Ontario Accessibility Policy and Multi-year Accessibility Plan

We are committed to accessibility for persons with disabilities based upon the core principles of dignity, independence, inclusion, integration, responsiveness and equality of opportunity. We are committed to meeting the needs of persons with disabilities in a timely manner, and will do so by preventing and removing barriers to accessibility and meeting the accessibility requirements under the Accessibility for Ontarians with Disabilities Act, 2005, and its Regulations (collectively referred to as the AODA).

Under the AODA all public and private sector organizations in the Province of Ontario must meet the requirements of accessibility standards established by regulation. This policy establishes the accessibility policy, multi-year accessibility plan and related commitments, in accordance with the Integrated Accessibility Standards (Ontario Regulation 191/11) for Ontario operations of Enwave Energy Corporation and its subsidiaries (together referred to as “Enwave”, the “Company”, “we” or “us”).

This Policy applies to all Enwave Representatives in the Province of Ontario.

1.0 General Accessibility Policy

Commitment to Accessible Information and Communications

(i) Accessible Formats and Communication Supports

Upon request, Enwave will provide the following in an accessible format or via accessible communication support:

a. all organizational information and communications made available to Enwave’s customers and the public, including this policy;

b. any publicly available emergency procedures, plans or public safety information to its customers and the public; and

c. access to any processes for receiving and responding to feedback. 

Enwave will consult with the person making the request to determine the suitability of any accessible format or communication support provided. This information and documentation will be provided as soon as is practicable, but specific timeframes may vary depending on the format requested.

(ii) Website Accessibility

Enwave continues to work towards increasing the accessibility of its internet website(s) so that its internet website(s), and the associated web content and web-based applications published after January 1, 2012, will conform to the Web Content Accessibility Guidelines (WCAG)2.0 at LevelAA (other than success criteria 1.2.4 and 1.2.5), except where doing so is not practicable.

(iii) Feedback Regarding Accessibility

Enwave encourages persons with disabilities to provide comments on the goods, services and facilities they receive or use, including feedback regarding the accessibility of those goods, services or facilities. Feedback may be delivered to Enwave in person, by telephone, mail, email or other means available to the person.

Customers may use any of the following feedback channels:

• In person at Enwave’s corporate office at 16 York Street, Suite 2200 Toronto, ON M5J 0E6
• By telephone at (416) 392-6838 or e-mail at info@enwave.com
• By mail in writing or through electronic or audio recording
  

All feedback will be reviewed for possible improvement. Feedback will be directed to the most appropriate department for resolution, and any complaints will be addressed as soon as possible. Persons providing feedback can expect an acknowledgment of their feedback to be issued within 10 business days. The acknowledgment will indicate when the matter will be addressed, and when the individual will be notified further in the matter. Correspondence with the individual will take into account their accessibility needs and will be provided in accordance with Enwave’s commitment to accessible information and communication supports, described above.

Accessible Employment

Enwave has implemented the following practices and procedures to promote the inclusion of applicants for employment and existing employees with disabilities in its workplace.

(i) Recruitment

Enwave notifies employees and the public about the availability of accommodations for applicants with disabilities during the recruitment process and when job applicants are individually selected to participate in an assessment or selection process.

If a selected applicant requests an accommodation, Enwave consults with the applicant and provides or arranges for the provision of a suitable accommodation (including with respect to any materials or processes used in the application process), taking into account the applicant’s disability.

When making offers of employment, Enwave notifies successful applicants of its policies for accommodating employees with disabilities

(ii) Employee Notification

Enwave informs its employees of its policies used to support its employees with disabilities: (a) to new employees as soon as practicable after they begin their employment; and (b) whenever there is a change to existing policies on the provision of job accommodations that take into account accessibility needs due to a disability. 

(iii) Accessible Formats and Communication Supports

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

Enwave will consult with the employee making the request in determining the suitability of an accessible format or communication support.

(iv) Individual Accommodation Plans

Enwave has a written process for the development of a documented Individual Accommodation Plan. A copy of this process can be found in our Accessible Employment Policy.

(v) Return to Work Process

Enwave has a return-to-work process for employees who have been absent from work due to a disability and require disability-related accommodation in order to return to work. A copy of this process can be found in our Accessible Employment Policy.

(vi) Performance Management, Career Development and Advancement and Redeployment

Enwave takes into account the accommodation needs of its employees, including any individual accommodation plans of employees, when: (a) using performance management; (b) providing career development and advancement opportunities; and (c) redeploying employees.

(vii) Workplace Emergency Response Information

Enwave provides 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 due to the employee’s disability. More details regarding this process can be found in our Accessible Employment Policy.

Training Commitment

Enwave provides three types of training related to accessibility: accessible customer service training (as further discussed below); integrated standards accessibility training; and training on the Human Rights Code as it relates to individuals with disabilities. 

This training will be provided to all Representatives as soon as practicable and generally, within three months of the individual’s commencement of duties. Training will also be provided on an ongoing basis when changes are made to these policies, practices and procedures.

Enwave will keep a record of the training provided, including the dates on which the training is provided and the number of individuals to whom it is provided.

2.0 Accessible Customer Service

Enwave is committed to providing access to goods and services to its customers in a manner that is consistent with the principles of independence, dignity, integration and equality of opportunity, and that is in compliance with the AODA. To that end, Enwave recognizes the importance of:

• Providing integrated access to goods and services for individuals with disabilities;
• Openly communicating and responding to the needs of customers with disabilities in order to provide them with excellent customer service; and
• Complying with the mandatory Customer Service Standard addressed under the AODA.
  

Accessible Customer Communications

Enwave Representatives are required to communicate with customers with disabilities in a manner that takes into account their disabilities. Representatives will consider how a customer’s disability may affects the way that the customer expresses, receives or processes communications and, where possible, they will ask the customer how to best communicate with the individual.

Assistive Devices

Assistive devices that may be used by individuals with disabilities are welcome on Enwave’s premises that are open to the public or other third parties. Enwave will take steps to ensure that Representatives are familiar with commonly used assistive devices.

Service Animals

Enwave welcomes guide dogs or other animals that serve individuals with disabilities in those areas of its premises that are open to customers and will permit the customer to keep the service animal with them, except for those animals that are otherwise excluded by law from the premises. In the event that a service animal is otherwise excluded by law from the premises, Enwave will provide the applicable customer with an alternative method of obtaining, using or benefitting from its goods or services.

Support Persons

Enwave welcomes persons who support individuals with disabilities to accompany them onto those parts of its premises that are open to the public or other third parties. Enwave will ensure that customers who so require have access to their support persons while on the premises. Such support persons need not be paid, professional support workers. They may be volunteers, family members or friends who provide support to the customer.

Temporary Unavailability of Access to Goods or Services for Customers with Disabilities

In the event that a facility, service or system offered by Enwave to customers with disabilities becomes temporarily unavailable, in whole or in part, Enwave will provide notice of the disruption, as is reasonable in the circumstances. The notices will be posted in a conspicuous location at Enwave or in another reasonable location, in the circumstances and shall:

• Explain the reason for and anticipated length of the disruption; and
• Provide a description of and indicate the location of an alternative facility or service that is accessible to individuals with disabilities, if available.
  

Accessible Customer Service Training

All Enwave Representatives will be:

• Provided with an overview of the AODA and the Customer Service Standard under the Regulations;
• Trained on how to interact, communicate and assist people with disabilities, and in particular, people with assistive devices, and those who require the assistance of a guide dog, service animal or support person;
• Made aware of the policies and procedures created by Enwave in accordance with the Customer Service Standard; and 
• Trained on how to help a person with a disability who is having difficulty accessing Enwave’s goods or services.
  

This training will also be provided on an ongoing basis, as soon as practicable, whenever Enwave’s policies change with respect to customer service accessibility for individuals with disabilities.

3.0 Multi-Year Accessibility Plan

Under the AODA, private and not-for-profit organizations with 50 or more employees in Ontario must create a multi-year accessibility plan. This Multi-Year Accessibility Plan outlines the policies and actions that Enwave will or has put in place to improve opportunities for people with disabilities across the organization.

This multi-year accessibility plan will be updated at least once every five years.

4.0 Availability of this Policy

A copy of this policy will be posted on Enwave’s corporate website. 

Upon request, Enwave will provide or arrange for the provision of this policy, or the information contained in this policy, to the requesting individual in an accessible format or with a communication support in a timely manner that takes into account the person’s accessibility needs due to disability and at no cost. In doing so, Enwave will consult with the person making the request in determining the suitability of the format or communication support.

Last Updated October 2021

Appendix A – Definitions

“Accessible Formats” means any form of large print, clear text, recorded audio and electronic formats, Braille and other formats usableby persons with disabilities in order to conduct business with Enwave.

“Communication Supports” means captioning, alternative and augmentative communication supports, plain language, signlanguage and other supports that facilitate effective communications in order to conduct business with Enwave.

“Disability”as defined in the Ontario Human Rights Code means:

(d) any degree of physical 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 impairment, 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,

(e) a condition of mental impairment or a developmental disability,

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

(g) a mental disorder, or 

(h) an injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997. 

“Representative” means employees, volunteers, others that provide goods or services on Enwave’s behalf, and all those who are involved in the development of Enwave’s policies, practices and procedures.

“Web Content Accessibility Guidelines” means the World Wide Web Consortium Recommendation, dated December 2008, entitled“ Web Content Accessibility Guidelines (WCAG)2.0”.

“Website” means acollection of related web pages, images, videos, or other digital assets that are addressed relative to a common Uniform Resources Identifier (URI) and is accessible to the public.