Accessibility

Our commitment to equal access and participation for all.

Bold Commerce is committed to ensuring equal access and participation for everyone. We are committed to treating people with disabilities in ways that allow them to maintain their dignity and independence. We believe in inclusion and are committed to meeting the needs of people who face accessibility barriers. We will do this by identifying, removing and preventing barriers and by meeting legislative requirements, such as (without limitation) The Accessibility for Manitobans Act (the “AMA”) and the Accessibility for Ontarians with Disabilities Act (the “AODA”) and corresponding regulations, which address the historical disadvantage suffered by persons with disabilities due to discrimination. Bold will continue to create and implement practices and procedures that reinforce our commitment to accessibility for everyone.

Bold welcomes feedback on how we can provide the most accessible customer service possible. This will allow us to identify barriers and address concerns.

Customers can provide feedback in the following ways:

• Email: [email protected]
• Phone: 204.808.8095
• Visiting our offices
• Via our social media channels
• Support live chat

Bold Commerce Accessibility Policy

Purpose

Bold Commerce is committed to ensuring equal access and participation for everyone. We are committed to treating people with disabilities in ways that allow them to maintain their dignity and independence. We believe in inclusion and are committed to meeting the needs of people who face accessibility barriers. We will do this by identifying, removing and preventing barriers and by meeting legislative requirements, such as (without limitation) The Accessibility for Manitobans Act (the “AMA”) and the Accessibility for Ontarians with Disabilities Act (the “AODA”) and corresponding regulations, which address the historical disadvantage suffered by persons with disabilities due to discrimination.

Scope

Bold is committed to meeting all legislative requirements addressing accessibility, including (without limitation) the AMA and its Customer Service Regulation and Accessible Employment Standards Regulation, and the AODA and its Integrated Accessibility Standards Regulation. This policy reflects our ongoing practices and measures of the requirements of these legislative requirements, including customer service standards and employment standards. Any current or future policy or practice not respecting and promoting the principles of dignity, independence, integration, and equal opportunity for people with disabilities, will be reviewed, modified, or removed.

Accessible customer service standards, procedures and practices

Bold is committed to providing access to our facilities and delivering excellent service at all times in a way that respects the dignity and independence of all of our customers and visitors.

Our commitment to this is demonstrated in the following areas:

Communication and Information

We will make information available in an accessible format or provide communication support to people with disabilities in a way that considers their disability. Bold has set out the following practices, among others, to meet this customer service standard:

• Ask customers how we can assist them better and if they have a preferred method of communication
• Create documents with easy to read fonts and plain language
• Have paper and pen available if required
• Ensure our website and services are accessible and compatible with screen readers

Assistive devices

When accessing our facilities, products, and services, people with disabilities may use their personal assistive devices. If the device presents a health or safety concern, we will attempt to use other measures to ensure the person has access to our facilities, products, and services. Bold has set out the following practice, among others, to meet this customer service standard:

• Employees are trained and familiar with various assistive devices that customers may use. This will include training on appropriate interaction of employees with customers using assistive devices.
• The Learning and Development Team is to ensure this training is available to all customer-facing employees.

Support People and Service Animals

Bold welcomes customers accompanied by a support person and is committed to meeting the requirements of provincial human rights legislation and welcomes customers accompanied by service animals. Bold has set out the following practices, among others, to meet this customer service standard:

• Training will include appropriate interaction of employees with customers accompanied by a support person
• If a support person is accompanying a person with a disability at an event where a fee is normally charged, no fee will be charged for the support person
• If a support person is accompanying a person with a disability at an event where a fee is normally charged, no fee will be charged for the support person
• When it is not easy to identify if an animal is a service animal, staff may ask: “Is the animal assisting you?”
• Training will ensure employees understand the rights of a person accompanied by a service animal and will not pet, play, or feed a service animal without permission of its handler

Maintaining Barrier-Free Access

We are committed to maintaining barrier free access to our goods and services. Bold has set out the following practices, among others, to meet this customer service standard:

• Keeping lobbies, hallways, and meeting rooms clear of clutter
• Keeping entranceways cleared of snow and ice
• Allowing space for mobility devices

Notice of Temporary Disruption

In the event of a disruption of services or facilities affecting customers disabled by barriers, we will promptly post notices. This will include the reason, anticipated length of time, and description of alternative services or facilities if available. Services or facilities affected by this policy include:

• Accessible washrooms
• Automatic doors
• Methods of contacting Bold

Bold has set out the following practice, among others, to meet this customer service standard:

• A notice will be posted in company-wide Slack channels and at main entrances, including the anticipated duration of the disruption

Feedback Process

Bold welcomes feedback on how we provide accessible customer service. This will allow us to identify barriers and address concerns.

Customers can provide feedback in the following ways:

• Email: [email protected]
• Phone: 204.808.8095
• Visiting our offices
• Via our social media channels
• Support live chat: Bold Commerce Help Center

All feedback will be directed to

Training

Accessibility training will be a part of Bold’s orientation program for new employees and will occur within the first two weeks of employment, depending on position. For all existing employees, an online training program will be completed via our online training platform. Training will include:

• The purpose of the AMA and the requirements of the Customer Service Standard Regulation, the AODA and the Integrated Accessibility Standards Regulation, and other applicable accessibility legislation and human rights legislation.
• The policies and actions related to the Customer Service Standard Regulation, the Integrated Accessibility Standards Regulation, and other applicable provincial legislation.
• How to interact and communicate with people disabled by barriers, including people who use assistive devices or require the assistance of a service animal or support person.
• What to do if a person with a disability is having difficulty in accessing our goods, services, or facilities.

If there are any changes to our accessible customer service procedures and practices, we will inform and train staff.

Accessible employment standards, procedures and practices

Bold is committed to removing and preventing accessibility barriers that affect current and potential future employees.

Our commitment to this is demonstrated in the following areas:

Recruitment

Bold will inform potential job applicants that reasonable accommodations are available during the recruitment process. Such notice will be provided on our website. If a job applicant requests disability-related accommodation, we will consult with the applicant to determine what accommodations can be provided, taking into account the individual’s disability-related needs, and provide or arrange for the provision of reasonable accommodation when carrying out the recruitment process.

Once a candidate is selected for hiring (whether or not the applicant is disabled), we will advise the applicant of the measures, policies, and practices in place for accommodating disabled employees.

Workplace Emergency Response Information and Assistance

When Bold is aware that an employee has a disability that requires accommodation in an emergency situation, individualized workplace emergency response information will be provided to the employee as soon as reasonably practicable after we are made aware of such requirement. We are committed to notifying employees of the availability of individualized assistance and preparing individual plans for employees who advise us of their need for accommodation in emergency situations. With the employee’s consent, Bold may provide the necessary information to a person designated by Bold to provide assistance to an employee who has a disability which requires accommodation in an emergency situation. We will review the individualized workplace emergency response information each time the employee is moved to a different workspace, the workspace is modified, or Bold’s general emergency response plan is changed such that it would affect the employee’s response in an emergency.

Employee Accommodations

Accommodation Requests

Employees who believe they require accommodation due to disability are responsible for requesting accommodation from the Human Resources department or the employee’s supervisor, either orally or in writing. We encourage employees to make their request in writing and to include relevant information, such as:

• A description of the accommodation that is being sought.
• The reason accommodation is needed.
• How the requested accommodation will assist in performance of job function.

Employees have the right to request the assistance of a person knowledgeable in workplace accommodations in the development of the accommodation plan.

In scenarios where an employee has not requested accommodation, but it is reasonably apparent that the employee may have a disability that requires accommodation, the employee’s supervisor may approach the employee to determine whether the employee wishes to request accommodation under this policy.

If the employee makes an oral request for accommodation, the Human Resources department and/or the employee’s supervisor will document the request, including the employee name, positions, and date of the request, as well as any details and accommodation options suggested by the employee. The Human Resources department may require more information related to the employee’s accommodation request, including provision of a note from the employee’s doctor, if any of the following apply:

• The employee’s disability is not obvious.
• The accommodation request does not clearly indicate a need related to disability.
• More information on the employee’s limitations or restrictions is needed to determine the appropriate accommodation.
• There is an objective reason to question the legitimacy of the employee’s request for accommodation.

Failure to respond to such requests for information may delay the provision of accommodation.

We may require the employee to attend an independent evaluation from a health care professional or other practitioner in the area of workplace accommodations of Bold’s choosing, at Bold’s expense.

Individual Accommodation Plans

Accommodations are individualized to reflect the employee’s particular needs and circumstances, short of causing undue hardship to Bold. Both the employee and the possible accommodations are assessed on an individual basis. The employee’s accommodation preferences will be considered but are not determinative.

Examples of possible accommodation solutions may include:

• Modifying the employee’s work location or work schedule.
• Creating a graduated return to work plan.
• Modifying the way the employee’s work is performed.
• Providing assistive devices for performing work tasks.
• Modifying equipment used by the employee.
• Modifying the workplace itself.
• Providing information in accessible formats.

Where necessary, interim accommodation may be provided while longer term solutions are developed. An employee’s accommodation needs or Bold’s organizational requirements may change over time and, therefore, any accommodation provided will be monitored and may require adjustments to improve effectiveness or efficiency.

Where an accommodation request is approved, the employee may request a copy of their individualized accommodation plan, in an accessible format. The individual accommodation plan will be reviewed and updated at least every six months, or earlier upon request by the employee.

We may deny an employee’s request of an individualized accommodation plan in the following circumstances:

• The employee is able to carry out most of the job without an accommodation.
• The independent medical examination does not support the employee’s self-assessed requirement for a workplace accommodation.
• Our research and evidence shows that the accommodation request would cause undue hardship (e.g., by creating safety risks to other employees or a significant measurable financial burden).

Where an accommodation request is denied, the Human Resources department or the employee’s supervisor will provide written reasons for denying the request to the employee.

When accommodation is refused based on undue hardship or otherwise, or accommodation is offered but the employee believes that the accommodation offered does not meet their needs, the employee may submit a written request for a review of the decision to the Director of Legal and Compliance.

Return to work

Where an employee has been absent from work due to a disability and they require reasonable accommodation on returning to work, we will work with the employee in determining the accommodations necessary to facilitate the return to work. If the employee requires disability-related accommodation, an individual accommodation plan will be developed in accordance with this policy.

Privacy

Confidentiality will be maintained, consistent with the needs of the accommodation process. Personal information and personal health information will only be disclosed to those with a demonstrated need to know for the purpose of determining or providing accommodation, as required to take corrective action for violation of this policy, or as required by law.

Bold and all individuals involved in the accommodation process will comply with the requirements of applicable privacy legislation and our privacy policy to protect employee personal information. The following steps will be taken to protect the employee’s personal information and personal health information:

• Implement and maintain administrative, technical, and physical controls to properly secure personal information and personal health information.
• Restrict access to personal information and personal health information to those who have a need to know the information.
• Investigate and respond to incidents or suspected incidents of unauthorized access to personal information or personal health information.
• Properly disposing of all personal information and personal health information following the applicable retention period.
• Providing training to employees on Bold’s data security policies.

No Reprisals

No reprisal or penalty will be taken against a person for requesting accommodation in good faith.

Administration

This Canadian Accessibility Policy will be reviewed and updated whenever there is a change that affects its effectiveness and, at a minimum, every two years. Bold expressly reserves the right to change, modify, or delete the provisions of this policy without notice.

The Human Resources department is responsible for the administration of this policy. If employees have questions regarding this policy, they may contact the Human Resources department.