its stores, it will ensure that such construction or redevelopment complies with the requirements of the Regulation with respect to the design of public spaces. More particularly, David's Bridal will ensure that, where new construction or redevelopment affects the design of its service counters, the Company will design those service counters in a manner which allows our customers to receive our services in an accessible fashion.

Maintenance of Public Spaces

On an annual basis (or more frequently where specifically required) our store managers will review the suitability of any accessible elements in our stores, and will arrange for the repair or replacement of any such elements which are deemed to require such.

Where the availability of accessible elements is disrupted on a temporary basis due to construction, repair or other circumstances, we will provide notice of such disruption in our stores. Our employees will work with customers who have disabilities to assist them in accessing our services in an alternate manner during any such disruption. In such circumstances, the customer shall be consulted concerning any supports which may be required and which may be available in order to accommodate for the absence of the accessible element.

Questions about this policy

This policy has been developed to break down barriers and increase accessibility for persons with disabilities in the areas of information and communications and employment. If anyone has a question about the policy, or if the purpose of a policy is not understood, an explanation will be provided by:

Darlene Huff
David's Bridal Canada
Regional Director, Canada
Phone: 416-662-6871
Fax: 610-943-5016

Accessibility for Ontarians with Disabilities Act, 2005

Integrated Accessibility Standards - Multi Year Plan

(Applicable to persons in the Province of Ontario only)

Section	Initiative	Description	Action	Status	Compliance Date
3	Establishment of Accessibility Policies	3.(1) Every obligated organization shall develop, implement and maintain policies governing how the organization achieves or will achieve accessibility through meeting its requirements under the accessibility standards referred to in this Regulation.	David's Bridal has developed, implemented and is maintaining policies governing how it will achieve accessibility through meeting its requirements under the accessibility standards.	Completed	January 1, 2014
4	Accessibility Plans	4.(1) Large organizations shall, (a) establish, implement, maintain and document a multi-year accessibility plan, which outlines the organization's strategy to prevent and remove barriers and meet its requirements under this Regulation; (b) post the accessibility plan on their website, if any, and provide the plan in an accessible format upon request; and (c) review and update the accessibility plan at least once every five years.	David's Bridal has established and implemented a multi-year accessibility plan in accordance with the regulations. David's Bridal will post the accessibility plan on their website by July 1. David's Bridal will review and update the accessibility plan at least once every five years.	Completed	January 1, 2014 development of plan; posted July 1, 2015
7	Training	7.(1) Every obligated organization shall ensure that training is provided on the requirements of the accessibility standards referred to in this Regulation and on the Human Rights Code as it pertains to persons with disabilities to, (a) all employees, and volunteers; (b) all persons who participate in developing the organization's policies; and (c) all other persons who provide goods, services or facilities on behalf of the organization.	David's Bridal has provided training on the requirements of the accessibility standards referred to in this Regulation to all employees, all persons involved in developing the policies, and all persons who provide goods, services, or facilities on behalf of David's Bridal. David's Bridal has completed this training for these individuals regarding the Code as well.	Completed; Ongoing for New Hires	January 1, 2015

 

Section	Initiative	Description	Action	Status	Compliance Date
11	Feedback	11.(1) Every obligated organization that has processes for receiving and responding to feedback shall ensure that the processes are accessible to persons with disabilities by providing or arranging for accessible formats and communications supports, upon request.	David's Bridal has processes for receiving and responding to feedback. Upon request, these processes are accessible to persons with disabilities through accessible formats and communications supports.	Completed	January 1, 2015
12	Accessible Formats & Communication Supports	12. (1) Except as otherwise provided, every obligated organization shall upon request provide or arrange for the provision of accessible formats and communication supports for persons with disabilities, (a) in a timely manner that takes into account the person's accessibility needs due to disability; and (b) at a cost that is no more than the regular cost charged to other persons.	Ongoing	Upon Request.	January 1, 2016
12		12. (2) The obligated organization shall consult with the person making the request in determining the suitability of an accessible format or communication support.	Ongoing	Completed	January 1, 2016
12		12. (3) Every obligated organization shall notify the public about the availability of accessible formats and communication supports.	Ongoing	Completed	January 1, 2016
13		13. (1) If an obligated organization prepares emergency procedures, plans or public safety information and makes the information available to the public, the obligated organization shall provide the information in an accessible format or with appropriate communication supports, as soon as practicable , upon request.	David's Bridal prepares emergency procedures, plans and public safety information, and it will make that information publicly available and will provide the information in an accessible format or with appropriate communication supports, as soon as practicable, upon request.	Completed	January 1, 2012
13		13. (2) Obligated organizations that prepare emergency procedures, plans or public safety information and make the information available to the public shall meet the requirements by January 1, 2012.	David's Bridal prepares emergency procedures, plans or public safety information, it will then make that information publicly available and will provide the information in an accessible format or with appropriate communication supports, as soon as practicable, upon request.	Completed	January 1, 2012
14	Accessible Websites & Web Content	14.(2) Designated public sector organizations and large organizations shall make their internet websites and web content conform with the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG)2.0, initially at Level A and increasing to Level AA, and shall do so in accordance with the schedule set out in this section.	David's Bridal shall make their internet websites and web content conform with the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG)2.0, initially at Level A and increasing to Level AA, and shall do so in accordance with the schedule set out in this section.	In Process	January 1, 2014 New internet websites and web content on those sites must conform with WCAG 2.0 Level A. January 1, 2021 All internet websites and web content must conform with WCAG 2.0 Level AA, other than, success criteria 1.2.4 Captions (Live), success criteria 1.2.5 Audio Descriptions (Pre-recorded).

 

Section	Initiative	Description	Action	Status	Compliance Date
22	Recruitment - General	22. Every employer shall notify its employees and the public about the availability of accommodation for applicants with disabilities in its recruitment processes.	David's Bridal shall notify its employees and the publick about the availability of of accommodation for applicants with disabilities in its recruitment processes.	Completed.	January 1, 2016
23	Recruitment, Assessment or Selection Process	23.(1) During a recruitment process, an employer shall notify job applicants, when they are individually selected to participate in an assessment or selection process, that accommodations are available upon request in relation to the materials or processes to be used. (2) If a selected applicant requests an accommodation, the employer shall consult with the applicant and provide or arrange for the provision of a suitable accommodation in a manner that takes into account the applicant's accessibility needs due to disability.	During a recruitment process, David's Bridal shall notify job applicants, when they are individually selected to participate in an assessment or selection process that accommodations are available upon request in relation to the materials or processes to be used. If a selected applicant requests an accommodation, David's Bridal shall consult with the applicant and provide or arrange for the provision of a suitable accommodation in a manner that takes into account the applicant's accessibility needs due to disability.	Completed.	January 1, 2016
24	Notice to Successful Applicants	24. Every employer shall, when making offers of employment, notify the successful applicant of its policies for accommodating employees with disabilities.	David's Bridal notifies its successful applicants of its policies for accommodating employees with disabilities in its Associate Handbook.	Complete	January 1, 2016
25	Informing Employees of Supports	25.(1) Every employer shall inform its employees of its policies used to support its employees with disabilities, including, but not limited to, policies on the provision of job accommodations that take into account an employee's accessibility needs due to disability.	David's Bridal will inform its associates of its policies used to support its associates with disabilities.	Completed. This is covered during orientation.	January 1, 2016
25		25. (2) Employers shall provide the information required under this section to new employees as soon as practicable after they begin their employment.	David's Bridal will inform its new associates of its policies used to support its associates with disabilities as soon as practicable.	Completed. This is covered during orientation.	January 1, 2016
25		25.(3)Employers shall provide updated information to its employees whenever there is a change to existing policies on the provision of job accommodations that take into account an employee's accessibility needs due to disability.	David's Bridal will inform its associates of any updated policies used to support its associates with disabilities.	Ongoing.	January 1, 2016
26	Accessible Formats & Communication Supports for Employees	26.1 In addition to its obligations under section 12, where an employee with a disability so requests it, every employer shall consult with the employee to provide or arrange for the provision of accessible formats and communication supports for, (a) information that is needed in order to perform the employee's job; and (b) information that is generally available to employees in the workplace.	David's Bridal will consult with its associates to provide accessible formats and communication supports for information needed to perform their jobs and other information generally available to other associates in the workplace.	Completed.	January 1, 2016
26		26.2. The employer shall consult with the employee making the request in determining the suitability of an accessible format or communication support.	David's Bridal will consult with the associate making the request to determine the suitability an accessible format or communication support.	See 26.1 Completed.	January 1, 2016
27	Workplace Emergency Response Information	27.(1) Every employer shall provide individualized workplace emergency response information to employees who have a disability, if the disability is such that the individualized information is necessary and the employer is aware of the need for accommodation due to the employee's disability.	Completed	Ongoing	January 1, 2012
27		(2) If an employee who receives individualized workplace emergency response information requires assistance and with the employee's consent, the employer shall provide the workplace emergency response information to the person designated by the employer to provide assistance to the employee.	Completed	Ongoing	January 1, 2012
27		(3) Employers shall provide the information required under this section as soon as practicable after the employer becomes aware of the need for accommodation due to the employee's disability.	Completed	Ongoing	January 1, 2012
27		(4) Every employer shall review the individualized workplace emergency response information, (a) when the employee moves to a different location in the organization; (b) when the employee's overall accommodations needs or plans are reviewed; and (c) when the employer reviews its general emergency response policies.	Completed	Ongoing	January 1, 2012
28	Documented Individual Accommodation Plans	28.(1) Employers, other than employers that are small organizations, shall develop and have in place a written process for the development of documented individual accommodation plans for employees with disabilities.	David's Bridal will develop a written process for the development of documented individual accommodation planes for employees with disabilities.	See 26.1 Completed.	January 1, 2016
28		28 (2) The process for the development of documented individual accommodation plans shall include the following elements: 1. The manner in which an employee requesting accommodation can participate in the development of the individual accommodation plan. 2. The means by which the employee is assessed on an individual basis. 3. The manner in which the employer can request an evaluation by an outside medical or other expert, at the employer's expense, to determine if and how accommodation can be achieved. 4. The manner in which the employee can request the participation of a representative from their bargaining agent, where the employee is represented by a bargaining agent, or other representative from the workplace, where the employee is not represented by a bargaining agent, in the development of the accommodation plan. 5. The steps taken to protect the privacy of the employee's personal. 6. The frequency with which the individual accommodation plan will be reviewed and updated and the manner in which it will be done. 7. If an individual accommodation plan is denied, the manner in which the reasons for the denial will be provided to the employee. 8. The means of providing the individual accommodation plan in a format that takes into account the employee's accessibility needs due to disability.	David's Bridal will develop a written process for the development of documented individual accommodation plans for employees with disabilities that meets the requirements set forth in this section.	See 26.1 Completed.	January 1, 2016
29	Return to Work Process	29.(1) Every employer, other than an employer that is a small organization, (a) shall develop and have in place a return to work process for its employees who have been absent from work due to a disability and require disability-related accommodations in order to return to work; and (b) shall document the process.	David's Bridal will develop a written process for the development of documented Return to Work Process that meets the requirements set forth in this section.	See 26.1 Completed	January 1, 2016
29		29. (2) The return to work process shall, (a) outline the steps the employer will take to facilitate the return to work of employees who were absent because their disability required them to be away from work; and (b) use individual In Process documented accommodation plans, as described in section 28, as part of the process.	David's Bridal will develop a written process for the development of documented Return to Work Process that meets the requirements set forth in this section.	See 26.1 Completed.	January 1, 2016
29		29. (3) The return to work process referenced in this section does not replace or override any other return to work process created by or under any other statute.	David's Bridal will develop a written process for the development of a documented Return to Work Process that does not replace or override any other return to work process created by or under any other statute.	See 26.1 Completed.	January 1, 2016
30	Performance Management	30.(1) An employer that uses performance management in respect of its employees shall take into account the accessibility needs of employees with disabilities, as well as individual accommodation plans, when using its performance management process in respect of employees with disabilities.	David's Bridal shall take into account the accessibility needs of its associates with disabilities as well as individual accommodation plans when using its performance management process.	Ongoing	January 1, 2016
31	Career Development & Advancement	31.(1) An employer that provides career development and advancement to its employees shall take into account the accessibility needs of its employees with disabilities as well as any individual accommodation plans, when providing career development and advancement to its employees with disabilities.	David's Bridal shall take into account the accessibility needs of its associates with disabilities as well as individual accommodation plans when providing career development and advancement to associates with disabilities.	Ongoing	January 1, 2016
32	Redeployment	32.(1) An employer that uses redeployment shall take into account the accessibility needs of its employees with disabilities, as well as individual accommodation plans, when redeploying employees with disabilities.	David's Bridal shall take into account the accessibility needs of its associates with disabilities as well as individual accommodation plans when redeploying associates with disabilities.	Ongoing.	January 1, 2016