Accessibility Plan 2023 – 2026
Intent
Tenold
Transportation Ltd. (the “Company”) is committed to providing a
barrier-free environment for all stakeholders, including customers, employees,
job applicants, suppliers, and any visitors who enter the premises, access
information provided by the Company, or use the Company’s services.
The Company will
work to identify and remove barriers, and prevent new barriers, for persons
with disabilities as they relate to employment, communication, the built
environment, and transportation at the Company. This plan outlines the
Company’s Accessibility Plan and strategy for identifying, removing, and
preventing these barriers.
The Company is
part of a network of wholly-owned companies and limited partnerships that are
subsidiaries of Mullen Group Ltd. (“Mullen Group”). Mullen Group’s
corporate office (“Corporate Office”) provides the Company certain
services and will assist with the development and implementation of the
Accessibility Plan on an ongoing basis.
Definitions
Barrier: Anything
physical, architectural, technological, or attitudinal, anything that is based
on information or communications, or anything that is the result of a policy or
a practice that hinders the full and equal participation in society of a person
with an impairment, including a physical, mental, intellectual, cognitive,
learning, communication, or sensory impairment, or a functional limitation.
Disability: Any
impairment, including a physical, mental, intellectual, cognitive, learning,
communication, and sensory impairment, or functional limitation that is either
permanent, temporary, or episodic in nature. It can be evident or not in
interaction with a barrier to hinder a person’s full and equal participation in
society.
Accessibility
Plan: This Accessibility Plan includes an overview of our policies, programs,
practices, and services in relation to the identification and removal of
barriers and the prevention of new barriers. The Accessibility Plan was
prepared and published by June 1, 2023, and will be updated every three years
following that, or sooner if necessary.
The Accessibility
Plan was developed in consultation with persons with disabilities and indicates
how they were consulted. This process is followed for the creation of and any
updates to the plan. The Company adheres to all requirements made by regulation
in the development and ongoing maintenance of the Accessibility Plan.
General
This information
is provided for the purposes of providing feedback and for requesting
alternative formats of the plan and/or feedback process.
Feedback Process and Contact Information
The Company
welcomes feedback regarding the manner in which it is implementing its
Accessibility Plan and any barriers encountered by persons with disabilities.
Persons who provide formal feedback will receive acknowledgement of their
feedback in the same manner in which it was received, unless feedback is
submitted anonymously. The Company is committed to reviewing the feedback
received in good faith and taking steps to address barriers identified in this
feedback.
Feedback can be
submitted in person, by mail, by telephone and by email to:
Director of Human
Resources
604-881-7822
30691 Simpson Road, Abbotsford, British Columbia, V2T 6C7
hr@tenold.com
Feedback can be
provided anonymously, if desired, and will remain confidential unless the
person consents to the disclosure of their personal information. Feedback is
received in whatever format the individual providing the feedback is most
comfortable with. Any feedback received will be reviewed with the Company’s
Business Unit Leader, and provided to Corporate Office. Consideration will be
given to the feedback upon review by the representative collecting feedback,
the Company’s Business Unit Leader and Corporate Office and a response or
summary will be included in the next progress report.
Any changes to
the Accessibility Plan or the feedback process are published as soon as
reasonably possible and notice of any changes are reported to the Accessibility
Commissioner. The personal information of anyone who provides feedback remains
confidential in accordance with all applicable privacy laws.
Alternative Formats
The Accessibility
Plan is offered in any of the following formats upon request:
Print;
Large print;
Braille;
Audio; and
Electronic.
You can request
alternative formats of the Accessibility Plan by contacting:
Director of Human
Resources
604-881-7822
30691 Simpson Road, Abbotsford, British Columbia, V2T 6C7
hr@tenold.com
The Accessibility
Plan will be made available as soon as feasible. In the instance of a request
for the plan in a Braille or audio format, it will be provided 45 days after
the day the request was received. Requests for other formats will be provided
within 15 days after the day the request was received.
i. Employment
The Company
understands that improving workplace accessibility and ensuring an accessible
recruitment and selection process for applicants with disabilities can
contribute to a more diverse and welcoming workplace culture. The Company
reviews its practices and procedures to identify, remove, and prevent barriers
by developing inclusive employment procedures that support persons with
disabilities. Where necessary, accommodations are made during the recruitment
and selection stages, and throughout the employment lifecycle. Technological
and systemic barriers may exist for employee orientation and training, as such,
training and development programs provided by the Company should be reviewed to
consider an employee’s barriers and abilities. Systemic barriers can be
identified with respect to conventions associated with the hiring process.
·
The Company will
review current job application processes for persons with disabilities who
experience barriers, and evaluate potential alternatives.
·
Review corporate
policies, with the support of Corporate Office, that pertain to accommodations
for employees and candidates with disabilities and make plans to remove any
barriers that are discovered.
·
Train those
responsible for hiring on the barriers that may exist in the hiring, selection
and accommodation process, with support from Corporate Office.
·
Review human resource
policies for improvements with respect to inclusion and accessibility, with
support from Corporate Office.
·
Provide online
learning on accessibility and inclusiveness to employees.
·
Offer training on
unconscious bias to human resources employees to improve awareness of
accessibility issues.
·
Review potential
opportunities, where suitable, for establishing mentorship for employees of the
Company that are persons with disabilities.
ii. The Built Environment
The Company
wishes to improve its publicly accessible facilities with a goal of working
towards making such facilities free of physical barriers, in order to promote a
space of inclusivity. Physical barriers may exist in the Company’s offices and
facilities, that can be improved upon.
·
With support from
Corporate Office, the Company will evaluate its offices and facilities to
assess the need for further accessibility features.
·
The Company will
review and update, as necessary, its emergency and disaster response plans to
account for employees, and visitors with disabilities.
·
Evaluate facilities to
verify that smoke, fire and other emergency alarms have visual and auditory
signals, and assess if improvements are required.
·
Review Company
workspaces, and customer facing facility areas to identify any physical
barriers, by the end of 2025 and plan improvements.
iii. Information and Communication Technologies (ICT)
Software with
accessibility functionality is already utilized by the Company; however, the
Company recognizes that systemic barriers exist within technology and
presumptions made about its use. The Company wishes to remove barriers and
improve accessibility for employees with disabilities, by making such
technology more accessible.
·
Add accessibility as
an evaluation metric when acquiring or developing new software or technology,
with support from Corporate Office.Review website content for any minor
barriers, including assessing the following:
Text contrast;
Text size;
Navigation and compatibility with screen readers; and
Clear formatting.
·
Provide guidance and
support on the accessibility features of utilized software with existing
accessibility features.
iv. Communication other than ICT
The Company
acknowledges that content and medium are both important in providing accessible
communication to its customers, employees, job applicants, suppliers, and any
visitors that access the premises. Communication barriers exist in the content
and format of online information, in-person interactions and meetings and
presentations. One of the Company’s goals is to work towards providing more
accessible communications.
·
Provide training on
accessibility and barriers for employees who work on communications, including
information on potential different communication styles.
·
Evaluate website,
social media posts, meetings and presentation conventions and practices to
create a plan to address barriers to accessibility if discovered, including
assessing the following:
Adding
alternative text for images;
Using high contrast font; and
Providing transcripts of audio and video posts, where appropriate.
·
Review virtual meeting
practices for accessibility, including the provision of presentations and real
time transcripts, and considering alternative means of communication.
·
Review orientation
processes and resources for new employees for improvements to accessibility,
with the support of Corporate Office.
v. Procurement of Goods, Services and Facilities
Procurement
practices have the potential to be subject to unconscious bias and systemic
barriers. It is the Company’s goal to consider accessibility in its procurement
processes, where possible.
·
Review procurement
practices and improve, where reasonable and applicable, to consider
accessibility in the purchase of goods, services and the use or purchase of
facilities.
vi. Design and Delivery of Programs and Services
The Company’s
primary customers are other businesses, and as such, evaluating the design and
delivery of programs and services to the public is not applicable. The Company
considers the design and delivery of programs and services as it might apply to
its employees and customers.
·
Review the
accessibility of design and delivery of programs and services with respect to
employees and customers with disabilities.
vii. Transportation
The Company’s
business may provide transportation, logistics services, and/or specialized and
industrial services, it does not provide passenger transportation services. As
such, barriers to the public and passenger-based services are not considered.
The Company’s focus is on continually evaluating potential barriers that exist
for employees and candidates. Such barriers might include, physical barriers,
like ramps, curbs, vehicle and equipment design or lack of vehicle and
equipment adaptability. The Company will work towards reducing barriers for
employees with disabilities to the extent reasonable, pursuant to applicable
occupational health and safety legislation, and other relevant legislation.
·
Assess the
accommodations available for vehicles and equipment that would be compliant
with the Company’s occupational health and safety, and other relevant
legislative, contractual and other obligations for opportunities for safe
implementation.
Consultation
The Company
understands that collaborating with persons with disabilities is an important
factor in developing an Accessibility Plan. Mullen Group consulted with the
Foothills Advocacy in Motion Society (“FAIM”) on behalf of its
federally regulated subsidiaries in the development of this Accessibility Plan
(the “Consultation”). The Consultation process was two-fold and
included:
a) a review
completed by FAIM of a draft of the Accessibility Plan; and
b) several in
person conversations with persons with disabilities facilitated by FAIM
The first facet
of the Consultation consisted of FAIM reviewing and providing feedback on a
draft of the Accessibility Plan, prior to the in-person portion of the
Consultation. The second facet of the Consultation included in-person
discussions that were facilitated by a staff member of FAIM. These discussions
posed questions and asked for input regarding the barriers faced by persons
with disabilities, including, physical, attitudinal, technological and
communication barriers. These conversations also asked for input on
recommendations for improving policies and procedures to support persons with
disabilities, and for recommendations on the inclusiveness and accessibility of
events and activities.
Progress Reports
The Company
prepares, publishes, and submits a progress report to the Accessibility
Commissioner regarding the implementation of the Accessibility Plan each year
the plan is not required to be updated. This report follows a similar structure
to the Accessibility Plan and includes feedback and contact information,
information about the consultations completed for the development of the plan,
and any good faith feedback received on the Accessibility Plan. The report
addresses how the consultations and feedback were taken into consideration
during the process. Progress reports can be made available upon request and are
available in all accessible formats the Accessibility Plan is available in.
Document Retention
The Company keeps
detailed records of the creation, implementation, and updating of the
Accessibility Plan and progress reports. The Accessibility Plan and feedback
process are retained (//tenold.com/) for seven years from the publication date.
Any feedback provided to the company is retained for seven years from the date
it is received. Where necessary, names and personal information of individuals
and employees who participated in the feedback process are redacted to ensure
confidentiality and privacy. The Company will not retain contact information
for any anonymously provided feedback.
