Employment Standards for Persons with Disabilities

Category	HR & Employment
Policy Number	409
Name	Employment Standards for Persons with Disabilities
Authorized by & date	Executive Director, December 16, 2015
Revisions & date

Context & Rationale

The Press is committed to diversity, inclusion and accessibility for persons with disabilities. This policy describes how the Press works with its employees as well as how it provides its programs, goods and services in a manner that respects the dignity, independence, integration and equal opportunity of persons with disabilities.

Policy Statement

Assistive devices

The Press permits persons with disabilities to use their personal assistive devices while on its premises.

Service animals and support persons

The Press welcomes onto its premises service animals and support persons upon whom persons with disabilities rely. The Press will advise the parties as soon as possible about any costs they will incur associated with having the support person.

Notice of temporary disruption

The Press will notify persons with disabilities promptly in the event of a planned or unexpected disruption to services or facilities. This notice will be provided in accessible formats and posted in public areas.

Recruitment & Selection

During the hiring process, candidates will be notified through the Press' job advertisements and postings that accommodation for disabilities will be provided upon request.

If a selected candidate requests an accommodation, the hiring manager and Talent Management Director will make adjustments in the hiring process to support the person with a disability.

When making offers of employment, the Press will notify the successful candidate of its policies for accommodating employees with disabilities.

As part of the onboarding process, all newly hired employees will be informed of the Press' accessibility policies.

Informing employees of supports

Employees will be informed about the Press' accessibility policies during the onboarding process and will be informed of any additions or changes to relevant policies via:

• E-mail communication
• Townhall meetings
• Posted memos
• One-on-one communication
• Employee policy handbook

Communication

The Press is committed to communicating with persons with disabilities in ways that take their disability into account. Upon request, an employee with a disability will be provided with accessible workplace information, including:

• Any information that employees need to perform their jobs
• General information that is available to all employees, including company newsletters, bulletins about PTP's policies and health and safety information
• Information about emergency procedures

Performance management

The needs of employees with disabilities will be taken into account during both formal and informal performance management and reviews. The format of documentation, feedback, coaching and training will take into account the employee's accessibility needs.

Career development and advancement

The Press will accommodate the needs of an employee with a disability so that they are not excluded from the opportunity to advance or develop their career.

Training of employees

The Press will provide training to all of its employees and volunteers regarding its accessibility policies and provision of accommodations to ensure accessible programs, goods, services and workplace.

Training will occur on an ongoing basis and whenever changes are made to relevant policies, practices and procedures.

Promotions or Re-deployment

The needs of employees with disabilities will be taken into account during the onboarding and training stages of promotions or re-deployments. Further accommodations will be made upon the request of the employee.

Individualized emergency response information

The Press will provide employees with disabilities with available emergency response information in an accessible format upon request, as well as work with the employee to create an emergency response plan that accommodates their needs, should an emergency arise.

The Press will regularly request that employees identify themselves to the Talent Management Director if they would like accommodation in an emergency situation. This information will be shared with the people designated to help them in an emergency, upon the employee's consent.

This plan will be reviewed if the employee changes work locations, the employee's overall accommodation needs change, or the Press' emergency response policies or procedures change.

Individual accommodation plans

The Press' process for developing individual accommodation plans for employees with disabilities includes the following:

• Details on how an employee is assessed and participates on an individual basis
• Information on how a unionized employee (if applicable) can ask for a representative from their bargaining agent to participate in the development of the accommodation plan
• Information on how a non-unionized employee can ask for a representative from the workplace to participate in the development of the accommodation plan
• Confirmation of the availability of assistance from outside experts, if deemed necessary
• Details of the steps the Press will take to protect the privacy of the employee's personal information
• Information on how and when the Press will provide the employee with their personalized accommodation plan
• The schedule for when and how the plan will be reviewed and updated
• Details of how the Press will inform an employee that their individual accommodation plan has not been accepted
• How the Press will provide the employee’s plan in an accessible format, if needed
• Individualized workplace emergency response information, as required

The Press will consult with the employee requesting accommodation in determining and implementing appropriate accommodation measures. The final decision on accommodation, however, rests with the Press.

Return to work process

Where it has been determined that an employee with a disability needs accommodation to return to work from an absence due to disability, the Talent Management Director will work with the employee and their manager to plan a reasonable accommodation and return to work. Employees are expected to follow treatment and rehabilitation recommendations made by attending health professionals as part of the accommodation plan, and accept reasonable offers of accommodation.

Accommodation options must be considered in the following order:

• Implementing changes to the physical work environment or equipment and/or modifying how and when tasks are performed to enable the employee to remain in their substantive position (job modifications)
• Modifying the employee's job duties in a manner consistent with their individual capabilities in order for the employee to perform the essential tasks of their substantive position (modified duties)
• Exploring other available job opportunities within the employee's department in which they would be capable of performing the essential tasks of the position, with or without modifications
• Exploring available job opportunities in other departments in which the employee would be capable of performing the essential tasks of the position, with or without modifications.

Limitations on Duty to Accommodate

The Press' responsibility to make reasonable accommodations to meet the needs of employees' with disabilities will be fulfilled up to the point of undue hardship as defined in the Ontario Human Rights Act. The criteria for determining undue hardship under the Act include, but are not limited to, such factors as:

• Safety risks that may impact the employee, or other employees or the public
• Disruption to the public
• Effect on contractual obligations (e.g. collective agreements)
• Financial cost
• Business efficiency

Bona Fide Occupational Requirement

The duty to accommodate is also limited where a bona fide occupational requirement (something that is necessary in order to accomplish the essential duties of the job) cannot be met because of the proposed accommodation. A bona fide occupational requirement is one that is:

• Adopted for a purpose connected to the performance of the essential duties of the job
• Adopted in an honest and good faith belief that the requirement is necessary to fulfill the essential duties of the job
• Necessary to the accomplishment of the essential duties of the job

Where Return to Work or Accommodation is Not Possible

At times, despite best efforts to provide a reasonable accommodation, because of the employee's identified restrictions and limitations an accommodation placement is not possible. In these cases, the employee's manager and the Talent Management Director should consult the appropriate experts regarding the options for both the employee and the Press (e.g. medical retirement, termination of the employment relationship, etc.).