Accessibility Policy

OVERVIEW AND PURPOSE

GlobeScan is committed to ensuring equal access and participation for people with disabilities. We are committed to treating people with disabilities in a way that allows them to maintain their dignity and independence.

We believe in integration, and we are committed to meeting the needs of people with disabilities in a timely manner. We will do so by removing and preventing barriers to accessibility and by meeting our accessibility requirements under Ontario’s accessibility laws.

This Policy is made pursuant to the requirements of the Accessibility for Ontarians with Disabilities Act, 2005 (“AODA”) and the Integrated Accessibility Standards Regulation (“IAS Regulation”) of the AODA and addresses how the Business will achieve accessibility.

Should you have any questions or feedback regarding this policy, please contact GlobeScan by e-mail at integrity@GlobeScan.com or anonymously by telephone at 1-415-445-4683.

APPLICATION AND SCOPE

This policy applies to all GlobeScan’s Ontario employees, volunteers, agents and/or contractors who deal with people on behalf of GlobeScan.

STATEMENT OF COMMITMENT

GlobeScan is committed to creating an inclusive culture across the organization by preventing and removing barriers for persons with disabilities. Where it is not possible to remove barriers, GlobeScan will make efforts to accommodate persons with disabilities in a timely, effective and suitable manner.

GlobeScan supports the principles of accessibility legislation.

As a small, private sector organization, GlobeScan’s goal is to ensure accessibility for our employees and our clients. Our employees, volunteers, agents and/or contractors aim to provide, to the best of their abilities, the same GlobeScan experience to all.

DEFINITIONS

The following definitions, some of which are provided in the AODA and the Integrated Accessibility Standards Regulation, apply for the purposes of this policy:

“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 his or her disability, including a physical barrier, an architectural barrier, an information or communications barrier, an attitudinal barrier, a technological barrier, a policy or a practice;

“DISABILITY”

means 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 co-ordination, 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; (“handicap”);

“FEEDBACK”

means any comments, compliments, suggestions or complaints provided to GlobeScan by its clients;

“WEBSITE”

means a collection of related web pages, images, videos or other digital assets that are expressed relative to a common Uniform Resource Identifier and is accessible to the public.

“SMALL ORGANIZATION”

means an obligated organization with less than 50 or more employees in Ontario, such as GlobeScan;

“ASSISTIVE DEVICE”

means a cane, walker or similar aid.

INDIVIDUALIZED EMERGENCY RESPONSE PLANS FOR EMPLOYEES

GlobeScan will provide individualized workplace emergency response information to employees who have a Disability, if the Disability is such that the individualized information is necessary and GlobeScan is aware of an accommodation need due to the Disability. If an employee who has received individualized information requires assistance, GlobeScan will, with the employee’s consent, provide the workplace emergency response information to the person designated by GlobeScan to provide assistance to the employee. GlobeScan will provide this workplace emergency response information as soon as practicable after GlobeScan becomes aware of the need for accommodation due to the Disability.

GlobeScan will review the individualized workplace emergency response information if the employee moves to a different location; when the employee’s overall accommodation needs or plans are reviewed; and when GlobeScan reviews its general emergency response policies.

CONFIDENTIALITY OF PERSONAL INFORMATION

Information about an employee’s disability is sensitive personal information and, as such, will be managed in a manner that is consistent with GlobeScan’s policies regarding the confidentiality of employee personal information. Where the accommodation process requires the release 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, will be required to ensure that confidentiality is protected, that the information obtained is kept in a secure location, and used solely for the purpose that the release was required. Click here to see GlobeScan’s privacy policy.

TRAINING

GlobeScan provides training to all its employees, volunteers, persons who participate in developing its policies and all other persons who provide goods, services or facilities on behalf of the Business. The training shall be:

  1. on the requirements of the IAS Regulation and the Human Rights Code as it relates to persons with disabilities;
  1. appropriate to the duties of the employees, volunteers and other persons;
  1. provided as soon as practicable, on an ongoing basis and as necessary to comply with all statutory requirements.

ACCESSIBLE CLIENT SERVICE POLICY

GlobeScan is committed to excellence in serving all clients, including people with disabilities. Our accessible client service policies are consistent with the principles of independence, dignity, integration and equality of opportunity for people with disabilities.

We will do so by removing and preventing barriers to accessibility and by meeting our accessibility requirements under Ontario’s accessibility laws and our obligations under the Human Rights Code.

  1. ASSISTIVE DEVICES

People with disabilities may use their personal assistive devices when accessing our goods, services or facilities.

In cases where the assistive device presents a significant and unavoidable health or safety concern or may not be permitted for other reasons, other measures will be used to ensure the person with a disability can access our goods, services or facilities.

  1. COMMUNICATION

We will communicate with people with disabilities in ways that take into account their disability. We will work with the person with a disability to determine what method of communication works for them.

We will ensure our website is accessible and continues to meet WCAG requirements.

  1. SERVICE ANIMALS

We welcome people with disabilities and their service animals. Service animals are allowed on the part of our premises which is open to the public.

  1. SUPPORT PERSONS

A person with a disability who is accompanied by a support person will be allowed to have that person accompany them on our premises.

In certain cases, we might require a person with a disability to be accompanied by a support person for the health or safety reasons of the person with a disability or others on the premises.

  1. NOTICE OF TEMPORARY DISRUPTION

In the event of a planned or unexpected disruption to services or facilities for clients with disabilities, we will notify clients promptly. This clearly posted notice or direct email or

telephone call will include information about the reason for the disruption, its anticipated length of time, and a description of alternative facilities or services, if available.

Services and facilities include: The business location.

The notice will be made publicly available as follows: The main entrance to the business location.

ACCESSIBILITY POLICIES

Through this Accessibility Policy, GlobeScan confirms our commitment to meet the needs of persons with disabilities in a manner consistent with legislative requirements.

GlobeScan will make these documents publicly available on its website and will provide them in an Accessible Format upon request.

This policy will be reviewed at least every five years and may be reviewed and/or revised more frequently to respond to business needs or legislative requirements.


Last reviewed: April 28, 2025