Accessibility Policy

AODA INTEGRATED ACCESSIBILITY STANDARDS POLICY

1. Statement of Commitment  

CTG Brands Inc. ("CTG") is committed to excellence in serving all people, including those with Disabilities, in accordance with its legal obligations pursuant to the Accessibility for Ontarians with Disabilities Act, 2005, S.O. 2005, c. 11 (the “AODA”) and Ontario Regulation 429/07 (the “Customer Service Standard”).  The following policy is guided by the fundamental principles underlying the Customer Service Standard. We are committed to ensuring that the Policy is rigorously observed by all employees who interact with clients or third parties in the delivery of goods and services. 

2. Purpose of this Policy  

CTG is committed to providing accessible customer service to persons who have Disabilities. CTG will make reasonable efforts to ensure that this Policy and related practices and procedures are consistent with the following principles as prescribed in the Customer Service Standard:

1. We will provide goods or services in a manner that respects the dignity and independence of persons with Disabilities;
2. We will provide integrated services to persons with Disabilities wherever possible and will provide alternate measures where necessary and in accordance with our legal obligations, whether temporarily or on a permanent basis, to enable a person with a disability to obtain, use or benefit from the goods or services; and
3. We will provide equal opportunity to persons with Disabilities to obtain, use and benefit from the goods or services.

3.Application and Scope 

This Policy applies without exception to all employees, agents and/or contractors of CTG providing goods and services on behalf of CTG and who may interact with CTG’s clients, the public or third parties. 

4.Definitions

The following definitions, some of which are provided in the AODA and the Customer Service Standard Regulation, apply for the purposes of this Policy:

“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;

“Barrier” means anything that prevents a person with a disability from fully participating in all aspects of society because of his or her disability, including a physical barrier, an architectural barrier, an information or communications barrier, an attitudinal barrier, a technological barrier, a policy or a practice;

“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,

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; (“handicap”)

“Feedback” means any comments, compliments, suggestions or complaints provided to CTG by clients or other third parties;

“Mobility Aid” means a device used to facilitate the transport, in a seated posture, of a person with a disability; and

“Mobility Assistive Device” means a cane, walker or similar aid.

5.Assistive Devices 

Persons with Disabilities shall be permitted to obtain, use or benefit from goods or services through the use of their own assistive devices. CTG’s employees in relevant roles will be trained to ensure that they are familiar with various assistive devices that may be used by clients with Disabilities while accessing services. 

In the event that a person with a Disability is hindered from accessing any goods or services offered, CTG will use its best efforts to accommodate the person by offering the use of another assistive device that is available or attempt to deliver the same service in another way

6.Communication 

When communicating with a person with a Disability, CTG will consider the particular individual’s needs and circumstances. CTG's employees who communicate with customers will be trained on how to interact and communicate with people with various types of Disabilities in order to ensure that CTG provides responsive and effective communication.  All communication shall be provided in a manner that respects the dignity and independence of persons with Disabilities. 

7. Service Animals 

CTG is committed to welcoming persons with Disabilities who are accompanied by a service animal on the parts of our premises that are open to clients, such as the showroom. If a service animal is excluded by law, CTG will suggest appropriate alternatives and provide assistance in order to ensure that the person is able to access, obtain, use or benefit from CTG’s services where possible. 

CTG will train employees with relevant job duties on how to interact with clients who are accompanied by service animals. 

8.Support Persons

A person with a Disability who is accompanied by a support person will be allowed to have that person accompany them on our premises. CTG will notify persons coming to the site of this through a notice posted on our premises at reception.

9.Notice of Temporary Disruption

In the event of a planned or unexpected disruption to services or facilities for people with Disabilities, the Executive Vice President, Tom Cheung, or his designate, will notify affected persons promptly and will post the information at reception. 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.

10.Training for Staff 

Training for staff members that, by virtue of their role, interact with clients and third parties will include the following:

• An overview of the purposes of the Accessibility for Ontarians with Disabilities Act, 2005 and the requirements of the Customer Service Standard;
• Training on how to interact and communicate with people with various types of Disabilities;
• Training on how to interact with people with Disabilities who use an assistive device or who require the assistance of a service animal or a support person;
• Training on how to use equipment or assistive devices available at the office or otherwise provided by CTG that may help with the provision of goods or services to a person with a Disability;
• Training on what to do if a person with a Disability is having difficulty in accessing CTG’s goods and services; and
• Training on CTG's current policies, practices and procedures relating to the Customer Service Standard.

CTG will keep records of the training provided, including the dates on which training occurred and the names of participants.

11. Feedback Process

Any person who wishes to provide feedback on the manner in which CTG provides services to people with Disabilities may direct their inquiry to customerservice@ctgbrands.com. All feedback will be directed to the appropriate person. Inquiries will be responded to within five (5) business days.

Complaints will be addressed according CTG's regular complaint management procedures.  

12.Notice of Availability of Documents

This Policy and any corresponding practices and procedures will be made available to any person upon request. CTG shall post notice of the availability of these documents on its website at www.ctgbrands.com

13. Format of Documents

Upon request, CTG shall provide this Policy and other any written documents created pursuant to the Customer Service Standard in a format that takes into account the Disability of the person submitting the request.

CTG recognizes that the AODA does not replace or supersede the Human Rights Code, R.S.O. 1990, c. H.19 (the “Code”).