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Municipal Services

Accessibility Policy

HGC Management Inc.

Company Policy and Standards for Compliance with

 AODA Integrated Accessibility Standards Regulation (IASR)

1.0 Purpose:

Under the Accessibilities for Ontarians with Disabilities Act, 2005 all public and private sector, organizations must meet the requirements of accessibility standards established by regulation in the areas of Employment, Information and Communications, Transportation and Public Spaces.

This document describes HGC company policies for these areas In accordance with Ontario Regulation 191/11, Ontario Regulation 413/12 and Human Rights Act of Ontario. 

2.0 Statement of Commitment

HGC Management is committed to ensuring it meets Ontario Accessibility and Human Rights Standards for a workplace in the areas of Information and Communication and Employment as set out the Ontario Accessibility Standards Regulations and Human Rights Code.

For Employment

HGC Management is committed to building a skilled, inclusive workforce reflective of Canadian society. As a result, it promotes employment equity.

HGC Management is also committed to developing inclusive, barrier-free selection processes and work environments by offering accommodations were practical.

HGC Management is also committed to assisting recovered Employees to return to work with an agreed to return to work program.

HGC Management is also committed to informing and training employees of our employment commitment and policies.

HGC Management is committed if requested to providing information on our Accessibility Standards and multi-year accessibility plan including emergency response information in a suitable format for accessibility.

HGC Management is also committed to providing information on its website to applicable legislated standards.

This revised Accessibility policy was adopted by the Board of Directors of HGC Management Inc. on January 2nd 1998 and reviewed January 2th 2020.

3.0 Definitions:

Below is a list of fifteen definitions used in this policy, listed in alphabetical order:

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.

Accommodation means the special arrangements made or assistance provided so that person with disabilities can participate in the experiences available to persons without disabilities. Accommodation will vary depending on the person’s unique needs.

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.

Communications means the interaction between two or more persons or entities, or any combination of them, where information is provided, sent or received.

Conversation Ready means an electronic or digital format that facilitates conversions into an accessible format.

IAP means Individualized Accommodation Plan.

Information includes data, facts and knowledge that exists in any format, including text, audio, digital or images, and that conveys meaning.

Internet Website means a collection of related web pages, images, video or other digital assets that are addressed relative to a common Uniform Resource Identifier (URI) and is accessible to the public.

Maintenance of Public Spaces means activities that are intended to keep existing public space and elements in existing public spaces in good working order or to restore the space or elements to their original condition, examples of which include painting and minor repairs.

Mobility Aid means a device used to facilitate the transport in a seated posture, of a person with disabilities.

Mobility Assistive Device means a cane, walker, wheelchair, scooter or similar aid.

New Internet Website means either a website with a new domain name or a website with an existing domain named undergoing a significant refresh.

Redeployment means the reassignment of employees to other departments or jobs within the organization as an alternative to layoff, when a particular job or department has been eliminated.

Unconvertible means if is not technically feasible to convert the information or communications. It also means if the technology to convert the information or communications is not readily available.

Web Content Accessibility Guidelines means the World Wide Web consortium recommendation, dated December 2008, entitled “Web Content Accessibility Guidelines” (WCAG) 2.0

4.0 General Provisions:

This section covers the general requirements of the Integrated Accessibility Standards Regulation.

Multi-Year Accessibility Plan:

HGC Management Multi-Year Accessibility Plan outlines a phase-in strategy to prevent and remove barriers and addresses the current and future requirements of the Accessibility for Ontarians with Disabilities Act (AODA). HGC Management will review the progress and implementation of the plan, post the information on our website and will provide it in alternative formats upon request. The plan will be reviewed and updated at least once every five years.

Procuring or Acquiring Goods, Services or Facilities:

HGC Management will use accessibility criteria and features when procuring or acquiring goods, services or facilities, except where it is not practical to do so, in which case, if requested we will provide an explanation.


HGC Management will ensure that training is provided to all employees on the requirements of the accessibility standards referred to in the regulation and on the Human Rights Code as it pertains to persons with disabilities. Training will be provided as soon as practicable. If any changes are made to this policy or the requirements training will be provided. We shall maintain a record of the dates when training is provided and the number of individuals to whom it was provided.

Information and Communications Standard:

HGC Management will create, provide and receive information and communications in ways that are accessible to people with disabilities.

If HGC Management determines that it is not technically feasible to convert the information or communications, or the technology to convert the information or communications is not readily available, we will be obligated to provide the person that requires the information, with an explanation as to why the information or communications are unconvertible, and a summary of the unconvertible information or communications.

Emergency Information:

HGC Management has a process in place for receiving and responding to feedback and will ensure that those processes are provided in accessible formats and with communication supports upon request. We will notify the public about the availability of accessible formats and communication support.

Accessible Formats and Communications Supports:

HGC Management shall be obligated to provide or arrange for accessible formats and communication supports for persons with disabilities for the situations listed below:

  • Upon request in a timely manner that takes into account the persons’ accessibility needs due to a disability;
  • At a cost that is no more than the regular cost charged to other persons;
  • Consult with the person making the request and determine suitability of an accessible format or communication support;
  • Notify the public about the availability of accessible formats and communication supports.

Website Accessibility:

HGC Management shall make their internet website and web content conform to the World Wide Web Consortium Web Content. Accessibility Guidelines (WCAG) 2.0 initially at Level A and increasing to Level AA. All information on the website back dated to 2012 will be accessible. By January 1, 2021, all internet websites and web content will conform to WCAG 2.0 Level AA.

Employment Standard:

The Employment Standard builds upon the existing requirements under the Ontario Human Rights Code in relation to how we provide accessibility throughout the entire employment cycle. It applies in respect to employees and does not apply to volunteers and other non-paid individuals.

The requirements of the Employment Standard shall be met by January 1, 2016 unless otherwise specified.


HGC Management shall notify employees and the public about availability of accommodation for applicants with disabilities as per the three items below:

  • When job applicants are individually selected to participate in an assessment or selection process;
  • If a selected applicant requires an accommodation, HGC Management shall consult with the applicant and provide or arrange for the provision of a suitable accommodation that takes into account the applicant’s disability;
  • Notify successful applicants of the policies for accommodating employees with disabilities.

Employee Notification:

HGC Management shall inform its employees of its policies used to support its employees with disabilities, including but not limited to, policies on the provision of job accommodations that take into account an employee’s accessibility needs due to a disability.

HGC Management shall provide information required under this section to new employees as soon as practicable after they begin their employment and whenever there is a change to existing policies on the provisions of job accommodations that take into account an employee’s accessibility needs due to a disability.

Accessible Formats:

In addition and where an employee with a disability requests it, HGC Management will consult with the employee to provide or arrange for the provisions of accessible formats and communication supports as per the three points below:

  • Information that is needed in order to perform the employee’s job;
  • Information that is generally available to employees in the workplace;
  • And consult with the employee making the request in determining the suitability of an accessible format or communication support.

Individual Accommodation Plan (IAP)

HGC Management shall have in place a written process for the developing a documented Individual Accommodation Plan for employees with a disability. Process to include for consideration the twelve points below:

  • The employee’s participation in the development of the IAP;
  • Assessments on an individual basis;
  • Identification of accommodations to be provided;
  • Timelines for the provision of accommodations;
  • HGC Management may request an evaluation by outside medical or other expert, at our expense, to assist with determining accommodation and how to achieve accommodation;
  • Employee may request the participation of a representative from their bargaining agent, where represented, or otherwise a representative from the workplace;
  • Steps taken to protect the privacy of the employee’s personal information;
  • Frequency with which the IAP will be reviewed and updated and the manner in which it will be done;
  • If denied, the reasons for denial are to be provided to the employee;
  • A format that takes into account the employee’s disability needs;
  • If requested, any information regarding accessible formats and communication supports provided;
  • Identification of any other accommodation that is to be provided.

Return to Work:

HGC Management will have in place 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. Such processes must be documented and must outline the steps that HGC Management will take to facilitate the return to work and include an individual accommodation plan.

Performance Management, Career Development and Advancement, and Redeployment:

HGC Management has no matrix for promoting one over the other they all do the same job for the same rate of pay for that job position. Career Development and Advancement is not a factor nor is Redeployment as per below:

  • Driver employees are required to hold a valid DZ license to perform these duties, separate pay rate;
  • Operators also need specific qualification in order to perform that work, separate pay rate;
  • Sorters  separate rate;
  • There is no opportunity for Redeployment due to contract loss as geographic location of our contracts makes it impractical.

Workplace Emergency Response Information:

HGC Management shall provide individualized workplace emergency response information to employees who have a disability as per the four points below:

  • 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;
  • If the employee who receives an individual workplace emergency response information requires assistance and with the employee’s consent, HGC Management shall provide the workplace emergency information to the person designated by HGC Management to provide assistance to the employee;
  • As soon as practicable after becoming aware of the need for accommodation due to the employee’s disability;
  • Review the individualized workplace emergency response information when the employee moves to a different location in the organization, when overall accommodations needs or plans are reviewed and when the employer reviews its general emergency response policies.

Transportation Standard:

The Transportation Standard will make it easier for people to travel in Ontario, including persons with disabilities, older Ontarians and families traveling with children in strollers. The Transportation Standard does not apply to us an organization, but we will inform staff through staff training on the upcoming changes and its impact and benefits to the community for people with disabilities.

Public Spaces Standard:

HGC Management shall incorporate accessibility into public spaces that are newly constructed or redeveloped on and after January 1, 2017. HGC Management does not have any public space and it is unlikely that we will develop public space. If we should, we will ensure that we follow the existing requirements stated under the Design of Public Spaces Standard (Accessibility Standard for the Build Environment) for recreational trails and beach access routes, outdoor public use eating areas, outdoor play spaces, and exterior paths of travel, accessible parking, and service related elements. We shall provide maintenance and restoration of public spaces, where applicable, by ensuring our multi-year accessibility plan includes procedures for preventative and emergency maintenance of accessible elements in public spaces and procedures for dealing with temporary disruptions when accessible elements required under this section are not in working order.

Scope and Responsibilities:

This policy has been written in accordance with the regulation and addresses how HGC Management achieves accessibility through meeting the regulation’s requirements. It provides the overall strategic direction that will follow to provide accessibilities support to Ontarians with disabilities.

The requirements of the Regulation include the following four items:

  • Establishment, implementation, maintenance and documentation of a multi-year accessibility plan, which outlines the organizations strategy to prevent and remove barriers and meet its requirements under the Regulation;
  • Incorporation of accessibility criteria and features when procuring or acquiring goods, services, or facilities;
  • Training; and
  • Other specific requirements under the Information and Communications, Employment, transportation and Public Spaces Standards.

2 Accessibility Standard for Customer Service (added May 2014)


Providing Goods and Services to People with Disabilities

HGC Management is committed to excellence in serving all customers including people with disabilities.

Assistive devices

We will ensure that our staff are trained and familiar with any assistive devices that may be used by customers with disabilities while accessing our facilities.


We will communicate with people with disabilities in way that take into account their disability.

Service Animals

We welcome people with disabilities and their service animals.  Service animals are allowed on the parts of our premises that are open to the public.

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.

Notice of temporary disruption

In the event of a planned or unexpected disruption to services for customers with disabilities (i.e. picking up recycling totes, tours) HGC Management will notify customers via a notice that will include information about the reason for the disruption, its anticipated length of time and a description of alternative facilities, if available.

The notice will be placed at the front door of the location, and on our website.


HGC Management will provide training to employees who deal with the public.  Training will also be provided to people involved in the development of policies, plan, practices and procedures to the provision of our goods and services.

Training will be provided to the staff upon hiring via this Employee Orientation Booklet, Health and Safety manual, and monthly training requirements.

Supervisors and administration staff will ensure when communication with potential new hire employees, they are made aware of HGC Accessibilities policies and accommodation plan.

Training will include:

  • An overview of the Accessibility for Ontarians with Disabilities Act, 2005 and the requirement of the customer service standard.
  • How to interact and communicate with people with various types of disabilities
  • How to interact with people with disabilities who use an assistive device or require the assistance of a service animal or a support person.
  • What to do if a person with a disability is having difficulty in accessing any of our locations.

Staff will also be trained when changes are made to our plan.

Feedback process

Customers who wish to provide feedback on the way HGC Management provide goods and services with disabilities can communicate via telephone, email, verbally or via our website.

All feedback, including complaints, will be submitted to Head Office for review.  Customers can expect to hear back in 5 business days.

Notice of availability

HGC Management will notice the public that our policies are available upon request by posting them on our website.

Modifications to this or other policies

Any policy of HGC Management Inc. that does not respect and promote the dignity and independence of people with disabilities will be modified or removed.

HGC Accessibility Action Plan WorksheetUpdated September 2020 
HGC Management Inc.  
1GeneralWrite/Create Accessibility Policies including statement of commitmentSenior Management/HOcompletecompleted 
Post policy statement of commitment at locationsSite Administration/Teenacompletecompleted 
Post policy publicly on WebsiteKim Stablerwaiting for website developmentDec-20 
establish, implement and maintain multi year A planSenior Management/HOcompletecompleted 
establish implementation committee to monitor A Plan monthlySenior Management/HOcompleteongoing 
Post Accessibility plan on websiteKim Stablerwaiting for website developmentDec-20 
Review A Plan every five yearsSenior Management/HOin Sept 2025Sep-20 
Provide employee training for Ontario Act and regulationsSite Management/AdministrationOn Hirecompleted
Provide employee training for human rights act AccessibilitySite Management/AdministrationOn Hirecompleted
Develop written training modulesHealth & Safety Coordinatorongoing
monitor training compliance and maintain recordTeenaongoing 
3Information and communicationAssure website complies with WCAG2.0 level AASenior Managementwaiting for website developmentDec-20 
4Employment StandardsPrepare and include accessibility statement with job posting or advertisingSite Management/Administration/Teenacompleted
 When selecting applicants advise of accommodation availabilitySite Management/Administrationongoing
If applicant requests accommodation provide suitable accommodationSite Management/Administration/Teenaongoing
New hires will be advised of accommodation policiesSite Management/Administrationongoing
if requested HGC will provide company and job information in accessible formatSenior management/HOongoing 
emergency information provided in accessible format for disabilitySenior Management? HOongoing 
document how notification, consultation and accommodation is done.Mark Chartrand/Teenacompleted 
post documents posterSite Administration/Teenacompleted 
5Individual Accommodation plansDevelop written plan for individual accommodationSite Management/Administration/Teenaongoing
post documents posterSite Administrationcompleted 
6Return to work plansdevelop a return to work process for employees absent due to disabilitySite Management/Administration/Teenaongoing

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