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(D) Dfc Auto Group

Accessibility for Ontarians with Disabilities Act

DFC Auto Group Inc. ("DFC Auto Group" or the "Company") is committed to treating all people in a way that allows them to maintain their dignity and independence, and DFC Auto Group believes in integration and equal opportunity.

This policy has been established by DFC Auto Group to meet the requirements of Ontario Regulation 191/11 (the "Regulation"), under the Accessibility for Ontarians with Disabilities Act, 2005 (the "AODA").

This policy addresses how DFC Auto Group will achieve accessibility by meeting the requirements set out in the Regulation.  This policy provides DFC Auto Group'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, employment and customer service.

In meeting the accessibility needs of persons with disabilities, DFC Auto Group is governed by this policy and the Accessibility Standards for Customer Service Policy, as well as any other requirements set out in the AODA and the Regulation.

GENERAL
Commitment

DFC Auto Group is committed to treating all people in a way that allows them to maintain their dignity and independence.  DFC Auto Group believes in integration and equal opportunity.  DFC Auto Group is committed to meeting the accessibility 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 AODA.

Definitions

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

"accessible 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" 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,

  • 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.

Self-Service Kiosks

The Company shall have regard to the accessibility for persons with disabilities when designing, procuring or acquiring self-service kiosks.  For this purpose, "kiosk" means an interactive electronic terminal, including a point-of-sale device, intended for public use that allows users to access one or more services or products or both.  This may include an electronic signing pad (i.e. for receiving packages).

Training

DFC Auto Group will ensure that training is provided on the requirements of the accessibility standards referred to in the Regulation (including, a review of the requirements set out in the Customer Service Standards section below), and on the Human Rights Code as it pertains to persons with disabilities, to:

all its employees and volunteers, in the event the Company hires employees or volunteers;

all persons who participate in developing the Company's policies; and,

all other persons who provide goods, services or facilities on behalf of the Company.  For these individuals, the service contract provider will provide proof of training to the Company, if requested.

The training will be appropriate to the duties of the employees and other persons, and will be provided as soon as practicable. Ongoing training will be provided in the event of changes to legislation and/or changes to DFC Auto Group's policies.

DFC Auto Group will keep a record of the training it provides, including the dates on which training was provided and the number of individuals who attended the training.

Further details about training are set out in DFC Auto Group's Accessibility Standards for Customer Service Policy.

Accessibility Report

DFC Auto Group will file an accessibility report with a director pursuant to section 14 of AODA.

 

INFORMATION AND COMMUNICATIONS STANDARDS

Feedback Process

DFC Auto Group will ensure 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 communication supports, upon request.

DFC Auto Group will notify the public about its feedback process, including information about the availability of accessible formats and communication supports with respect to the feedback process, by making the information available in an accessible format upon request.

Accessible Formats and Communication Supports

Upon request, DFC Auto Group 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.

DFC Auto Group will consult with the person making the request in determining the suitability of an accessible format or communication support.

DFC Auto Group will notify the public about the availability of accessible formats and communication supports, by posting this information on DFC Auto Group's website, if applicable, and making such formats available upon request.

Emergency Procedure, Plans or Public Safety Information

If DFC Auto Group prepares emergency procedures, plans or public safety information and makes the information available to the public, DFC Auto Group will provide the information in an accessible format or with appropriate communication supports, as soon as practicable, upon request.

EMPLOYMENT STANDARDS

Scope

The Employment Standards apply in respect of employees.  They do not apply in respect of volunteers and other non-paid individuals.

Recruitment

DFC Auto Group will notify its employees and the public about the availability of accommodation for applicants with disabilities in its recruitment process.  This will be done when any posting and/or communication is made with respect to recruitment.

Recruitment, Assessment or Selection Process

DFC Auto Group 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, DFC Auto Group 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

When making offers of employment, DFC Auto Group will notify the successful applicant about DFC Auto Group's Accommodation Policy for Employees with Disabilities.

Informing Employees of Supports

DFC Auto Group will inform its employees about its Accommodation Policy for Employees with Disabilities, as well as any other policies or practices 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 or providing services to DFC Auto Group.  DFC Auto Group will provide its employees with updated information 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.  DFC Auto Group will coordinate with the employee with a disability in order to accommodate the employee with a disability.

Accessible Formats and Communication Supports for Employees

Upon the request of an employee with a disability, DFC Auto Group 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 their job, and information that is generally available to other employees.  DFC Auto Group will coordinate with the employee with a disability in order to accommodate the employee with a disability.

In determining the suitability of an accessible format or communication support, DFC Auto Group will consult with the employee making the request.

Workplace Emergency Response Information

DFC Auto Group will 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 DFC Auto Group is aware of the need for accommodation due to the employee’s disability.  DFC Auto Group will provide this information as soon as practicable after becoming aware of the need for accommodation.

Where the employee requires assistance, DFC Auto Group will, with the consent of the employee, provide the workplace emergency response information to the person designated by DFC Auto Group to provide assistance to the employee.

DFC Auto Group 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.

DFC Auto Group will review the individualized workplace emergency response information when the employee moves to a different location in the Company, when the employee’s overall accommodations, needs, or plans are reviewed and when DFC Auto Group reviews its general emergency response policies.  DFC Auto Group will consult with the employee with a disability to accommodate the employee with a disability.

Individual Accommodation Plans

Employees with disabilities will work with their Department Manager and/or General Manager to develop an individual accommodation plan.  Individual accommodation plans will be assessed on an individual basis based on the employee's needs and the nature of their role.  DFC Auto Group reserves the right to arrange for an evaluation by an outside medical or other expert, at DFC Auto Group's expense, to assist DFC Auto Group in determining if accommodation can be achieved, and if so, how.  The employee with a disability may ask for participation from their manager or health and safety committee in developing an individual accommodation plan.  DFC Auto Group will ensure that the employee with a disability's privacy is maintained and that the accommodation plan is only shared with individuals who need to know about the plan in order to properly execute it.  The individual accommodation plan will be reviewed as often as is necessary.  The individual accommodation plan will be provided in a format that takes into account the employee's accessibility needs due to disability.

Return to Work Process

If an employee has been absent from work due to a disability and requires disability-related accommodations in order to return to work, the employee with a disability will work with their Department Manager and/or General Manager to facilitate their return to work and create a plan in writing.  DFC Auto Group will take reasonable steps to ensure that the return to work process is discussed prior to the employee with a disability actually returning to work, to allow for processes to be put in place for a smooth transition.  DFC Auto Group will ensure that individual accommodation plans are used as part of the process to return to work.

Performance Management, Career Development and Advancement & Redeployment

DFC Auto Group will 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.

For the purposes of this section, "performance management" refers to activities related to assessing and improving employee performance, productivity, and effectiveness, with the goal of facilitating employee success.

For the purposes of this section, "career development and advancement" includes providing additional responsibilities within an employee's current position and the movement of an employee from one job to another in an organization that may be higher in pay, provide greater responsibility or be at a higher level in the organization or any combination of them and, for both additional responsibilities and employee movement, is usually based on merit or seniority, or a combination of them.

For the purposes of this section, "redeployment" means 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.

ACCESSIBLE PARKING

The following accessible parking sections apply with respect to constructing new or redeveloping off-street parking facilities that DFC Auto Group intends to maintain.

Types of Accessible Parking Spaces

If DFC Auto Group constructs new or redevelops off-street common element or other parking facilities that it intends to maintain, it will do so in accordance with AODA.

Access Aisles

Access aisles must be provided for all parking spaces for the use of persons with disabilities in off-street parking facilities and will be provided in accordance with AODA.

Minimum Number and Type of Accessible Parking Spaces

DFC Auto Group will comply with AODA.

Signage

DFC Auto Group will ensure that parking spaces for the use of persons with disabilities are distinctly indicated by erecting an accessible permit parking sign in accordance with section 11 of Regulation 581 of the Revised Regulations of Ontario, 1990 (Accessible Parking for Persons with Disabilities) made under the Highway Traffic Act.

Exceptions

If DFC Auto Group can demonstrate that it is not practicable to comply with the required minimum number of parking spaces to be used by persons with disabilities, or that site constraints prevent it from meeting the required ration, then they are exempted from the above requirement.  This may occur if the minimum width for parking spaces for persons with disabilities or access aisles cannot be met because of existing pay and display parking meters, surrounding curb edges, walkways, landscaping or the need to maintain a minimum drive aisle width.  If DFC Auto Group claims this exemption, it will provide as close to as many parking spaces for the use of persons with disabilities that meet the requirements cited above and under AODA.

SERVICE COUNTERS

DFC Auto Group will provide at least one service counter that accommodates a mobility aid for each type of service provided.  If more than one service counter exists, the service counter that can accommodate a mobility aid must be clearly identified with signage.

The service counter that accommodates mobility aids will be at a height that is usable by a person seated in a mobility aid.  There must be sufficient knee clearance for a person seated in a mobility aid, where a forward approach to the counter is required.  The floor space will be sufficiently clear so as to accommodate a mobility aid.

Note that this section applies only when re-developing/replacing or constructing new service counters, both inside and out of doors.

When constructing new fixed queuing guides, there will be sufficient width to allow for the passage of mobility aids and mobility assistive devices, with sufficiently clear floor areas to permit mobility aids to turn where queuing lines change direction.  The fixed queuing guides will be cane detectable.

WAITING AREAS

When constructing a new waiting area, or redeveloping an existing waiting area, where the seating is fixed to the floor, a minimum of three percent of the new seating must be accessible.  In any event, there will always be at least one accessible seating space.

CUSTOMER SERVICE STANDARDS

DFC Auto Group strives at all times to provide its goods and services in a way that respects the dignity and independence of people with disabilities. We are also committed to giving people with disabilities the same opportunity to access our goods and services; allowing them to benefit from the same services, in the same place and in a similar way, as customers.   This policy applies to all Team Members.

DFC Auto Group is committed to excellence in serving all customers including people with disabilities and we will carry out our functions and responsibilities in the following areas:

Accessible formats

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

Assistive devices

This means 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 clients bring with them such as a wheelchair, walker or a personal oxygen tank.  These devices might assist in hearing, seeing, communicating, moving, breathing, remembering, and/or reading.

Communication Supports

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

Disability

This means:

  1. 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;
  2. a condition of mental impairment or a developmental disability;
  3. a learning disability, or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language;
  4. a mental disorder; or
  5. an injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997.

Service animals

A service animal is a "service animal" for a person with a disability if:

  1. the animal can be readily identified as one that is being used by the person for reasons relating to the person's disability, as a result of visual indicators such as the vest or harness worn by the animal; or
  2. the person provides documentation from one of the following regulated health professionals confirming that the person requires the animal for reasons related to the disability:
    1. A member of the College of Audiologists and Speech-Language Pathologists of Ontario.
    2. A member of the College of Chiropractors of Ontario.
    3. A member of the College of Nurses of Ontario.
    4. A member of the College of Occupational Therapists of Ontario.
    5. A member of the College of Optometrists of Ontario.
    6. A member of the College of Physicians and Surgeons of Ontario.
    7. A member of the College of Physiotherapists of Ontario.
    8. A member of the College of Psychologists of Ontario.
    9. A member of the College of Registered Psychotherapists and Registered Mental Health Therapists of Ontario.

We welcome people with disabilities and their service animals. Service animals are allowed on the parts of our premises that are open to the public.  When we cannot easily identify that an animal is a service animal, our staff may ask a person to provide documentation (template, letter or form) from a regulated health professional that confirms the person needs the service animal for reasons relating to their disability.
A service animal can be easily identified through visual indicators, such as when it wears a harness or a vest, or when it helps the person perform certain tasks.

If service animals are prohibited by another law, we will do the following to ensure people with disabilities can access our goods, services or facilities:

Explain why the animal is excluded; and

Discuss with the customer another way of providing goods, services or facilities

Support persons

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 or medical needs, or with access to goods, services or facilities.

We are committed to welcoming people with disabilities, who are accompanied by a support person. Any person with a disability, who is accompanied by a support person, will be allowed to enter DFC Auto Group’s premises with his or her support person. At no time will a person with a disability, who is accompanied by a support person, be prevented from having access to his or her support person, while on our premises.

General Principles

In accordance with the Customer Service Standards, as set out in Ontario Regulation 191/11 under the AODA, this policy addresses the following:

  1. The Provision of Goods, Services or Facilities to Persons with Disabilities
  2. The Use of Assistive Devices
  3. The Use of Guide Dogs and Service Animals
  4. The Use of Support Persons
  5. Notice of Service Disruptions
  6. Feedback
  7. Training
  8. Notice of Availability and Format of Required Documents

The Provision of Goods, Services or Facilities to Persons with Disabilities

DFC Auto Group 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 clients receive the same value and quality;
  • ensuring that the provision of goods, services or facilities to persons with disabilities are integrated with the provision of goods, services or facilities to others, unless an alternative measure is necessary, to enable a person with a disability to obtain, use or benefit from the goods, services or facilities;
  • allowing clients 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 to the clients or others;
  • using alternative methods, when possible, to ensure that clients with disabilities have access to the same services, in the same place and in a similar manner, as clients without disabilities;
  • taking into account individual needs when providing goods and services; and
  • communicating in a manner that takes into account the client's disability.

Assistive Devices

Persons with disabilities may use their own assistive devices, as required, when accessing goods, services or facilities provided by DFC Auto Group.  In cases where the assistive devices present a safety concern or where accessibility might be an issue, other reasonable measures will be used to ensure access to the goods and services.

Guide Dogs and Service Animals

If a person with a disability is accompanied by a guide dog or other service animal at DFC Auto Group's premises, that person will be permitted to enter the premises with the animal, and keep the animal with them, unless the animal is otherwise excluded by law from the premises.

If a guide dog or service animal is excluded by law from the premises, DFC Auto Group will offer alternative methods to enable the person with a disability to access goods, services or facilities, when possible (e.g., securing the animal in a safe location and offering the guidance of an employee).

If it is not readily apparent that the animal is being used by a person for reasons relating to their disability, DFC Auto Group may request verification.  Verification may include:

  • a letter from a regulated health professional (for instance, a physician or a nurse) confirming that the person requires the animal for reasons related to the disability; or
  • a certificate of training from a recognized guide dog or service animal training school.

The person who is accompanied by a guide dog or other service animal is responsible for maintaining care and control of the animal at all times.

If a health and safety concern presents itself (e.g., in the form of a severe allergy to the animal), DFC Auto Group will take all reasonable steps to meet the needs of all individuals concerned.

Support Persons

If a person with a disability is accompanied by a support person, DFC Auto Group will ensure that both persons are allowed to enter the premises together and that the person with a disability is not prevented from having access to the support person while on the premises.

There may be times where seating and availability prevent the person with a disability and the support person from sitting beside each other.  In those situations, DFC Auto Group will make every reasonable attempt to resolve the issue with a view to ensuring the provision of goods, services or facilities.

In the event an amount is payable for a person's admission to the premises or in connection with a person's presence on the premises, DFC Auto Group shall ensure that notice is given in advance about the amount, if any, payable in respect of the support person.  However, if DFC Auto Group determines that a person with a disability requires the support person's presence, any admission fee will be waived for the support person.

DFC Auto Group may require a person with a disability to be accompanied by a support person when on the Company's premises, but only if, after consulting with the person with a disability and considering the available evidence, the DFC Auto Group determines that:

  • the support person is necessary to protect the health and safety of the person with a disability or the health and safety of others on the premises; and
  • there is no other reasonable way to protect the health or safety of the person with a disability and the health and safety of others on the premises.

Notice of Disruptions in Service

Service disruptions may occur due to reasons that may or may not be within the control or knowledge of DFC Auto Group.  In the event of any temporary disruptions, either to DFC Auto Group's services or to access to its facilities, where persons with disabilities rely on the services or access to them, reasonable efforts will be made to provide advance notice of such disruptions.  In some cases (e.g., unplanned temporary disruptions), advance notice may not be possible.  A notice will be posted on the HR Bulletin Board.

When DFC Auto Group gives notice of a temporary disruption, the following information will be included in the notice, unless it is not readily available or known:

  • goods and/or services that are disrupted or unavailable;
  • reason(s) for the disruption;
  • anticipated duration of the disruption; and
  • description of any alternative facilities, services or options.

When temporary disruptions occur, DFC Auto Group will give notice by:

  • posting notice on DFC Auto Group website, if applicable;
  • contacting affected individuals who have appointments with DFC Auto Group; and
  • by any other method that may be reasonable under the circumstances.

Feedback Process

DFC Auto Group will provide the opportunity to provide feedback relating to:

  • the manner in which DFC Auto Group provides goods, services or facilities to persons with disabilities; and
  • whether DFC Auto Group's feedback process referred to in paragraph (a) is accessible to persons with disabilities by providing, or arranging for the provision of, accessible formats and communication supports, on request.

Information concerning DFC Auto Group's feedback process, including information about the availability of accessible formats and communications supports with respect to the feedback process, will be available on DFC Auto Group's website, if applicable, or by request. DFC Auto Group will arrange for the policy to be provided in an alternative accessible format or with communication supports, on request.

Feedback can be submitted directly to a VP and/or General Manager by email or by phone. Customers can expect to hear back in ten (10) days. Complaints will be addressed according to our organization’s regular complaint management procedures.

Upon receiving feedback, DFC Auto Group will then investigate, if appropriate, and take all reasonable steps to correct the situation, if necessary, with a view to ensuring access to the goods, services or facilities.

DFC Auto Group will provide or arrange for the provision of accessible formats and communications supports, upon request, if required to access DFC Auto Group's feedback process.  This will be done 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, if any.  DFC Auto Group shall consult with the person making the request in determining the suitability of an accessible format or communication support.

Training

Training will be provided to:

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

Training will cover the following:

  • A review of the purpose of the AODA;
  • A review of the requirements set out in Ontario Regulation 191/11, including a review of the Customer Service Standards;
  • 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 or other service animal; or
    • require the use of a support person;
  • Instructions on how to use equipment or devices that are available at the Company's premises that may help people with disabilities, if applicable;
  • Instructions on what to do if a person with a disability is having difficulty accessing the Company's services; and
  • The Company's policies, procedures and practices pertaining to providing accessible client service to persons with disabilities.

Training will be provided as soon as practicable.  Ongoing training will be provided in the event of changes to legislation and/or changes to the Company's policies.

The Company will keep a record of the training it provides, including the dates on which training was provided and the number of individuals who attended the training.

Notice of Availability and Format of Documents

If the Company gives a copy of this policy to a person with a disability, or if the Company is otherwise required by this policy to give them a copy of any other document, the Company will, upon request, provide or arrange for the provision of the document, or the information contained in the document, to the person in an accessible format or with communication support. Same will be provided in a timely manner and at a cost that is no more than the regular cost charged to other persons.  The Company will consult with the person making the request in determining the suitability of an accessible format or communication support.

SERVICE TIPS

The following are service tips to assist Workers with their interactions with persons with disabilities when providing customer service:

  • speak directly to your guest, positioning yourself so that you can make eye contact.  Respect your guest's personal space.  Do not lean over them or their assistive device;
  • let your guests know about accessible features in the immediate area (such as automatic entry doors and barrier-free washrooms);
  • don't touch assistive devices without permission.  If you have permission, remember to wait for instructions, following which, describe what you're going to do before you do it, and never leave the guest in an awkward, dangerous or undignified position (such as facing a wall or in the path of opening doors);
  • do not cover your face if you are talking to a person with hearing loss – they may be reading lips;
  • offer to adjust the background noise, to the extent possible, when interacting with a person with hearing loss;
  • when engaging with service animals, remember that they are not a pet.  Avoid touching or addressing service animals;
  • it may not be readily apparent that the animal is a service animal or that a person is a support person.   If you are unsure, ask the guest.

Modifications to this or other policies

Any policy of DFC Auto Group, that does not respect and promote the principles of dignity, independence, integration and equal opportunity for people with disabilities in accessing our good and services, will be modified or removed.

Questions about this policy

This policy exists to achieve service excellence to customers with disabilities. This policy will be publicly available at the Company and will be provided in an accessible format, upon request. If anyone has questions about this policy kindly contact Dealer General Manager at DFC Auto Group.