ACCESSIBILITY

ACCESSIBLE CUSTOMER SERVICE POLICY

1. Purpose:

This Accessible Customer Service Policy (the “Policy”) has been developed to ensure that RFA (“RFA”) provides equal customer service for people with disabilities.

RFA is committed to identifying, removing and preventing barriers for people with disabilities when accessing RFA’s goods, services and facilities (the “RFA Services”). If a barrier to accessing RFA Services cannot be removed, RFA seeks to provide alternate means to access said RFA Services.

This Policy is intended to comply with applicable accessibility legislation governing customer service across Canada.

2. Communication:

RFA will make reasonable efforts to ensure that, when communicating with a person who self-identifies as being disabled, the communication is done in a manner that takes into account the disability and finds alternative formats to communicate appropriately.

3. Assistive Devices:

A person who uses assistive devices when accessing RFA Services will be reasonably accommodated. The provision and safe use of an assistive device is the sole responsibility of the person using the assistive device.

In cases where an assistive device presents a significant or unavoidable health or safety concern or may not be permitted for other reasons, RFA will strive to use other reasonable measures to ensure that the person disabled by a barrier can access RFA Services.

4. Support Person:

A support person may accompany a person who is disabled when accessing RFA Services.

If a support person is required to pay an amount to be admitted to, or be present at our premises, RFA will ensure that advance notice is given of the amount payable, in respect of the support person.

5. Service Animals:

A person who requires a service animal may be accompanied by a service animal when accessing RFA Services. In cases where the presence of a service animal presents a significant or unavoidable health or safety concern or may not be permitted for other reasons or may be excluded by law, RFA will strive to use other measures to ensure that the person can access RFA Services.

The person who is accompanied by a service animal is solely responsible for the care, control, safety and clean-up of the service animal at all times. If it is not readily apparent, RFA may request verification that the animal is a service animal and is being used in connection with the person’s disability.

6. Notice of Temporary Disruption:

RFA will provide prompt notification to the public if an accessibility feature related to RFA Services is temporarily unavailable. A notice will be posted that will include information about the reasons for the disruption, its anticipated length of time, and a description of alternative facilities or services, if available. The notice will be posted on the RFA website or by other means that may be appropriate in the circumstances.

7. Training:

RFA will train any staff responsible for providing RFA Services to the public and all staff who are responsible for this Policy, as soon as reasonably practical.

Training will include instruction about (i) how to interact and communicate with persons disabled by barriers, (ii) how to interact with persons disabled by barriers who use an assistive device or require the assistance of a support person or service animal, (iii) how to use any equipment or assistive devices that may be available to assist persons disabled by barriers, and (iv) what to do if a person disabled by a particular barrier is having difficulty accessing a good or service; and (b) a review of applicable human rights and accessibility legislation and this Policy.

Please be advised that a free online platform has been launched to assist organizations to meet the training requirement. For more information, visit: The Accessibility for Manitobans Act Learning Portal (amalearningmb.ca).

8. Feedback:

RFA welcomes feedback on its accessible customer service and this Policy. Anyone who wishes to provide feedback may do so by contacting:

RFA Asset Management
Accessibility Coordinator
600 – 220 Portage Avenue
Winnipeg, MB
R3C 0A5
Phone 204-947-1250
Email: [email protected]

The Accessibility Coordinator will review the feedback and work towards resolution, as appropriate. A response acknowledging receipt of the feedback/concern will be provided within 10 business days.

Responses to feedback about accessibility will be provided in a manner that is appropriate in the circumstances and is suitable for persons who are disabled by barriers. In addition, the company will document the actions resulting from the feedback, and make this documentation available on request.

ACCESSIBLE EMPLOYMENT STANDARD POLICY

Introduction

RFA is committed to complying with applicable accessibility legislation and human rights laws across Canada. Our policies, practices and measures reflect principles of dignity, independence, integration and equal opportunity for people with disabilities. We aim to remove barriers in our workplace. If a barrier cannot be removed, we seek to provide reasonable accommodations to affected employees.
The following policy statements, organizational practices and measures are intended to meet the requirements of applicable accessibility legislation governing employment across Canada. This policy is publicly available and will be provided in an accessible format upon request.
This policy applies to all employees of RFA and is to be read in conjunction with RFA’s Reasonable Accommodation and Return to Work policies, where applicable.

Pre-Employment Accessibility Requirements

RFA informs potential applicants for employment that, upon request, reasonable accommodations are available to applicants with disabilities during the assessment or selection process, including with respect to the materials or activities used in said processes. When an applicant has made a request for an accommodation during the selection and/or assessment process, RFA shall consult with the applicant to determine a reasonable accommodation and then put the reasonable accommodation(s) in place during the assessment or selection process. Further, when offering employment, and during the onboarding process, RFA informs selected applicants of our measures, policies and practices for accommodating employees with disabilities.

Employment Accessibility Requirements

1: Informing Employees of Accommodation Measures, Policies and Practices

FA provides employees with information about our accessibility policies, measures, and practices for employees with disabilities, and any changes made to those measures, policies and practices. Our policies are made available to employees on the RFA Employee Portal.

2: Accessible Communication

We aim to meet the communication needs of our employees by providing workplace information and communications in ways that are easy to access for everyone. Upon the request of an employee with a disability, we:

• consult with the employee to identify the accessible formats or communication supports they require when being provided with information; and
• ensure that we continually use the identified accessible formats or communication supports when providing information to the employee.

This includes, but is not limited to, providing copies of this policy and the documents referred to herein to employees in accessible formats upon request.

3: Individualized Accommodation Plans

RFA provides reasonable accommodations to employees with disabilities. On request by an employee with a disability, RFA will develop and implement a documented individualized accommodation plan (“IAP”) for that employee. Requests for an IAP shall be made to the employee’s direct manager or supervisor.

A: Creation of an IAP

Where an employee requests an IAP, RFA will work with the employee to assess their disability-related needs and possible accommodations on an individual basis. An employee may request assistance with developing their IAP from another person who is knowledgeable about workplace accommodations for employees with disabilities.

An employee’s IAP will include, where applicable, the following content:

• accessible formats and communication supports to be used when providing information to the employee;
• workplace emergency response information;
• details of how and when any other reasonable accommodations will be provided; and,
• when the plan will be reviewed and updated, including upon the employee’s request.

Our employees are required to participate and cooperate in the accommodation process by:

• filling out a Request for Workplace Accommodation form;
• providing further relevant information as requested by RFA, including but not limited to a Functional Capabilities form completed by the employee’s health practitioner;
• upon RFA ’s request, participating in an evaluation or assessment of the employee (which may include an evaluation by an independent regulated health professional or other practitioner in the area of workplace accommodations for employees with disabilities, at no cost to the employee), to assist RFA in determining what reasonable accommodation is required, if any;
• complying with their IAP and performing their work in accordance with the IAP;
• providing ongoing feedback to RFA regarding the requirements of the IAP; and
• advising RFA if any modifications to the IAP are needed, including if the accommodation is no longer required.

B: Implementation and Review of IAP

Managers will review an employee’s IAP, and update if required, when:

• the employee’s workspace is modified or relocated;
• the employee’s responsibilities have changed;
• other workplace changes have occurred that affect the IAP; and/or
• the employee has made a request to review and update the IAP.

RFA protects the privacy of its employee in respect of IAPs and other personal health information by following the practices outlined in section 9 below.

C: Denial of IAP

RFA may deny an employee’s request for an IAP in the following circumstances:

• the employee is able to carry out most of the job without an accommodation;
• the independent regulated health professional(s) does not support the employee’s self-assessed requirement for a workplace accommodation; or,
• the accommodation request would cause undue hardship to RFA (e.g., by creating safety risks to other employees or a significant measurable financial burden).

In the event a request for an IAP is denied, the employee will be provided with written reasons for the denial.

4: Performance Management

RFA ensures that our performance management processes take into account that an employee may be temporarily or permanently disabled by one or more barriers in the workplace, any IAP in place for an employee, and that any IAP may not fully address the barriers faced by the employee in the workplace.

For the purposes of this policy, “performance management process[es]” includes any process used by RFA to manage the work of an individual employee, as well as any process used to plan, monitor, and review an employee’s work objectives and overall contribution to RFA.

5: Career Development, Training, Internal Advancement and Reassignment

When providing career development training or opportunities for internal advancement, RFA ensures the process for recruiting and selecting candidates takes into account that an employee may be temporarily or permanently disabled by one or more barriers in the workplace, any IAP in place for an employee, and that any IAP may not fully address the barriers faced by the employee in the workplace. Our practices and measures aim to ensure that workplace accommodations do not negatively affect access to career development.

6: Return to Work Processes

RFA is committed to providing a safe and healthy working environment for all employees, including those who are, or have been, absent from work due to a disability or health condition and who require reasonable accommodation(s) to return to work. This policy is to be read in conjunction with our Reasonable Accommodation and Return to Work policies.

In the event that an employee has been absent from work due to a disability or other health condition, RFA shall:

• inquire with the returning employee as to any special needs they may have that may require reasonable accommodation upon their return to work; and,
• where a reasonable accommodation is required, develop and tailor a Return to Work Plan (“RTW Plan”) to the employee’s individual needs (including following and complying with any return to work process imposed by WCB).

In determining what, if any, reasonable accommodations may be required, RFA may require the employee to provide documentation from their health practitioner that sets out the employee’s functional abilities and any limitations thereto (e.g. a Functional Capabilities form, accessible at Appendix A.6 to our Reasonable Accommodation Policy), as well as any reasonable accommodations that may be required. We may also request that the employee participate in an evaluation by an independent regulated health professional or other practitioner in the area of workplace accommodations for employees with disabilities, to assist in determining if reasonable accommodation is required. Independent evaluations will be done at no cost to the employee.

A RTW Plan will typically involve modifying and graduating an employee’s duties and hours at work, according to their functional abilities. The goal of a RTW Plan is to increase the employee’s duties and/or work schedule based on their functional abilities, until they are safely able to return to performing their regular duties and/or schedule.

7: Workplace Emergency Response Information

RFA notifies all employees of steps to be taken during emergencies, to ensure the safety of all employees, including those who are temporarily or permanently disabled. If RFA is aware that an employee with a disability may face special risks or challenges during a workplace emergency, we offer the employee individualized workplace emergency response information (“WER Information”) as soon as practicable. We ensure that WER information is specific to each employee’s needs and the physical nature of the employee’s workspace. Individualized WER information will be reviewed by RFA each time that the employee’s workspace is modified or relocated, and each time that RFA reviews its general emergency response plans and make changes that would affect the specific employee’s WER information. If an employee with a disability requires the assistance of another person during an emergency (the “Designated Person”), RFA will, with the employee’s consent, provide the Designated Person with all information necessary to allow them to assist the employee.

8: Accommodation Training

RFA provides training on how to accommodate employees with a disability to staff (including management) with any of the following responsibilities:

• recruiting, selecting or training employees;
• supervising, managing or coordinating the work of employees;
• promoting, redeploying or terminating employees; and/or
• developing and implementing employment policies and practices.

This training is provided as soon as reasonably practicable upon hiring and/or assignment to any of the above responsibilities, and on an ongoing basis in connection with changes to RFA’s accessibility policies.

The content of this training shall include, but not be limited to:

• how to make employment opportunities accessible to people with disabilities;
• how to interact and communicate with applicants or employees who are disabled by barriers, including those who use assistive devices, or are assisted by a support person or service animal; and,
• an overview of applicable accessibility legislation and human rights legislation, and RFA’s own accessible employment policies, practices and measures, including any updates or changes.
• Human Resources shall maintain a record of who has taken training and when.
• Human Resources shall maintain a record of who has taken training and when.

9: Employee Privacy

RFA is committed to protecting the privacy and confidentiality of our employees’ personal information and personal health information. An employee’s personal information, including personal health information, that is collected for the purpose of carrying out the objectives of this policy shall be stored by our Human Resources department in a secured location (whether physically or electronically) and shall only be used and disclosed as required to carry out those objectives or as otherwise required by law, unless the employee specifically consents for the information to be used and/or disclosed for some other purpose.

Date of next review: December 31, 2026