Accessibility Policy

MORGUARD ACCESSIBILITY POLICY

1.0 INTRODUCTION

The purpose of the Accessibility for Ontarians with Disabilities Act, 2005 (the “AODA”) is “to benefit all Ontarians by developing, implementing, and enforcing accessibility standards in order to achieve accessibility for Ontarians with disabilities with respect to goods, services, facilities, accommodation, employment, buildings, structures, and premises on or before January 1, 2025; and providing for the involvement of persons with disabilities, of the Government of Ontario and of representatives of industries and of various sectors of the economy in the development of the accessibility standards.” The Morguard Accessibility Policy (the “Policy”) outlines the goals, policies, practices, and procedures adopted by Morguard Corporation and certain of its subsidiaries - namely Morguard Investments Limited, Morguard REIT, Morguard Residential, Morguard Revenue Properties, and Morguard Financial Corp (referred to in this Policy as “we,” “our,” “us,” or Morguard, as appropriate) - regarding accessibility for Ontarians with disabilities, in compliance with the AODA.

Under the AODA, various Accessibility Standards are planned to ensure Ontario is fully accessible to persons with disabilities by 2025. The Accessibility Standard for Customer Services (the “ASCS”), Ontario Regulation 429/07, became effective for Morguard on January 1st, 2012. The Integrated Accessibility Standards (the “IAS”), Ontario Regulation 191/11, has a staggered implementation date, with requirements becoming effective for Morguard between January 1st, 2012, and January 1st 2021.

This Policy addresses the requirements of the AODA, the ASCS and the IAS by speaking to Morguard’s policies, practices, and procedures with respect to accessible customer service in general, and in relation to assistive devices, communication with persons with disabilities, the use of service animals and support persons by persons with disabilities, the provision of notice for disruptions to accessibility services, accessibility training, accessible emergency procedures, our feedback process, and the provision of notice of our documentation in relation to the AODA, ASCS, and IAS. This Policy is intended to benefit all persons with disabilities, as defined in the AODA, and strives towards adhering to the principles of dignity, independence, integration, and equality of opportunity for persons with disabilities in the provision of our goods and services. This Policy will be amended, as required, as other AODA standards are approved and become law, and as the requirements under these standards become effective for Morguard.

This Policy aligns with Morguard’s reputation for adherence to the highest principles of fairness, honesty, and integrity in the conduct of its business, and its commitment to maintaining the highest ethical and legal standards in its operations and in its dealings with the public at large. Through working towards achieving accessibility for Ontarians with disabilities with respect to goods, services, facilities, accommodation, communications, employment, buildings, structures, and premises, Morguard hopes to achieve and maintain its principles and standards.

This policy is available in alternative formats upon request.

2.0 PRINCIPLES

Morguard will strive to provide inclusive and integrated customer service that respects the dignity and independence of persons with disabilities, through limiting barriers to access and aspiring towards the highest standards of customer service. It is Morguard’s goal that all policies, practices, and procedures contained in this Policy or derived therefrom are consistent with the principles of dignity, independence, equal opportunity, and integration for persons with disabilities.

3.0 APPLICATION

This policy applies to all employees who interact with the public or third parties in the provision of our goods and services in Ontario.

Morguard will strive to ensure that any third parties who act on our behalf and interact with the public or third parties in the provision of goods and services will comply with the requirements of the AODA. This may include, but is not necessarily limited to, the use of reasonable efforts to include a general requirement of compliance with all Morguard and Government directives and policies as applicable to Morguard and/or the third party, in all relevant third-party service contracts, and the distribution of a copy of this Policy to said third parties.

Third parties are responsible for ensuring that all contractors and sub-contractors they retain comply with this Policy and their own requirements under the AODA.

4.0 LIMITATIONS

This policy only addresses the requirements of the AODA, ASCS and IAS, and not any other legislated requirements regarding persons with disabilities. If this policy conflicts with a provision of any other Act or regulation, the provision that provides the highest level of accessibility for persons with disabilities with respect to goods, services, facilities, employment, accommodation, buildings, structures or premises shall prevail.

5.0 DEFINITIONS

ASCS principles are fundamental to the Policy, and underlie the policies, practices, and procedures contained therein. These principles include dignity, independence, equality of opportunity, and integration for persons with disabilities.

Dignity means treatment of persons with disabilities as equally valuable and equally deserving of effective and full service.

Independence means that persons with disabilities should be allowed to perform tasks at their own pace and in their own way, receiving assistance and accommodation, but free from control or undue influence over their actions.

Equality of opportunity relates to obtaining, using, and benefiting from our services. It means that persons with disabilities should have no more burdens and no fewer benefits because of the method of providing goods and services.

Integration means that persons with disabilities should receive the same service, in the same place, and in a similar way as other customers, insofar as this is possible while maintaining equality of opportunity.

Assistive devices are specialized tools or mechanisms used by or provided to persons with disabilities in order to allow for their full participation in society. Without limiting the foregoing, assistive devices may include mobility devices (e.g. wheelchairs, walkers, canes, crutches etc.), elevators, automatic doors, hearing aids, white canes, teletypewriters, and speech generating devices.

Barriers include all things that prevent persons with disabilities from fully participating in society. These include attitudinal barriers (how people think about and interact with persons with disabilities), structural barriers, communicational barriers, systemic barriers (arising from an organization’s policies, practices, and procedures), and technological barriers.

Disability is defined in the Act. It includes both visible and non-visible disabilities. A disability is:

1. Any degree of physical disability, infirmity, malformation or disfigurement that is caused by bodily injury, birth defect or illness, including but not limited to 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").

Service Animals are defined in the ASCS. “An animal is a service animal for a person with a disability if it is readily apparent that the animal is used by the person for reasons relating to his or her disability; or if the person provides a letter from a physician or nurse confirming that the person requires the animal for reasons relating to the disability.”
Examples of service animals include dogs used by people who are blind; hearing alert animals for people who are deaf, deafened or hard of hearing; and animals trained to alert an individual to an oncoming seizure and lead them to safety.

Support Persons are individuals who help with communication, mobility, personal care, medical needs, or with access to goods or services for persons with disabilities.

6.0 ASSISTIVE DEVICES

Morguard is committed to serving persons with disabilities who use assistive devices to obtain, use, or benefit from our goods and services, in accordance with the ASCS principles. Employees who interact with the public or third parties in the provision of our goods and services will allow persons with disabilities to use their assistive devices to obtain, use, or benefit from our goods and services.

Morguard will make efforts to ensure that any third parties who act on our behalf in the provision of goods or services and interact regularly with the public or other third parties will allow persons with disabilities to use their assistive devices to obtain, use, or benefit from our goods and services, through the method set out in Section 3.0 of this Policy.

Where Morguard provides assistive devices for persons with disabilities, Morguard will ensure that the appropriate staff members are aware of their existence, and are able to inform customers on their availability, location, and use.

7.0 COMMUNICATION

In aiming to provide accessible goods and services to persons with disabilities, Morguard strives to communicate effectively with persons with disabilities. As such, Morguard and its employees will communicate with persons with disabilities in a way that takes into account their disabilities. Morguard’s employees are expected to uphold the highest standards of customer service, speaking to all customers with courtesy, respect, and patience. They should communicate with customers by speaking clearly and directly to the customer. Morguard and its employees will use reasonable efforts to ensure that alternative modes of communication are explored, in the hopes of achieving accessible communications.

8.0 SERVICE ANIMALS

Morguard strives to ensure that all premises that we own or operate, and that are accessible to the public or third parties, are accessible to persons with disabilities who are accompanied by a service animal. Any person with a disability who is accompanied by a service animal may freely enter any premise owned or operated by Morguard with his or her service animal, provided that the following requirements are met: the premise is accessible to the public or third parties; the person is entitled or permitted to enter the premise; and, the service animals is not otherwise excluded from the premise by law. So long as the requirements of this section are met, at no time will a person accompanied by a service animal be prevented from having access to that service animal while on those premises.

Morguard will ensure that the appropriate staff members are trained on how to interact with persons with disabilities who are accompanied by service animals.

Where a service animal is excluded by law, Morguard and its employees will take all steps as required by the AODA to ensure the availability of some other measure that enables the person with a disability to obtain, use, or benefit from our goods and services.

Morguard will make efforts to ensure that any properties owned by Morguard, but leased to third parties, comply with AODA requirements in regards to service animals. These efforts may include, but are not necessarily limited to, the use of reasonable efforts to include a general requirement in all relevant third party lease contracts to comply with all Morguard and Government directives and policies as applicable to Morguard and/or the third party.

9.0 SUPPORT PERSONS

Morguard strives to ensure that all premises that we own or operate, and that are accessible to the public or third parties, are accessible to persons with disabilities who are accompanied by support persons. Any person with a disability who is accompanied by a support person may enter any premise owned or operated by Morguard with his or her support person, provided that it is accessible to the public or third parties, and that person is entitled or permitted to enter it. So long as the requirements of this section are met, at no time will a person accompanied by a support person be prevented from having access to that support person while on those premises.

If an amount is payable by a support person for admission to the premises or in connection with his or her presence at the premises, Morguard will ensure that reasonable notice is provided in advance of this fact and the amount payable.

In some circumstances, a manager may deem that it is necessary for a person with a disability to be accompanied by a support person while on a property owned or operated by Morguard. In such cases, a manager may require that a person with a disability be accompanied by an adequate support person, but only in those circumstances that are deemed necessary either to protect the health or safety of the person with a disability, or the health or safety of others on the premises.

Morguard will make efforts to ensure that any properties owned by Morguard, but leased to third parties, comply with AODA requirements in regards to support persons. These efforts may include, but are not necessarily limited to, the use of reasonable efforts to include a general requirement in all relevant third party lease contracts to comply with all Morguard and Government directives and policies as applicable to Morguard and/or the third party.

10.0 NOTIFICATION OF TEMPORARY DISRUPTIONS

Morguard will provide notice to its customers in the event of a planned or unexpected disruption in facilities and services provided by Morguard and used by persons with disabilities to gain access to our goods and services. In the event of a planned disruption, reasonable notice will be provided, as determined by a manager or an appropriate employee. In the event of an unexpected disruption, notice will be provided as soon as is practicable following the discovery of the disruption. This notice will include information about the reason for the disruption, its anticipated duration, and a description of alternative facilities or services, if any, that are available.

The notice will be provided in such a location or locations so as to achieve effective notice, as reasonably determined by a manager or an appropriate employee. Possible locations include, but are not limited to, conspicuous places on the affected premises and on appropriate web-sites.

11.0 ACCESSIBILITY TRAINING FOR STAFF

Morguard will provide training to all of our employees who interact with the public or third parties in the provision of our goods or services, as well as every employee who is involved in the development and approvals of our customer service policies, practices and procedures. New employees will undertake training as part of their orientation as soon as is practicable. Training will be provided on an ongoing basis in connection with any material changes to this Policy or Morguard’s practices and procedures relating to the provision of goods or services to persons with disabilities. Morguard will keep a record of the training, including the number of individuals trained and the dates on which they were trained.

Morguard will ensure that the aforementioned training includes:

• A review of the purpose of the AODA, the requirements of the ASCS, and the contents of this Policy;
• Methods of interaction and communication with persons who have various types of disabilities;
• Methods of interaction with persons with disabilities who use assistive devices or require the assistance of service animals or support persons;
• Instruction on the use of equipment or devices available on our premises or provided by us that may help with the provision of services to a person with a disability; and
• Procedures to undertake when a person with a particular type of disability is having difficulty accessing Morguard’s goods or services.

Morguard will make efforts to ensure that any third parties who act on our behalf in the provision of goods or services and interact regularly with the public or other third parties undertake their own accessibility training, through the method set out in Section 3.0 of this Policy.

12.0 ACCESSIBLE EMERGENCY PROCEDURES

Morguard will ensure that any emergency procedures, plans, or public safety information that we make available to the public will be provided in an accessible format and/or with communications supports, upon request, as soon as is practicable following the request. Morguard will also provide notice to the public of the availability of such accessible formats and/or communication supports for these procedures, plans, and information.

When requested to do so, Morguard will strive to provide these procedures, plans, and information in accessible formats and/or with communications supports in a timely manner, at no greater cost than the regular cost charged to anyone else, and through consultation with the person with a disability who has made the request, in order to determine an accommodation that can meet their communication needs.

If the information cannot be converted into an accessible format, Morguard will provide the individual who has requested the information with the reason why the information cannot be converted, and will offer to provide a summary of the data in an accessible format, as determined through consultation with the person who has made the request.

Morguard will also provide individualized emergency response information as soon as is practicable for every employee who has a disability, so long as Morguard is aware or has been alerted of the need for such accommodations. If, as part of the emergency response plan, the disabled employee requires the assistance of another, Morguard will provide the individualized emergency response information to the person designated to provide assistance, so long as the employee with a disability consents that this can be done.

The individualized emergency response information will be reviewed whenever the employee moves to a different location within the organization; whenever the employee’s accommodation needs are reviewed; and, whenever Morguard reviews our general emergency response policies.

13.0 FEEDBACK PROCESS

In connection with Morguard’s commitment to maintaining the highest principles and ethical and legal standards, Morguard welcomes and appreciates feedback from its customers and clients on all of its operations, including its success at achieving accessible customer services for persons with disabilities.

Notice shall be provided of the existence of our feedback process, including where and/or to whom feedback should be directed, as well as the format in which feedback will be accepted. Notice shall be provided in such a way and in such a location as to be effective, as reasonably determined by a manger or an appropriate employee. One or more of the following formats for providing feedback will be possible, as appropriate in the circumstances: in person, by telephone, in writing, and by electronic text. If such methods are not suitable, customers may request another format for providing feedback, and Morguard will use reasonable efforts to accommodate the requested format or find another suitable alternative.

Where possible, as reasonably determined by a manager or an appropriate employee, immediate action will be taken to address complaints. All feedback pertaining to Morguard’s Accessibility Policy will be directed to Morguard’s Accessibility Policy Officer, who will consider possible steps for addressing the complaint, including, but not limited to, the modification of this Policy and Morguard’s practices and procedures.

14.0 NOTICE OF AVAILABILITY OF DOCUMENTS

Morguard shall provide notice to its customers that the documents required by the ASCS, IAS and AODA are available upon request. The notice will be provided in such a location or locations so as to achieve effective notice, as reasonably determined by a manager or an appropriate employee. Possible locations include, but are not limited to, conspicuous places on the affected premises and on appropriate web-sites.

Morguard is committed to providing accessibility documentation in an accessible format. If a person with a disability requests a document that Morguard is required to provide by the IAS, ASCS and/or the AODA, we will provide the document, or the information contained therein, in a format that takes into account the person’s disability. Morguard will use reasonable efforts to provide the document, or the information contained therein, in the format requested by a person with a disability. If it is not feasible to convert the requested information into that format, Morguard will make reasonable efforts to accommodate the requestor’s needs in a manner that would make such information accessible.

15.0 QUESTIONS ABOUT THIS POLICY

If anyone has a question about this policy or would like to request a copy of it, please contact Morguard’s Compliance Officer:

Andrew Warman
905.281.4839
AWarman@Morguard.com

Please click here to view Morguard's Accessibility Procedures. This document provides guidance to compliance with the Morguard Accessibility Policy by setting out procedures to be followed in generalized scenarios.