INTRODUCTION
The Ontario government passed the Accessibility for Ontarians with Disabilities Act (the “AODA”) in 2005. Its goal is to make Ontario accessible for persons with disabilities by 2025. The Integrated Accessibility Standards Regulations (the “IASR”) under the AODA require that, effective January 1, 2014, Levi Strauss & Co. (Canada) Inc. (“LSC”) establish, implement, maintain and document a multi-year accessibility plan which outlines LSC’s strategy to prevent and remove barriers for persons with disabilities and to meet LSC’s requirements under the IASR.
The review of the latest 2014-2021 accessibility plan outlines the policies and actions that LSC has and will continue to implement to improve opportunities for people with disabilities. LSC strives to meet the needs of its employees and customers with disabilities and is working to remove and prevent barriers to accessibility. LSC is committed to fulfilling our requirements under the AODA. This plan outlines the steps LSC is taking to meet those requirements and improve opportunities for people with disabilities.
Our plan shows how LSC will live up to its commitments in making Ontario an accessible province for all Ontarians, including training employees as soon as practicable after hiring and provide training in respect of changes to LSC policies, and maintaining records of the training provided, including the dates on which the training was provided and the individuals to whom it was provided.
This plan will be reviewed and updated every five years.
Therefore, in accordance with the requirements set out in the IASR, LSC will, without limitation:
• Establish, review and update this plan in accordance with requirements;
• Post this plan in its offices in a public location;
• Provide this plan in an accessible format, upon request; and
• Review and update this plan at least once every five years.
STATEMENT OF COMMITMENT
Our policies prohibit discrimination and harassment of any kind by any employee or outside person on LSC premises, including disability. Discrimination, harassment, slurs or jokes based on a person's mental or physical disability, as well as race, color, creed, religion, national origin, citizenship, age, sex, sexual orientation, or marital status, as well as other individual attributes or statuses that may be protected under applicable law, will not be tolerated. LSC intends to provide a work environment that is fair and non-discriminatory. We are committed to treating all people in a way that allows them to maintain their dignity and independence and to meeting the needs of people with disabilities in a timely manner, and will do so, in respect of individuals with disabilities, by preventing and removing barriers to accessibility and meeting accessibility requirements under the AODA.
PAST ACHIEVEMENTS TO REMOVE AND PREVENT BARRIERS
a)Accessibility Standards for Customer Service
LSC has been and is committed to providing exceptional service to our customers, third parties and visitors, including those with disabilities (collectively, the “Customers.”)
LSC has created a policy in relation to this standard and achieved compliance on or before December 31, 2012. Specifically, the following measures have been implemented:
Assistive devices
LSC has provided training, as required, to employees on the various assistive devices that may be used by Customers with disabilities in order to access goods and services. LSC has provided training on how to use the assistive devices available on LSC’s premises.
Communication
LSC has made reasonable attempts to communicate with Customers with disabilities in ways that take into account their disabilities.
Service animals
LSC has welcomed the use of service animals and has provided access to non-restricted areas, unless otherwise precluded by law.
Support persons
A person who supports a Customer with a disability may accompany that person on our premises and areas open to the public.
Notice of temporary disruption
In the event of a planned or unexpected disruption in its facilities or provision of services, LSC has put in place processes to notify Customers with disabilities as soon as practicable. Notice will be posted at the front of the store (or office] that is affected. The 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. Alternatively, for the visually impaired, staff will verbally provide such notice, if possible.
b) Employment and Training
LSC has implemented processes to ensure its employees are properly trained in AODA compliance. This includes the following:
Training for employees
LSC has provided training, as required under the Accessibility Standards for Customer Service, Ont. Reg. 429/07 (“Customer Service Standards”) to employees. New employees are trained as soon as practicable. This training is provided to employees as part of our New Hire Program and includes the following:
- An overview of the AODA and the requirements of the Customer Service Standards;
- How to effectively interact and communicate with Customers with various types of disabilities;
- How to interact with Customers with disabilities who use an assistive device and/or require the assistance of a service animal or a support person;
- How to use equipment or devices available on LSC’s premises that may help Customers with disabilities access goods and services;
- What to do if a Customer with a disability is having difficulty accessing LSC’s goods and services;
- LSC’s policy, practices and procedures related to the Customer Service Standard.
LSC has recorded the names of employees who have been trained and the dates that training has been provided. We will continue to record any new employees who have been trained.
c) Information and Communications
LSC has implemented the following processes to ensure AODA information is properly communicated:
Feedback process
Customers, third parties and visitors who wish to provide feedback on the way LSC provides goods and services to people with disabilities may do so in person, by telephone, in writing or by e-mail to LSC’s Customer Service Centre at: 1-888-501-LEVI or by going to our website at: https://help.levi.com/hc/en-ca/requests/new to submit. Complaints will be addressed according to our complaint management procedures and processed in a timely manner.
Modifications to this or other policies
LSC is committed to developing and updating Customer service policies and procedures that respect and promote the dignity and independence of Customers with disabilities. When making changes to this policy, LSC will consider the potential impact on Customers with disabilities.
Availability of LSC Accessibility Policy
Upon request, Customers may view LSC’s policy under the Accessibility Standards for Customer Service.
STRATEGIES AND ACTIONS
a) Customer Service
As set out above, LSC is committed to providing accessible customer service to people with disabilities. We will provide goods and services and facilities to people with disabilities with the same quality and timeliness as others.
This includes the following:
- LSC will continue to make reasonable attempts to communicate with Customers with disabilities in ways that take into account their disabilities.
- LSC will continue to welcome the use of service animals and provide access to non-restricted areas, unless otherwise precluded by law.
- A person who supports a Customer with a disability may accompany that person on our premises and areas open to the public.
- In the event of a planned or unexpected disruption in its facilities or provision of services, LSC will notify Customers with disabilities as soon as practicable.
ACCESSIBLE EMERGENCY INFORMATION
Upon request, LSC is committed to providing customers, third parties and visitors with publicly available emergency information in an accessible way. We will also provide employees with disabilities with individualized emergency response information, when necessary, as further set out below.
b) TRAINING
LSC is committed to providing training in the requirements of the AODA and human rights legislation. It will provide training to employees, volunteers and other staff members on Ontario’s accessibility laws under the AODA, as well as under the Ontario Human Rights Code as it relates to people with disabilities. Training will be provided in a method that best suits the duties of employees, volunteers and other staff members. A record will be kept of such training.
LSC has taken and will take the following steps to ensure employees and volunteers are provided with the training needed to meet Ontario’s accessibility laws:
- Determine and ensure appropriate training is provided on the requirements of the IASR, the Customer Service Standards and the Ontario Human Rights Code as it relates to persons with disabilities;
- Achieve accessibility for persons with disabilities by 2025;
- Train employees and volunteers on the requirements of the Ontario Human Rights Code as it pertains to persons with disabilities;
- Regularly ensure training is provided to employees and volunteers based on changes to the prescribed policies and the AODA’s standards and guidelines.
c) INFORMATION AND COMMUNICATIONS
LSC is committed to meeting the communication needs of people with disabilities. We will consult with people with disabilities to determine their information and communication needs.
LSC, in collaboration with our IT team, partners with a third party provider to audit our site for compliance with World Wide Web Consortium Web Content Accessibility Guidelines (WCAG).
d) EMPLOYMENT
LSC is committed to enhancing fair and accessible employment practices, as defined by the IASR.
Workplace Emergency Response Information
Where LSC is aware that an employee has a disability requiring accommodation, individualized workplace emergency response plans are and will be provided to the employee as soon as practicable.
LSC will take the following steps to ensure individualized workplace emergency response plans are prepared for an employee who has been identified as needing an individualized plan.
- Work with the employee to prepare an individualized emergency plan to assist him/her in evacuating the workplace in the event of an emergency;
- Communicate the plan to the employee’s respective manager and Joint Workplace Health, Safety and Wellness Committee on an “as needed” basis;
- Review the emergency plan(s) on an annual basis with all relevant parties and plan to modify as needed.
LSC will take the following steps to notify the public and staff that, when requested, LSC will accommodate people with disabilities during the recruitment, selection and assessment processes and when people are hired.
- Review and, as necessary, modify existing recruitment policies, procedures and processes;
- Incorporate in job advertisements or postings a statement that LSC will accommodate people with disabilities during these processes to the extent required by applicable law;
- Work with external website provider to ensure that LSC’s external Web pages are compliant with the Information and Communication Standards under the IASR’s requirements;
- Provide new hires with information about LSC’s accommodation practices and policies.
LSC will take the following steps to develop and implement a process for developing individual accommodation plans and return-to-work policies for employees that have been absent due to a disability:
- Review and assess and, if necessary, modify its existing policies to ensure inclusion of a process for the development of documented individual accommodation plans for employees with disabilities, if such plans are necessary;
- Train employees on such policies;
- Ensure that the process for the development of documented individual accommodation plans includes the following elements, in accordance with the provisions of the IASR:
- The manner in which the employee requesting accommodation can provide input to the development of the plan;
- The means by which the employee is assessed;
- The manner in which LSC can request an evaluation by an outside medical or other expert, at the LSC’s expense, to assist LSC in determining if and how accommodation can be achieved;
- Established steps to protect the privacy of the employee’s personal information;
- An outline of the frequency in which individual accommodation plans will be reviewed and updated and the manner in which this will be done;
- Employee notification of the reasons for the denial, if an individual accommodation plan is denied;
- The means of providing the individual accommodation plan in a format that takes into account the employee’s accessibility needs;
- If accommodation plans are established, ensure inclusion of:
- Required workplace emergency response information;
- Any information regarding accessible formats and communication supports that have been provided for or arranged, in order to provide the employee with:
- Information that is needed in order to successfully perform the employee’s essential job functions;
- Information that is generally available to employees in the workplace.
- Identification of any other accommodation(s) that need to be provided to the employee.
LSC will ensure that the return to work process, as set out in its existing policies, outlines the steps LSC will take to facilitate the employee’s return to work after a disability-related absence, outlines the development of a written return to work plan for such employees, and requires the use of accommodation plans, as discussed above, in the return to work process.
LSC will take the following steps to ensure the accessibility needs of employees with disabilities are taken into account when using performance management, career development and redeployment processes:
- Ensure that supervisors and managers are trained in the importance of taking into account the accessibility needs of employees with disabilities when engaging in performance management, career development or redeployment. This will occur at regular intervals and when onboarded.
- Consider the accessibility needs of employees with disabilities in meeting performance standards, in the following situations:
- When using its performance management process in respect of employees with disabilities;
- When providing career development and advancement to its employees with disabilities
- When redeploying employees with disabilities;
- When developing Individual Accommodation Plans (IAPs).
LSC will take the following steps to prevent and remove other accessibility barriers identified:
- Conduct regular auditing of the workplace to identify accessibility barriers;
- Comply with ongoing legal obligations under the AODA;
- If barriers are identified, meet with the appropriate departments (Legal; Human Resources) to implement plan to eliminate such barriers.
e) DESIGN OF PUBLIC SPACES
LSC will consider the Accessibility Standards for the Design of Public Spaces when building or making modifications to public spaces after January 1, 2017 as and if required by such standards if and when implemented. Public spaces include:
- Outdoor public eating areas;
- Outdoor paths of travel like sidewalks, ramps, stairs, curb ramps, rest areas and accessible pedestrian signals;
- Accessible off-street parking; and
- Service-related elements like service counters, fixed queuing lines and waiting areas.
If it has any, LSC will put procedures in place to prevent service disruptions to its accessible parts of its public spaces including procedures for preventative and emergency maintenance of such spaces.
In the event of a service disruption, LSC will notify the public of the service disruption and alternatives available.
For more information
For more information on this accessibility plan, please contact Human Resources at:
• Phone: 905-763-4400
• Contact Name: Aaron Brown-Kert
• Email: MCanada-HR@levi.com
Accessible formats of this document are available free upon request from: LSC Human Resources.