Accessibility

Accessible Client Service Policy

Whitehorse Liquidity Partners Inc., doing business as Dawson (the “Firm”) is committed to excellence in serving all clients including people with disabilities. Our accessible client service policies are consistent with the principles of independence, dignity, integration and equality of opportunity for people with disabilities.

We will do so by removing and preventing barriers to accessibility and by meeting our accessibility requirements under Ontario’s accessibility laws and our obligations under the Human Rights Code.

Assistive Devices

People with disabilities may use their personal assistive devices when accessing our services or facilities.

In cases where the assistive device presents a significant and unavoidable health or safety concern or may not be permitted for other reasons, other measures will be used to ensure the person with a disability can access our goods, services or facilities.

We will ensure that our staff are trained and familiar with equipment or assistive devices we have on site or that we provide that may be used by clients with disabilities while accessing our goods, services or facilities.

Communication

We will communicate with people with disabilities in ways that take into account their disability. We will work with the person with a disability to determine what method of communication works for them.

Service Animals

We welcome people with disabilities and their service animals. Service animals are allowed on the part of our premises which is open to the public, specifically, our client service areas. When we cannot easily identify whether an animal is a service animal, our staff may ask the person to provide documentation from a regulated health professional that confirms the person needs the service animal for reasons relating to their disability.

If service animals are prohibited by another law, we will ensure the client can access our goods, services or facilities by explaining why the animal is excluded and discussing with the client alternative method of providing the goods, services or facilities.

A person with a disability who is accompanied by a support person will be allowed to have that person accompany them on our premises. In certain cases, we may require a person with a disability to be accompanied by a support person for the health or safety reasons of the person with a disability or others on the premises.

Notice of Temporary Disruption

In the event of a planned or unexpected disruption to services or facilities for clients with disabilities, we will notify clients promptly, which may include by posting a notice. This clearly posted 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.

Training

We will provide accessible client service training to all employees and volunteers, any person involved in developing our policies and any person who provides goods, services or facilities to clients on our behalf.

The training will encompass:

the purpose of the Accessibility for Ontarians with Disabilities Act, 2005 and the requirements of the customer service standard;
the Firm’s policies related to the customer service standard;
how to interact and communicate with people with various types of disabilities;
how to interact with people with disabilities who use an assistive device or require the assistance of a service animal or support person;
how to use the equipment or devices available on-site or otherwise that may help with providing goods, services or facilities to people with disabilities; and
what to do if a person with a disability is having difficulty accessing the Firm’s goods, services or facilities.

Staff will be trained on accessible client service as part of their training when they are first hired and if changes are made to our Accessible Client Service Policy.

Feedback Process

We welcome feedback.

Clients who wish to provide feedback on the way we provide goods, services or facilities to people with disabilities can provide feedback in the following way(s):

By telephone by calling: Jenn McGoey, Chief Compliance Officer at (647) 925-1284
By email to: jmcgoey@dawsonpartners.com
By mail to:
79 Wellington Street West
TD South Tower
Suite 2100, P.O. Box 92
Toronto, ON
M5K 1G8
Canada

We will make sure our feedback process is accessible to people with disabilities by providing or arranging for accessible formats and communication supports, on request.

All feedback received will be reviewed within a reasonable time period and we will take all appropriate steps to address any issues raised. All complaints will be processed in accordance with the Firm’s complaints process.

Documents

We will provide this document and any other document referenced in this policy, such as a notice of temporary disruption, in an accessible format or with communication support, on request. We will consult with the person making the request to determine the suitability of the format or communication support. We will provide the accessible format in a timely manner and at no additional cost.

Any policies of the Firm that do not respect and promote the principles of dignity, independence, integration and equal opportunity for people with disabilities will be modified or removed.

Accessibility Policy and Multi-Year Accessibility Plan

Commitment to Accessibility

Dawson (the “Firm”) is committed to ensuring equal access and participation for people with disabilities. We are committed to treating people with disabilities in a way that allows them to maintain their dignity and independence.

We believe in integration, and we are committed to meeting the needs of people with disabilities in a timely manner. We will do so by removing and preventing barriers to accessibility and by meeting our accessibility requirements under Ontario’s accessibility laws.

Application and Scope

This Accessibility Policy (“Policy”) and Multi-Year Accessibility Plan (“Plan”) are made pursuant to the requirements of the Accessibility for Ontarians with Disabilities Act, 2005 (“AODA”) and the Integrated Accessibility Standards Regulation (“IAS Regulation”) of AODA, and address how we will achieve accessibility. This Policy and Plan will be reviewed and updated as necessary, but at least every five years, and posted on our website.

For purpose of this Policy and Plan, “disability” is defined as follows:

(i) 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;

(ii) a condition of mental impairment or a developmental disability;

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

(iv) a mental disorder; or

(v) 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 Firm will incorporate accessibility features if it designs, procures or acquires self-service kiosks.

Training

We provide training to all its employees, volunteers, persons who participate in developing our policies and all other persons who provide goods, services or facilities on behalf of us. The training will:

outline the requirements of the IAS Regulation and the Human Rights Code as it relates to persons with disabilities;
- be appropriate to the duties of the employee, volunteer or other person; and
- be provided as soon as practicable, on an ongoing basis, and as necessary to comply with all statutory requirements.

The Firm will keep a record of the training provided, including the date(s) on which it is provided and the individuals who attended.

Information and Communications Standards

Accessible Formats and Communication Supports

Upon request, and in accordance with the compliance schedule set out in the IAS Regulation, we will provide or arrange for the provision of accessible formats and communication supports for persons with disabilities in a timely manner and at a cost that is not greater than the cost charged to other persons, if any. We will consult with the person making the request to determine the suitability of an accessible format or communication support.

Feedback

In accordance with the requirements of the IAS Regulation, we will ensure that our feedback processes are accessible to persons with disabilities by providing or arranging for the provision of accessible formats and communication supports, upon request.

Further information about our feedback process is available at the end of this Policy.

Accessible Websites and Web Content

In accordance with the compliance requirements set out in the IAS Regulation, and subject to applicable exceptions, we will ensure that our website and the applicable web content will conform with the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG 2.0) Level AA (other than criteria 1.2.4 (live captions) and 1.2.5 (pre-recorded audio descriptions)).

Emergency Information

Where we prepare emergency procedures, plans or public safety information and make such information available to the public, we will provide the information in an accessible format or with appropriate communication supports, as soon as practicable, upon request.

Employment Standards

We are committed to ensuring that our employment practices are in compliance with AODA, IAS Regulation and the Ontario Human Rights Code.

Recruitment

Accommodations for applicants (including existing employees) with disabilities are available in our recruitment processes.

We will notify applicants, when they are individually selected to participate in an assessment or selection process, that accommodations, including accessible formats and communication supports, are available upon request in relation to the materials or processes to be used. If a selected applicant requests an accommodation, we 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 a disability.

We will notify successful applicants of our policies for accommodating employees with disabilities when making offers of employment.

We will also notify employees of our policies that support 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 a disability.

Accessible Formats & Communication Supports for Employees

Where an employee with a disability requests it, we will consult with the employee to provide or arrange for the provision of accessible formats and communication supports for information that is (a) needed in order to perform the employee’s job and (b) generally available to employees in the workplace.

Documented Individual Accommodation Plans & Return-to-Work Process

In accordance with the requirements set out in the IAS Regulation, we will continue to develop a process for the development of individual accommodation plans for employees with disabilities. Our processes will include the following elements:

the manner in which an employee requesting accommodation can participate in the development of the individual accommodation plan;
the means by which the employee is assessed on an individual basis;
the manner in which the Firm may request an evaluation by an outside medical or other expert to assist with determining if accommodation can be achieved and, if so, how to achieve accommodation;
the manner in which the employee can request the participation of a representative from the workplace in the accommodation process;
the steps taken to protect the privacy of the employee’s personal information;
the frequency with which the individual accommodation plan will be reviewed and updated and the manner in which it will be done;
if an individual accommodation plan is denied, the manner in which the reasons for the denial will be provided to the employee; and
the means of providing the accommodation plan in a format that takes into account the employee’s accessibility needs.

Individual accommodation plans will, if requested, include any information regarding accessible formats and communication supports provided, individualized workplace emergency response information, and identify any other accommodation that is to be provided.

We have documented return-to-work processes for employees who have been absent from work due to a disability and require disability-related accommodation in order to return to work. We will ensure that those processes clearly outline the steps that we will take to facilitate the return-to-work process amongst other requirements that facilitate that process. Our return-to-work processes will include preparation of individualized accommodation plans for any employee requiring a disability-related accommodation.

Performance Management, Career Development and Advancement, Redeployment

We will take into account the accessibility needs and/or individual accommodation plans of employees when using performance management processes, providing career development and advancement, and when using redeployment.

Workplace Emergency Response Information

We 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. We will provide this information as soon as practicable after becoming aware of the need for accommodation.

If an employee who receives individualized workplace emergency response information requires assistance and the employee’s consent is obtained, we will provide the workplace emergency response information to the person designated by the employer to provide assistance to the employee.

We will review the individualized workplace emergency response information in the following circumstances: when the employee moves to a different location in the organization, when overall accommodation needs or plans are reviewed, and when we review our general emergency response policies.

Accessibility Standards for our Facilities

We are committed to designing our facilities to be free from barriers and accessible to all persons we serve. We will comply with the Design of Public Spaces Standards with respect to public spaces that are newly constructed or redeveloped in accordance with the requirements of the IAS Regulation.

References

Accessible Client Service Policy
Accessibility for Ontarians with Disabilities Act, 2005
Regulation 191/11 made under the Accessibility for Ontarians with Disabilities Act, 2005 (Integrated Accessibility Standards)

Copies

Upon request, all of our policies can be made available in an accessible format and we can provide or arrange to provide communication supports as necessary.

Feedback and Questions?

If you have any questions about this Policy or our accessibility initiatives, please let us know. Feedback on this Policy and the Firm’s accessibility measures is welcome. Feedback can be provided through various means and in various forms. If you have questions, concerns or comments, please contact:

Name: Jenn McGoey, Chief Compliance Officer

Tel: (647) 925-1284

Email: jmcgoey@dawsonpartners.com