AODA: Customer Service Standard Policy

Sterling Karamar Property Management ("SKPM") is committed to providing exemplary services to all of our customers (including tenants, prospective tenants, members of the public and third parties) in accordance with the Accessibility for Ontarians with Disabilities Act, 2005 ("AODA") and Ontario Regulation 429/07 (the "Customer Service Standard").

The following policies, procedures and practices are guided by the fundamental principles underlying the Customer Service Standard. We are committed to ensuring that the Policy is rigorously observed by all employees and any third party that provides goods and services on our behalf.

1. Objectives

The objective of this Policy is to provide a framework through which SKPM can achieve service excellence for people with disabilities. SKPM is committed to providing a respectful, welcoming and inclusive environment to all individuals who seek access to our goods and services.

2. Application

This Policy applies to all employees of SKPM and any third party providing goods and services on behalf of SKPM and who may interact with the SKPM's customers, the public or third parties.

3. Mission Statement

SKPM is committed to providing accessible customer service to persons who have disabilities. SKPM will make reasonable efforts to ensure that this Policy and related practices and procedures are consistent with the following principles as prescribed in the Customer Service Standard: (a) SKPM will provide goods or services in a manner that respects the dignity and independence of persons with disabilities; (b) SKPM will provide integrated services to persons with disabilities wherever possible and will provide alternate measures where necessary, whether temporarily or on a permanent basis, to enable a person with a disability to obtain, use or benefit from the goods or services. (c) SKPM will provide equal opportunity to persons with disabilities to obtain, use and benefit from the goods or services.

4. Providing Goods and Services to People with Disabilities

4.01 Communication

When communicating with persons with a disability, SKPM will take into account the particular individual's needs and circumstances. SKPM's employees, agents and third parties who communicate with customers will be trained on how to interact and communicate with people with various types of disabilities in order to ensure that SKPM provides responsive and effective communication. All communication shall be provided in a manner that respects the dignity and independence of persons with disabilities.

4.02 Assistive Devices

Persons with disabilities shall be permitted to obtain, use or benefit from goods or services through the use of their own assistive devices. SKPM's employees, agents and third parties will be trained so as to be familiar with various assistive devices that may be used by customers with disabilities while accessing services. In the event a person with a disability is hindered from accessing any goods or services offered, the SKPM will use its best efforts to accommodate the person by offering the use of another assistive device that is available or attempt to deliver the same service in another way. SKPM will train employees, agents and third parties on how to use assistive devices that are available at the residential complex for customers. SKPM will also train employees, agents and third parties to inform customers of the assistive devices that are available.

4.03 Telephone Services

SKPM is committed to providing fully accessible telephone service to our members. SKPM will train employees to communicate over the telephone in clear and plain language and to speak clearly and slowly. If telephone communication provides a barrier to a person with a disability, SKPM will be available to communicate in writing, by e-mail, by fax or other electronic means.

5. Use of Service Animals and Support Persons

5.01 Service Animals

SKPM is committed to welcoming persons with disabilities who are accompanied by a service animal on the parts of our premises that are open to the public. If a service animal is excluded by law, SKPM will suggest appropriate alternatives and provide assistance in order to ensure that the person is able to access, obtain, use or benefit from SKPM's services where possible.

SKPM will train employees on how to interact with customers who are accompanied by service animals.

When we cannot easily identify that an animal is a service animal, our staff may ask a person to provide documentation (template, letter or form) from a regulated health professional that confirms the person needs the service animal for reasons relating to their disability.

A regulated health professional is defined as a member of one of the following colleges: • College of Audiologists and Speech-Language Pathologists of Ontario • College of Chiropractors of Ontario • College of Nurses of Ontario • College of Occupational Therapists of Ontario • College of Optometrists of Ontario • College of Physicians and Surgeons of Ontario • College of Physiotherapists of Ontario • College of Psychologists of Ontario • College of Registered Psychotherapists and Registered Mental Health Therapists of Ontario

5.02 Support Persons

Any person with a disability who is accompanied by a Support Person will be allowed to access any services provided by SKPM with his or her Support Person. SKPM will not prevent a person with a disability who is accompanied by a Support Person from having access to his or her Support Person. Where there are barriers to access or attendance by a Support Person, SKPM will seek to facilitate access to ensure the participation of persons with disabilities.

6. Notice of Temporary Disruptions

SKPM is aware that that the operation of its services and facilities is important to its customers and that that persons with disabilities rely on certain services and facilities provided by SKPM. However, temporary disruptions in services and facilities may occur from time to time. SKPM will provide notice when there is a temporary disruption in those services or facilities that persons with disabilities may rely on. This notice will include information about the reason for the disruption, its anticipated duration, and, if applicable, a description of alternative facilities or services that may be available. Notice of service disruptions will be provided as soon as practical after SKPM is aware of the disruption, or in advance in the case of planned disruptions. Notice will be provided by a variety of methods, depending on the circumstances, and may include postings in conspicuous places at the residential complex, in other facilities of the residential complex, on SKPM's website or by any other means that will reasonably ensure that the notice reaches those persons potentially affected by the temporary disruption in a manner that is accessible to them.

7. Training for Staff

SKPM will ensure that all employees, agents and third parties who interact with customers on its behalf receive AODA Customer Service Standard Training. Training shall be provided on an ongoing basis whenever changes are made to this Policy to ensure that this Policy is properly implemented at all times. Training will include the following:

An overview of the purposes of the Accessibility for Ontarians with Disabilities Act, 2005 and the requirements of the Customer Service Standard;
Training on how to interact and communicate with people with various types of disabilities; • Training on how to interact with people with disabilities who use an assistive device or require the assistance of a service animal or a support person;
Training on how to use equipment or assistive devices available at the residential complex or otherwise provided by SKPM that may help with the provision of goods or services to a person with a disability;
Training on what to do if a person with a disability is having difficulty in accessing SKPM's goods and services
Training on SKPM's current policies, practices and procedures relating to the Customer Service Standard. SKPM will keep records of the training provided, including the dates on which training was received and the names and number of participants.

8. Feedback Process

In order to properly assess the needs of persons with disabilities, SKPM has created a feedback process and designated a member of staff as its AODA Compliance Officer.

8.01 Receiving Feedback

Feedback may be provided by a person with a disability in the manner they deem most convenient to them. For example, a person may provide feedback by completing a Customer Feedback Form or by contacting the AODA Compliance Officer in person, by mail, phone, e-mail or by diskette. All feedback will be processed by the AODA Compliance Officer. All feedback will be kept in strict confidence and will be used to improve customer service.

8.02 Responding to Feedback

If the feedback raises serious concerns with respect to the delivery of goods and services to persons with disabilities, SKPM will provide a response to the concerns in a timely manner. The author of the feedback will be provided a response in the format requested (or the most appropriate format where no request was made) outlining actions taken. SKPM shall make best efforts to respond to feedback within five (5) business days.

9. Notice of Availability of Documents

This Policy and any corresponding practices and procedures will be made available to any person on request. SKPM shall post notice of the availability of these documents in a conspicuous place at the residential complex and, if applicable, on the Landlord's website.

10. Format of Documents

Upon request, SKPM shall provide this Policy and other any forms created pursuant to the Customer Service Standard in a format that takes into account the disability of the person submitting the request.

11. Modifications to the Policy and Related Policies

SKPM is committed to developing customer service policies that respect and promote the dignity and independence of people with disabilities. All of the Landlord's policies and procedures will be developed or updated in such a manner as to respect and promote the dignity and independence of persons with disabilities.

12. Additional Obligations

SKPM recognizes that the AODA does not replace or supersede the Residential Tenancies Act, S.O. 2006, c.17 (the "R.T.A.") or the Human Rights Code, R.S.O. 1990, c. H.19 (the "Code").

13. Enquiries

Any Enquiries related to this Policy and any feedback should be directed to our AODA Compliance Officer:

By Email to: privacyofficer@sterlingkaramar.com By Phone: 416-256-4434

By Post: Sterling Karamar Property Management, 53 The Links Road, Toronto, Ontario, M2P 1T7

AODA: Integrated Accessibility Standard Policy

Sterling Karamar Property Management (hereinafter "SKPM") have developed the following AODA Integrated Accessibility Standard Policy (the "IAS Policy") in accordance with the Accessibility for Ontarians with Disabilities Act, 2005, S.O. 2005, c. 11 (the "AODA"), Ontario Regulation 191/11 (the "Integrated Accessibility Standard").

Part I: Commitment to Excellence and Training

14. Commitment to Excellence

15. Integrated Accessibility Standard Policy

This IAS Policy and all of the related procedures and forms are guided by the fundamental principles underlying the AODA: dignity, independence, integration and equal opportunity.

16. Training

All employees, volunteers, agents and third parties who interact with customers on SKPM's behalf shall receive training on the requirements of the Integrated Accessibility Standard, the IAS Policy and the Human Rights Code as it pertains to persons with disabilities. This training shall be provided as soon as practicable.

16.01 Training Shall be Appropriate to Duties The training shall be appropriate to the duties of the employees, volunteers, agents and third parties who interact with customers on SKPM's behalf.
16.02 Additional Training Additional training shall be provided on an ongoing basis whenever changes are made to this IAS Policy to ensure that this IAS Policy is properly implemented at all times.
16.03 Record of Training SKPM will keep records of the training provided, including the dates on which training was received and the names and number of participants.

Part II: Information and Communication

17. Exemptions

Part II of this IAS Policy does not apply to: products and product labels (except as specifically provided); unconvertible information or communications; or information that SKPM does not control directly or indirectly through a contractual relationship.

18. Feedback Process

SKPM has created a feedback process and designated a member of staff as its AODA Compliance Officer to receive and respond to feedback. This feedback process is in addition to the feedback process outlined in the AODA Customer Service Standard Policy.

18.01 Receiving Feedback - Feedback may be provided by a person with a disability in the manner they deem most convenient to them. Feedback may be provided by completing a Customer Feedback Form or by contacting the AODA Compliance Officer in person, by mail, phone, e-mail or by diskette.
18.02 Confidentiality - All feedback will be confidential and will be used to improve the delivery of goods and services, information, communication, the employment of persons with disabilities, and/or the design of public spaces.
18.03 Retention of Feedback Feedback will be kept for a minimum of one (1) year from the date it was provided. After that time, feedback may be kept or destroyed at the sole discretion of the AODA Compliance Officer.
18.04 Responding to Feedback If the AODA Compliance Officer determines that the feedback raises serious concerns, the author of the feedback will be provided a response in the format requested (or the most appropriate format where no request was made) outlining the actions taken or the action that will be taken in the future. SKPM will make best efforts to respond to feedback within three (3) business days.

19. Accessible Formats and Communication

Supports Upon request, SKPM shall provide or arrange for the provision of accessible formats and communication supports for persons with disabilities. SKPM shall consult with the person making the request in determining the suitability of an accessible format or communication support.

19.01 Timing and Cost - SKPM shall provide or arrange for the provision of accessible formats and communication supports in a timely manner that takes into account the person's accessibility needs due to disability. This shall be done at a cost that is no more than the regular cost charged to other persons.
19.02 Notice of Availability of Accessible Formats and Communication - Supports SKPM shall post notice of the availability of accessible formats and communication supports in a conspicuous place at the office and on SKPM's website.

20. Emergency Procedure or Public Safety Information

Generally, SKPM does not make emergency procedures, plans or public safety information available to the public. Where this information is made available to the public, as soon as practicable after a request is made, SKPM shall provide that information in an accessible format or with appropriate communication supports.

Part III: Employment

21. Commitment to Excellence in the Workplace

SKPM strives for excellence in the workplace. As part of our efforts to achieve this goal, we are committed to identifying, removing and preventing barriers that interfere with current or prospective employees with disabilities from participating in the employment experience. Unfortunately, it is not always possible to determine whether someone requires accommodation – let alone the best path to provide the right support. Accordingly, we take this opportunity to advise that we will work with current and prospective employees to accommodate disability-related needs that impact their employment. All you need to do is ask and we will work with you to determine the right way to ensure accommodation. We remind you to review our websites and employee login portal (where applicable) for more information about our processes and policies, including those around accommodating persons with disabilities.

21.01 Recruitment, Assessment or Selection Process - SKPM welcomes and encourages applications from people with disabilities. Accommodations are available on request for candidates taking part in all aspects of the selection process. SKPM's recruitment process is designed to be fully accessible and SKPM accepts applications from all qualified individuals. SKPM shall notify its employees and the public, via SKPM's website, about the availability of accommodation for applicants with disabilities in its recruitment process. Accommodation during the recruitment process may include, but is not limited to, providing and receiving information and documents in accessible formats (i.e. fax, e-mail or in person) and the use of assistive devices and/or service animals.
21.02 Notification of Selected Applicants - When an applicant is individually selected to participate in an assessment or in a selection process, SKPM shall notify all selected applicants that accommodations are available upon request in relation to the materials or processes to be used.
21.03 Accommodating Selected Applicants - Where a selected applicant requests an accommodation during the recruitment process, SKPM shall consult with the selected applicant and shall provide or arrange for the provision or a suitable accommodation in a manner that takes into account the applicant's accessibility needs due to disability.
21.04 Informing Successful Applicants - When making offers of employment, SKPM shall notify the successful applicant about its policies for accommodating employees with disabilities.
21.05 Informing New Employees of Supports - As soon as practicable after they begin their employment, SKPM shall advise new 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 disability.
21.06 Obligation to Provide Updated Information - SKPM shall provide updated information to its employees when there is a change to its accommodations policies.

22. Accessible Formats and Communication Supports for Employees

In addition to any other obligation under this IAS Policy, upon request SKPM shall provide or arrange for the provision of accessible formats and communication supports for: (a) Information that is needed to perform the employee's job; and (b) Information that is generally available to employees in the workplace. SKPM shall consult with the employee making the request in determining the suitability of an accessible format or communication support

23. Workplace Emergency Response Information

SKPM has in place a written process for the provision of workplace emergency response information to employees with disabilities who require them. This process is documented in the Fire Safety Plan.

24. Performance Management and Career Development

When using its performance management process in respect of employees with disabilities, SKPM shall take into account the accessibility needs of employees with disabilities and individual accommodation plans.

25. Career Development and Advancement

SKPM shall take into account the accessibility needs of its employees with disabilities as well as any individual accommodation plans, when providing career development and advancement to its employees with disabilities.

26. Redeployment

If SKPM reassigns an employees with a disability to another department or job within the organization as an alternative to layoff (when a particular job or department has been eliminated), SKPM shall take into account the accessibility needs of its employees with disabilities, as well as individual accommodation plans.

Part IV: Design of Public Spaces

27. Design of Public Spaces

Where SKPM engages in construction or reconstruction of regulated public spaces, such construction or reconstruction shall comply with the requirements of the Integrated Accessibility Standard.

27.01 Definition of Public Spaces - Public spaces include: recreational trails/beach access routes; outdoor public eating areas; outdoor play spaces; outdoor paths of travel; accessible off street parking; and service-related elements (i.e. service counters, fixed queuing lines and waiting areas).
27.02 Disruption - SKPM will endeavour to prevent or minimize service disruptions to the accessible parts of its public spaces. In the event of a service disruption, SKPM will notify the public of the service disruption and alternatives available.
27.03 Maintenance - SKPM shall specifically consider procedures for preventative and emergency maintenance of the accessible elements in public spaces to minimize the disruption in access to the accessible parts of its public spaces.
27.04 Effective Date - This section of the IAS Policy becomes effective on January 1, 2018. Part V: General 28. Effective Date Except where otherwise indicated, this IAS Policy becomes effective on January 1, 2017. 29. Additional Obligations SKPM recognizes that the AODA does not replace or supersede the Human Rights Code, R.S.O. 1990, c. H.19, or other laws relating to the accommodation of persons with disabilities.

Part V: General

28. Effective Date

Except where otherwise indicated, this IAS Policy becomes effective on January 1, 2017.

29. Additional Obligations

SKPM recognizes that the AODA does not replace or supersede the Human Rights Code, R.S.O. 1990, c. H.19, or other laws relating to the accommodation of persons with disabilities.

30. Enquiries

Any Enquiries related to this IAS Policy and any feedback should be directed to our AODA Compliance Officer:

By Email to: privacyofficer@sterlingkaramar.com

By Phone: 416-256-4434