Superior Propane Accessibility Policies
Last Updated: January 31, 2023
The purpose of this document is to affirm the commitment of Superior Propane, a division of Superior Plus LP (“Superior Propane”) to meeting the diverse needs of people with Disabilities and to set forth our multi-year accessibility plan for compliance with the requirements of the Integrated Accessibility Standards (the “IAS”) under the Accessibility for Ontarians with Disabilities Act, 2005 (“AODA”), The Accessibility for Manitobans Act, and other applicable accessibility laws. The Plan also incorporates and references to Superior Propane’s existing accessibility policies and practices, where applicable.
These policies apply to all staff of Superior Propane.
C. MULTI-YEAR ACCESSIBILITY PLAN
This Multi-Year Accessibility Plan (the “Plan”) outlines the policies, practices and actions that Superior Propane (together with its affiliates, collectively the “Company”) have or will implement in its Ontario operations to improve accessibility for individuals with disabilities. The Plan also incorporates and references the Company’s existing accessibility policies and practices, where applicable.
1. Statement of Commitment
Superior Propane is committed to meeting the diverse needs of people with Disabilities in a timely manner that is consistent with the principles of independence, dignity, integration and equality of opportunity, and will do so by striving to identify, prevent and remove Barriers to accessibility wherever possible. Superior Propane is also committed to ensure compliance with the accessibility requirements under the AODA. The Vice President of Human Resources for Superior Propane will be responsible for ensuring the Company implements the obligations contained in this Plan in accordance with this Statement of Commitment.
2. Customer Service
Superior Plus maintains an Accessible Customer Service Policy, as well as appropriate feedback mechanisms with respect to that policy. Superior Plus will continue to comply with this policy and will review it from time to time to implement any required changes in order to promote accessibility within our customer service operations.
Superior Plus will put procedures in place to prevent/notify the public of service disruptions to the accessible parts of its public spaces, if and as applicable.
3. Accessible Emergency Information
Wherever Superior Propane prepares emergency procedures, plans or public safety information and makes the information available to the public, we are committed to providing the information in an accessible format or with appropriate communication supports as soon as practicable upon request.
Superior Propane will ensure that all employees and volunteers in Ontario, and any other persons who provide goods, services or facilities to the public or other third parties in Ontario on behalf of Superior Propane or who participate in developing Superior Propane’s policies on the provision of goods, services or facilities to the public or other third parties in Ontario, will receive training on the requirements of the IAS and on the Ontario Human Rights Code as it pertains to persons with Disabilities.
Training will be provided in a manner that is appropriate to the duties of the employees, volunteers and other persons, and will be provided as soon as practicable after staff or volunteers commence their duties and on an ongoing basis with respect to any changes to this policy.
Superior Propane will maintain a record of the training it provides to staff and volunteers, including the dates on which the training is provided and the number of individuals to whom it is provided.
Superior Propane understands that AODA requires it to consider the needs of people with Disabilities when designing, procuring or acquiring self-service kiosks. To the extent that Superior Propane engages in such activities in the future, the Company will implement a policy and/or practice to ensure that accessibility issues are considered.
6. Information and Communications
Superior Propane is committed to meeting the communication needs of individuals with Disabilities. Superior Propane will consult with such individuals to determine their information and communication needs and will provide information and communications in accessible formats and with communication supports in a timely manner (and at a cost that is no more than any regular cost) in accordance with the requirements of AODA.
Superior Propane’s website meets the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0 Level AA (with certain exceptions as permitted by AODA).
Superior Propane is committed to accessible employment practices and to removing any barriers that prevent or hinder the career development of employees with disabilities at the Company.
We will provide employees with disabilities with individualized emergency response information where necessary, in accordance with AODA. Superior Propane will take steps to determine whether employees require individualized emergency response information on an ongoing basis as part of our human resources and occupational health and safety functions.
In accordance with AODA, Superior Propane takes steps to: notify the public and staff that Superior Propane accommodates people with disabilities during the recruitment and selection process as well as during the course of employment; provide employees with employment-related information in accessible formats and with communication supports if and as needed; develop individual accommodation and return-to-work policies and plans as required by AODA; and ensure the accessibility needs of employees with disabilities are taken into account in Superior Propane’s performance management, career development and redeployment processes.
8. Design of Public Spaces
Superior Propane will meet its accessibility obligations in respect of the design of public spaces when building or making major modifications to public spaces, including service counters, fixed queuing lines and waiting areas, if and as applicable.
9. Compliance Strategy
Superior Propane believes that our staff and customers are our best resources for assisting us to identify, prevent and remove barriers to accessibility and thereby ensure that the diverse needs of people with disabilities are met or exceeded.
For various reasons, barriers to accessibility can often be difficult to identify. Our staff and customers, including in particular those persons with disabilities, are often in the best position to recognize the existence of any accessibility Barriers and their impact on people with disabilities, and to alert Superior Propane so that we can take appropriate action to prevent or remove the Barriers wherever reasonably possible.
Accordingly, Superior Propane will take the following steps to facilitate the identification, prevention and removal of accessibility barriers wherever it is reasonably possible to do so:
- in order to promote an understanding of and appreciation for the accessibility requirements under the IASR, as well as the importance of identifying, preventing and removing Barriers to accessibility, Superior Propane will ensure that all staff in Ontario are provided with a copy of this policy and are encouraged to review the policy and to raise any questions that they may have regarding the policy with our Legal Department;
- Superior Propane will encourage, welcome and appreciate all feedback from staff and customers regarding any Barriers to accessibility and more generally on how we can best achieve our goal of striving towards a Barrier‐free environment;
- Superior Propane will take a proactive approach to accessibility wherever reasonably possible by striving to have regard to and incorporating disability‐related needs and accessibility issues in general in all aspects of our business and decision‐making; and
- Superior Propane will strive to work cooperatively and consult with any person with a Disability who brings to our attention an issue or concern regarding accessibility, and we will take all reasonable steps in the circumstances to address the disability‐related needs of the individual
10. Modification of the Plan
This Plan will be reviewed and updated by the Company at least every 5 years. At the time of revision, information regarding accessibility policies and practices adopted by the Company in accordance with the Plan or otherwise will be included in the revised Plan.
11. Questions about this Plan
All questions regarding this plan should be referred to Superior Propane’s Legal Department. Please contact the Vice President of Human Resources for Superior Propane, Graham Fisher (email@example.com). Accessible formats of this document will be provided upon request.
D. ACCOMMODATION AND RETURN TO WORK POLICY
This policy sets out the process by which Superior Propane (the “Company”) will (a) respond to requests for accommodation and develop individual accommodation plans, and (b) facilitate employees’ return to work following absences due to disabilities. The aim of the policy is to remove barriers to participation in the workplace. All accommodation and return to work requests will be taken seriously and dealt with in accordance with this policy, as promptly as possible in light of individual circumstances. No employee will be penalized for making an accommodation request and/or seeking to return to work following a disability leave of absence.
Employees should request accommodation by contacting their direct manager or Human Resources. Requests for accommodation should, wherever possible, be made in writing and include the ground with respect to which accommodation is being requested (e.g., disability), the limitations of the employee having regard to their job duties, and any other information relevant to the Company’s assessment of the accommodation request and requirements.
The Company may request additional information as necessary, such as information from the employee’s doctor outlining his/her functional limitations. In certain circumstances, including where medical or other information provided by the employee is inconsistent or inconclusive, the Company may request that the employee be evaluated by a third party medical or other expert to assist the Company in determining if and how accommodation can be achieved. Any such evaluation will be at the Company’s expense. Employees must participate in the accommodation process in accordance with applicable laws.
In appropriate circumstances, the Company will permit a medically-required support person to participate in the accommodation process. However, in most cases, it is expected that the employee will not be represented during the accommodation process.
Any information collected in relation to an accommodation request or the implementation of an individual accommodation plan will be shared only with a person who needs the information, and shall be subject in all cases to the Company’s privacy policies and procedures.
If the Company ultimately determines that accommodation is not required, the Company will advise the employee of its decision and the reasons for that decision, in writing, as soon as practicable.
If the Company determines that accommodation is required, the employee will be provided with an individual accommodation plan. Individual accommodation plans will be provided to employees in a format that takes into account the employee’s accessibility needs, where required. To the extent that an individual’s disability requires the use of a prescribed drug (including but not limited to medicinal marijuana) the individual accommodation plan may include a use and dosage schedule to ensure that the employee is not impaired at work and is able to perform their works duties in a safe and responsible manner.
The frequency with which individual accommodation plans will be reviewed and updated will be as stated in the plan and determined with respect to individual circumstances, although it is expected that accommodation plans will be reviewed at least every three to six months. Human Resources will generally be responsible for reviewing and updating individual accommodation plans, in coordination with the employee and their manager in appropriate circumstances. The review of an individual accommodation plan may result in the employee being required to provide updated medical or other documentation substantiating the continued need for accommodation.
2. Return to Work
The Company will maintain contact with an employee on a disability leave of absence (and request updated medical information from the employee) as is appropriate in the circumstances. In determining the level of contact and requests for medical information that are appropriate in the circumstances, the Company will have regard to any related processes administered by a disability insurance provider.
Employees should advise their Manager and disability Case Manager promptly when the employee is able to return to work, with or without accommodation. The Company will typically require the employee to provide medical information substantiating their ability to perform the essential duties of their position (with or without accommodation) prior to determining the employee’s return to work date.
In determining the return to work date, and in order to facilitate the employee’s reintegration into the workplace, the Company will consider and document, as applicable, any changes to job duties, reporting relationships or compensation/benefits, as well as any training needs. Any such changes or training needs will be documented in writing and required training will be completed as soon as practicable following the employee’s return to work. It is expected that the employee will meet with their direct manager on or shortly following the return to work date to discuss any issues or concerns relating to the employee’s return to work.
Any requests or needs for accommodation following the employee’s return to work will be addressed pursuant to the accommodation process set out above. Individual accommodation plans will be used as necessary.
Should you have any questions regarding this policy, please contact Human Resources at firstname.lastname@example.org.
E. ACCESSIBLE CUSTOMER SERVICE POLICY
Superior Propane (the “Company”) is committed to ensuring that our goods and services are provided to our customers with disabilities in an accessible manner. We understand the importance of treating individuals with disabilities in a way that respects their dignity and independence. This policy establishes the Company’s policies, practices and procedures relating to its provision of accessible customer service. All other Company policies will be interpreted and applied in a manner consistent with the requirements and intent of the policy.
1. Accessible Communications
The Company will communicate with individuals with disabilities in a manner that takes into account their disabilities. In determining the appropriate method and form of communication, the Company will take into account accessibility needs resulting from disabilities. The Company encourages individuals we communicate with to identify any accessibility needs so that we can respond appropriately to those needs.
2. Service Animals
The Company welcomes individuals with disabilities who use service animals. Service animals are allowed on any parts of our premises that are open to the public or other third parties, in accordance with applicable laws. Additional information related to our service animal policies is available upon request.
3. Support Persons
Customers, customer representatives and others with disabilities who require the assistance of a support person will be allowed to have that support person accompany them when interacting the Company. Additional information related to our support persons policies is available upon request.
4. Assistive Devices
Individuals with disabilities may use their own assistive devices to access goods and services provided by the Company. To the extent required, the Company will ensure that our staff members are trained and familiar with various assistive devices that may be used by individuals when accessing our goods and services. Additional information related to our assistive devices policies is available upon request.
5. Notice of Temporary Disruptions
In the event of a planned or unexpected disruption to services or facilities that may be used by individuals with disabilities to access goods or services, the Company will notify individuals of the disruption promptly. The notice will advise individuals regarding the reason for the disruption, its anticipated duration, and provide a description of alternative services or facilities available, if any. The notice will be posted and/or communicated to individuals with disabilities in a manner that is reasonable in the circumstances. Additional information related to our temporary disruptions policies is available upon request.
6. Training of Staff
The Company is committed to ensuring that our staff members are able to effectively respond to accessibility needs. The Company will provide training to staff members, including volunteers, regarding accessible customer service in accordance with applicable laws as soon is practicable and on an ongoing basis. This training includes instructions related to how to interact and communicate with persons with various types of disabilities, how to interact with persons with disabilities who use an assistive device or require the assistance of a guide dog or other service animal or the assistance of a support person, how to use equipment or devices available on the provider’s premises or otherwise provided by the provider that may help with the provision of goods, services or facilities to a person with a disability, and what to do if a person with a particular type of disability is having difficulty accessing the provider’s goods, services or facilities. The Company will keep appropriate records in respect of this training. Additional information related to our staff training policies is available upon request.
7. Feedback Process
The Company understands the importance of listening to our customers’ concerns and responding appropriately to customer feedback, including about the feedback process itself. Feedback can be provided in person at or by mail to Alex Wozniak, Director of Customer Enablement, at 6750 Century Avenue, Suite 400, Mississauga, ON L5N 2V8or by email at email@example.com or telephone at (905) 542-5484. Individuals can generally expect a response or preliminary response to their feedback within 15 business days of receipt by the Company of the feedback, if the nature of the feedback requires a response. The Company will take such steps as are necessary in the circumstances to rectify any issues or concerns raised in a manner consistent with the policy. Such steps may include requesting additional information from the individual providing the feedback, investigating specific complaints and/or providing documentation or communications in accessible formats. The Company will advise the individual providing the feedback of the results of the feedback review process as appropriate in the circumstances.
Any other feedback policies or process maintained by the Company will be interpreted in a manner consistent with this policy. Additional information on our feedback policies is available upon request.
The Company will provide a copy of the policy to individuals requesting it, in an accessible format if required.