MULTI-YEAR ACCESSIBILITY PLAN 2025 – 2028

Statement of Commitment

Odyssey Medical is committed to upholding and exceeding Ontario’s legislation intended to remove barriers to accessibility for persons with disabilities. This includes providing equal access to employment, information, goods, and services, and treating persons with disabilities with dignity and respect in a way that takes their disability into account.

Definitions

Definitions taken from the Accessibility for Ontarians with Disabilities Act, S.O. 2005, C. 11 or Ontario Human Rights Code.

“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.

“Barrier” means anything that prevents a person with a disability from fully participating in all aspects of society because of their disability, including a physical barrier, an architectural barrier, an information or communications barrier, an attitudinal barrier, a technological barrier, a policy, or a practice; (“obstacle”).

“Disability” is defined broadly by the Ontario Human Rights Code as:

“any degree of physical disability, infirmity, malformation or disfigurement that is caused by bodily injury, birth defect or illness and, without limiting the generality of the foregoing, includes diabetes mellitus, epilepsy, a brain injury, any degree of paralysis, amputation, lack of physical coordination, blindness or visual impediment, deafness or hearing impediment, muteness or speech impediment, or physical reliance on a guide dog or other animal or on a wheelchair or other remedial appliance or device,
a condition of mental impairment or a developmental disability,
a learning disability, or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language,
a mental disorder, or
an injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997.”

Policy

Odyssey Medical will make every reasonable effort to meet the requirements of the Accessibility for Ontarians with Disabilities Act (AODA), 2005, including all applicable elements of the Integrated Accessibility Standards.

Information and Communication
Employment
Customer Service
Design of Public Spaces
Transportation

Odyssey Medical will provide training to all employees, volunteers, and independent contractors to ensure they are familiar with our policies, practices, and procedures for communicating with and providing services to persons with disabilities.

Information and Communication

Odyssey Medical will make its information accessible to people with disabilities by creating materials in accessible formats, and it will notify the public of the types of accessible formats provided.

Further, Odyssey Medical will deliver alternate formats of information to clients upon request. If a particular material cannot be converted into an accessible format that meets the needs of the person requesting it, Odyssey Medical will provide details of why it cannot be converted and provide a summary of the information or communication in another way that is suitable to the person requesting it.

This extends to any emergency procedures or safety information prepared by Odyssey Medical.

Employment

Odyssey Medical welcomes and encourages employment applications from people with disabilities and will do its part to make hiring and employee support practices more accessible by providing accommodation during all stages of recruitment, hiring, and employment.

If a job applicant requests an accommodation, Odyssey Medical will consult with the applicant and provide suitable accommodation that takes the person’s needs into account, when/where possible.

When making offers of employment, Odyssey Medical will notify the successful applicant of its policies for accommodating employees with disabilities.

New employees will be reminded about the organization’s job accommodation policies as soon as possible upon being hired and notified when any future changes are made to policies. Policy and practice information will include available employment accommodations that will be provided for job-related matters such as performance management, career development, emergency response plans, and return to work information.

Odyssey Medical will consult with an employee who requests it, to provide or arrange for the provision of accessible formats and communication tools that take the employee’s needs into account when providing information that is needed to perform the employee’s job, and information that is generally available to employees in the workplace.

Customer Service

Odyssey Medical will provide customer service in a manner that removes barriers for people with disabilities according to the following key principles of the AODA:

Goods and services will be provided in a manner that respects the dignity and independence of persons with disabilities.
Service to people with disabilities will be integrated with others unless an alternate way of providing the goods, service or facility is required by the person with the disability.
Persons with disabilities will be given equal opportunity to use and benefit from the goods, services, or facilities an organization or business has to offer.
We will communicate with people with disabilities in a way that takes the individual’s disability into account.

Assistive Devices, and Service Animals, Service Dogs or Guide Dogs

Persons with disabilities who use an assistive device will be permitted to use their own device to access the services of Odyssey Medical.

If a person with a disability is accompanied by a guide dog or other service animal, Odyssey Medical shall ensure that the person is permitted to enter the premises with the animal and to keep the animal with them, unless the animal is otherwise excluded by law from the premises.

Support Workers

If a person with a disability is accompanied by a support person, Odyssey Medical will ensure that both persons are permitted to enter the premises together and that the person with a disability is not prevented from having access to the support person while on the premises.

Odyssey Medical will ensure that notice is given in advance if admission fees will be charged to support workers for accessing the goods or services in their role as support persons, including how much the fee will be.

Service Interruptions

If there is a temporary disruption in any of our services either in whole or in part, Odyssey Medical will provide notice of the disruption to the public via as many channels as possible, in accessible formats, where available. We will physically post notices where the disruption is taking place as well as through any other channels that are appropriate such as email, phone, text, social media, or on our website.

Notice of the disruption will include the reason for the disruption, its anticipated duration and a description of alternative facilities or services, if any, that are available.

Process for Receiving Feedback

Odyssey Medical will accept feedback about the way in which it provides goods and services to persons with disabilities in person, by phone or email, or in another way that is suitable to a person with a disability.

When a complaint is received about the way we provide goods, services, or facilities to persons with disabilities, Odyssey Medical will let the person who submitted the feedback know about the actions the organization will take to resolve the issue.

At Odyssey Medical, the person designated to accept feedback is Sharon Foulkes who can be reached at the following email address: [email protected].

Transportation

Odyssey Medical does not provide conventional or specialized commercial transportation services to passengers and is not required to adhere to the Transportation Standards.

For more information:

By email: [email protected]

By phone: 705-730-7600

By mail: 28 Currie Street, Unit 24, Barrie, ON L4M 5N4

WORKPLACE ACCOMMODATION POLICY AND PROCESS

Policy Statement

Odyssey Medical is committed to providing an accessible working environment for all employees. Odyssey Medical will support and facilitate the accommodation of employees with disabilities so that they are able to safely access all the opportunities that Odyssey Medical offers, subject only to the limits of undue hardship.

Odyssey Medical recognizes the importance of inclusion by design and barrier removal in the integration of employees with disabilities. Odyssey Medical will work to eliminate or minimize the adverse effects of all forms of barriers in accordance with its obligations under the Human Rights Code (“the Code”), and the Accessibility for Ontarians with Disabilities Act, 2005 (“the AODA”).

Purpose

Subject to the foregoing, this policy guides the process and decision-making for individual employee disability-related accommodations at Odyssey Medical. Moreover, it outlines the process for receiving, approving, and facilitating accommodation requests.

This document is available in alternate accessible formats on request.

Definitions

Disability: is defined by the Human Rights Code as follows:

(a) any degree of physical disability, infirmity, malformation or disfigurement that is caused by bodily injury, birth defect or illness and, without limiting the generality of the foregoing, includes diabetes mellitus, epilepsy, a brain injury, any degree of paralysis, amputation, lack of physical coordination, blindness or visual impediment, deafness or hearing impediment, muteness or speech impediment, or physical reliance on a guide dog or other animal or a wheelchair or other remedial appliance or device,

(b) a condition of mental impairment or a developmental disability,

(c) a learning disability, or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language,

(d) a mental disorder, or

(e) an injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997.

Reasonable Accommodation:for the purpose of this procedure, is an individualized process which, to the point of undue hardship, involves the removal or alleviation of barriers that prevent an otherwise capable individual from participating equally in the workplace because of a disability. For the purpose of this document, “reasonable accommodation” and “accommodation” are used interchangeably.

Undue Hardship:The point at which, having regard to all of the relevant circumstances, providing an employee with accommodation is outweighed by financial and/or institutional costs, the impact on other employees, health and safety considerations, and/or other relevant factors involved in providing the accommodation.

Objectives

Odyssey Medical is committed to:

Ensuring compliance with all applicable legislation and Odyssey Medical policies;
Ensuring that all requests for accommodation are considered on a case-by-case basis in order to determine accommodation requirements;
Ensuring that all safety measures are taken into consideration when determining appropriate accommodation;
Establishing an efficient and timely accommodation process that is consistent with the requisite principles outlined in Human Rights jurisprudence and
Outlining the process for submitting a request for accommodation, verifying and accepting the need for accommodation, and facilitating the accommodation.

General Principles

In individual cases, accommodation is a process which seeks to find the means to ameliorate those restrictions/limitations caused by the individual’s disability that preclude the individual from either meeting the requisite qualifications or from carrying out the essential requirements of a position. This process will take into account the following guiding principles:
The search for accommodation in any individual case is a process that takes into account the unique needs of the individual being accommodated.
In the accommodation process, workplace parties will be expected to work together cooperatively in a respectful manner, to share information, and to avail themselves of potential accommodation solutions.
Pursuant to the previous point, the individual must cooperate in the process by providing information, including medical reports, that clearly outline the restrictions/limitations/needs that result from the disability. As well, the individual must work with Odyssey Medical to find an appropriate accommodation.
Every effort should be made to provide reasonable accommodations. The accommodation selected will be an accommodation that aims to reduce the impact of the disability at work, respects the individual’s dignity, and does not give rise to undue hardship.
The accommodation process will incorporate measures to respect and protect the confidentiality of the employee’s personal or medical information.
A written Accommodation Plan shall be developed to detail the roles and responsibilities of the parties and to facilitate accountability and regular monitoring.
Accommodations shall be developed on an individualized basis, shall aim to remove barriers and ensure equality, and shall incorporate all appropriate measures to ensure the safety of the individual requesting the accommodation and all others.
It is the obligation and desire of Odyssey Medical to provide appropriate accommodation up to the point of undue hardship, which includes health and safety considerations.

Confidentiality of Information

Requests for accommodation may involve the disclosure of private or highly sensitive information. Persons requesting accommodation shall be asked only for information required to support the accommodation request and to respond appropriately to the request.
Information related to an individual’s disability and accommodation requests shall be kept in a separate location from the individual’s regular personnel file.
Personal information concerning an employee’s disability shall not be disclosed without the prior written consent of the individual or, where the disclosure is necessary to obtain an effective accommodation, without advising the individual to whom the information will be disclosed and must be managed in a manner that is consistent with the Personal Information Protection and Electronic Documents Act OR Freedom of Information and Protection of Privacy Act (1990).
Only relevant stakeholders will be involved in the development of an employee’s accommodation plan.
Where the accommodation process requires the disclosure of confidential information to a third party (such as an external resource group), the third party and any person or department delegated by that third party shall be required to ensure that confidentiality is protected, that the information obtained is kept in a secure location, and is used solely for the purpose for which the disclosure was required.

Accommodation Process

Workplace accommodations can range from simple and straightforward cases to lengthy and complex ones. The steps in this procedure outline the general process by which Odyssey Medical addresses accommodation for employees with disabilities in the workplace. It must be recognized that the Human Rights Tribunal of Ontario has emphasized that following a proper process in every case is of critical importance and that failure to do so may be seen as a violation of the Human Rights Code.

The principles of dignity, individualization, inclusion, and full participation are to be applied throughout the entire accommodation process. All parties share the responsibility to engage in meaningful dialogue and to work together respectfully towards accommodation solutions.

Requests for Accommodation

A need for accommodation for reasons of disability may be identified in several ways, including the following:

An employee may identify the need by notifying their manager that due to a disability, they cannot perform the essential duties of their job and are requesting an individual accommodation plan.
For an employee returning to work after an illness or injury, the return to work process involves a review to determine whether there are any disabilities and/or required accommodations prior to the employee returning to the workplace, and they are covered by the RTW Policy.
The need for accommodation may be identified by a manager, health care provider or another party, in which case the employee will be made aware of the accommodation process.

Accommodation requests are to be made in writing to the employee’s manager. If requested, the employee may provide their accommodation request in an alternate format that takes into account their accommodation needs.

In the event that an accommodation request is denied, the employee will be provided with written documentation of the reasons for the denial. These reasons will also be provided in an alternate format upon request.

The denial of an accommodation request may be appealed, in writing, to Senior Management if not involved in the original decision or designate. A final decision will be reached as soon as reasonably possible, based on a review of the accommodation request, the written documentation of the reasons for the denial, and any further information provided by or obtained from all parties regarding the request.

Medical Documentation

A request for accommodation must be supported by appropriate medical documentation.
Medical documentation must confirm that the employee has a disability that interferes with their ability to do their job or otherwise participate fully in the workplace, outline the specific restrictions and limitations that need to be accommodated, and the duration of the accommodation.
It is recognized that there may be some obvious cases where medical documentation would not be required; Human Resources can assist with this determination.
Additional medical documentation may be required with complex medical cases, cases involving a permanent disability, or cases requiring clarification about the employee’s disability or restrictions.
In such situations, Odyssey Medical will provide the employee with the employer’s written request for further information from the employee’s doctor, medical specialist, or other healthcare provider.
Where such requests result in insufficient information to determine appropriate accommodation measures, Odyssey Medical may require the employee to undergo an independent medical examination.
The employee will be requested to sign a consent document to permit enquiries and release of information to Odyssey Medical.
Odyssey Medical will review the information in the medical documents received, and will only communicate non-confidential information (e.g. functional abilities, limitations or restrictions, prognosis, anticipated duration of accommodation) to the employee’s manager.
No confidential information (e.g. diagnosis, treatment plan, name/specialty of the health care provider) will be shared without the prior written consent of the employee, except only where the information needs to be shared with a supervisor or others in order to achieve the accommodation.

Accommodation Process

The employee shall notify their manager of the request for an individual accommodation plan.
The employee or manager may contact Human Resources for assistance in the development of the accommodation plan. Human Resources will provide information, support and assistance as needed throughout the accommodation process.
Once the request is received, the employee will be required to provide appropriate medical documentation, as noted above.
The medical documentation will be reviewed to ensure that the information provided is adequate and will request additional medical information if needed. The manager will be informed about the employee’s restrictions, limitations, and accommodation needs.
The manager, in consultation with the employee, will make every reasonable effort to identify appropriate accommodation measures that will enable the employee to fulfill the essential duties of their job.

Note: Odyssey Medical is not required to create a new position for the employee; the accommodation process is intended to assist the employee in performing their current position. However, in some cases, the employee may be assigned a temporary position pending resolution of their disability to the point where they are able to return to their position, with or without accommodation.

The manager will also determine whether the employee requires individualized workplace emergency response information and/or an individual Workplace Emergency Response Information plan as a result of the disability.
All possible reasonable accommodation measures must be canvassed. Those accommodation measures selected to be included in the accommodation plan must be the measures that most respect the dignity of the individual while achieving the aim of providing the individual with equal opportunity, provided that no accommodation measures are selected which create undue hardship.
Where a concern arises that either no measure for accommodation is available or all possible accommodation measures would give rise to an undue hardship, Human Resources or Senior Management, as applicable, must be involved in any subsequent decisions regarding the accommodation process.
Once the accommodation measures have been determined, the manager will prepare a written accommodation plan outlining the nature of the accommodation and the measures agreed upon.
The manager will sign the plan document, and the employee will be given an opportunity to sign the plan. A copy of the final plan will be forwarded to all parties involved. A copy will be kept alongside the employee’s personnel file.
The manager, with cooperation from the employee, is responsible for ensuring that the measures outlined in the accommodation plan are implemented.

Monitoring and Review

The manager must conduct ongoing monitoring and reassessment of the accommodation plan during the period of accommodation.
Odyssey Medical may request updated medical information periodically to support ongoing accommodations.
If the accommodation is no longer appropriate, the employee and the manager will work together to gather relevant information and reassess the employee’s needs in order for the employer to find the best accommodation measure.
The employee or manager can contact Odyssey Medical senior management to assist in reviewing or revising the accommodation plan if the restrictions and limitations have changed or if updated medical documentation is received.

HIRING PRACTICES

The purpose of this policy is to outline the processes Odyssey Medical Inc. will follow to ensure our hiring practices are fair, consistent, equitable and in line with all applicable legislation such as the Ontario Human Rights Code, the Accessibility for Ontarians with Disabilities Act, and the Employment Standards Act.

Policy

Odyssey Medical is committed to the principles of equality and diversity in the workplace. We aim to hire the best candidate for the position based on their qualifications and merit in terms of knowledge, skills, and experience. Odyssey Medical will not discriminate against job applicants on any of the grounds protected by human rights legislation during any phases of the recruitment, screening and hiring process.

We welcome applications from persons with disabilities and will provide accommodations during all stages of the hiring process, upon request. This statement will be added to any job postings and all applicants will be reminded of this policy:

1) when they are invited to an interview, and

2) within any job offer provided.

All Odyssey Medical employees, including hiring managers involved in the candidate selection process will treat all job applicants with dignity and respect.

At no time during the interview process will any questions be asked that touch on any prohibited areas outlined in the Human Rights Code (such as age, ancestry, colour, race, citizenship, ethnic origin, place of origin, creed, disability, sex/pregnancy, family status, marital status, sexual orientation, gender identity, gender expression, and record of offences).

Reference checks may be completed for any candidate that is considered for hiring prior to making an offer of employment, to validate credentials and the accuracy of information provided by the candidate during the recruitment and screening process.

Any offer of employment will outline the terms and conditions of employment, including any further steps that the applicant must agree to complete to be eligible for employment (for example: a successful police records check).

Offers of employment will contain a probationary period of at least three months, so that both the employer and employee can trial the fit between the employee and the position, without any negative consequences.

Once the offer of employment is signed by the employee and any additional agreed terms have been met, the new employee may begin work at the agreed-upon date. New employees will receive orientation and training about key policies and safety issues that pertain to their position or that are required by law.

Odyssey Medical Inc. will ensure any personal information collected during any stage of the recruitment and hiring process is retained in an appropriate manner and remains confidential.

INDIVIDUALIZED WORKPLACE EMERGENCY RESPONSE INFORMATION

Objective:To ensure the safety and security of employees with disabilities during emergencies by providing individualized emergency response information and accommodations.

Planned Actions:

Identification of Employees Requiring Assistance:
- Employees will be informed during orientation and through regular communications about the option to request individualized emergency response information.
- Managers and HR personnel will proactively discuss emergency response needs with employees who self-identify as requiring assistance.
Development of Individualized Emergency Plans:
- Collaborate with employees to develop personalized emergency response plans tailored to their specific needs.
- Plans will include:
  - Identification of the nature of the accommodation required.
  - Specific roles or support needed during an emergency.
  - Steps to ensure safety during evacuation or shelter-in-place scenarios.
Distribution and Communication of Plans:
- Share the emergency response plan with the employee and designated individuals (e.g., supervisors, staff) as necessary while maintaining confidentiality.
- Update employees on any changes to emergency procedures that may affect their individualized plan.
Review and Updates:
- Individualized plans will be reviewed:
  - Annually as part of performance or safety reviews.
  - When the employee moves to a different location or role.
  - When the organization updates emergency procedures.
- Employees can request updates to their plans at any time.
Training and Awareness:
- Train staff involved in emergency response (e.g., managers, safety personnel) to understand their roles in implementing individualized plans.
- Conduct regular emergency drills to ensure all employees are familiar with procedures, including those with individualized needs.

Timeline for Implementation:

Ongoing, with regular reviews every [e.g., six months or annually] to ensure compliance and effectiveness.

Accountability:

Human Resources will oversee the development, implementation, and maintenance of individualized emergency response plans.

Progress Reporting:

Annual updates will be included in accessibility compliance reports and shared with employees.