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Multi-Year Accessibility Plan, 2012 – 2021

(Accessibilities for Ontarians with disabilities act (AODA), 2005 – Ontario Regulation 191/11, Integrated Accessibility Standards)

The multi-year accessibility plan is a road map that illustrates how RMG plans to make its commitments to accessibility a reality; meet all requirements under the IAS; and remove and prevent any additional barriers to accessibility at RMG.

PART I – General Requirements
# Initiative Requirement Outlined in the Act RMG’s Actions Status Compliance Date
1. Establishment of Accessibility Policies

3. (1) Every obligated organization shall develop, implement and maintain policies governing how the organization achieves or will achieve accessibility through meeting its requirements under the accessibility standards referred to in this regulation

RMG has developed and implemented policies governing how it achieves accessibility and meets its legal requirements.

Compliant

January 1, 2014

2. Accessibility Plan

4. (1) Large organizations shall,

a) Establish, implement, maintain and document a multi-year accessibility plan, which outlines the organization’s strategy to prevent and remove barriers and meet its requirements under this Regulation
b) Post the accessibility plan on their website, if any, and provide the plan in an accessible format upon request; and
c) Review and update the Accessibility Plan at least once every five years.

a) RMG established and implemented a multi-year accessibility plan in order to identify and remove barriers and meet its legal requirements

b) RMG posted the accessibility plans on its internal and external website in an accessible format

c) RMG will review and update the Accessibility Plan next in January 2019 and every 5 years thereafter.

Compliant

January 1, 2014

3. Training

7. (1) Every obligated organization shall ensure that training is provided on the requirements of the accessibility standards referred to in the Regulation and on the Human Rights Code as it pertains to persons with disabilities to,
a) all employees, and volunteers;
b) all persons who participate in developing the organization’s policies; and
c) all other persons who provide goods, services or facilities on behalf of the organization

All RMG employees and contractors receive training on accessibility standards as it relates to people with disabilities. Training will be available in an accessible format as requested and training records will be kept. Through ongoing education and awareness, RMG will give staff the knowledge and skills they need to meet or exceed compliance requirements. This will include alternate formats, hosting accessible meetings and creating documents, processes and policies with accessibility in mind.

All new employees will be trained on the IAS.

Compliant

January 1, 2015

PART II – Information and Communication Standards
# Initiative Requirement Outlined in the Act RMG’s Actions Status Compliance Date
4. Emergency procedures, Plans for Public Safety Information

13. (1) In addition to its obligation under section 12, if an obligated organization prepares emergency procedures, plans or public safety information and makes the information available to the public, the obligated organization shall provide the information in an accessible format or with appropriate communication supports, as soon as practicable, upon request.

RMG provides emergency procedures, plans or public safety information when requested.

Compliant

January 1, 2012

5. Accessible Websites & Web Content

14. (2) Designated public sector organizations and large organizations shall make their internet websites and web content conform with the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0, initially at Level A and increasing to Level AA, and shall do so in accordance with the schedule set out in this section.

RMG will continue to make its website and web content conform to the World Wide Consortium Web Content Accessibility Guidelines (WCAG) 2.0, initially at Level A and increasing to Level AA. Our internet and intranet websites, technology solutions, communication materials, telephone communications and in-person interactions will be based on accessibility best practices.
Accessible Websites and Web Content:
By achieving compliance with WCAG 2.0, employees and customers will receive web information in accessible format. This will provide them with equal and appropriate access to the information they need.

Compliant
(WCAG 2.0 Level A)

Pending (Level AA for January 1st, 2021)

January 1, 2014

6. Feedback

11. (1) Every obligated organization that has processes for receiving and responding to feedback shall ensure that the processes are accessible to person with disabilities by providing or arranging for accessible formats and communications supports, upon request.

Feedback forms are posted on RMG’s external and internal websites.

Compliant

January 1, 2015

7. Accessible Formats & Communication Supports

12. (1) Except as otherwise provided, every obligated organization shall upon request provide or arrange for the provision of accessible formats and communication supports for persons with disabilities,

a) in a timely manner that takes into account the person’s accessibility needs due to disability; and
b) at a cost that is no more than the regular cost charged to other persons.

Upon request, RMG will provide accessible formats and communication supports for persons with disabilities in a timely manner and at no extra cost.

Compliant

January 1, 2016

12. (2) The obligated organization shall consult with the person making the request in determining the suitability of an accessible format or communication support.

RMG does and will continue to consult with the person making the request in determining the suitability of an accessible format or communication support.

Compliant

January 1, 2016

12. (3) Every obligated organization shall notify the public about the availability of accessible formats and communication supports.

RMG will notify the public about the availability of accessible formats and communication supports.

Compliant

January 1, 2016

PART III – Employment Standards
# Initiative Requirement Outlined in the Act RMG’s Actions Status Compliance Date
8. Workplace Emergency Response Information

27. (1) Every employer shall provide individualized workplace emergency response information to employees who have a disability, if the disability is such that the individualized information is necessary and the employer is aware of the need for accommodation due to the employee’s disability.

Individualized response plans created for employees with disabilities.

Compliant

January 1, 2012

27. (2) If an employee who receives individualized workplace emergency response information requires assistance and with the employee’s consent the employers shall provide the workplace emergency response information to the person designated by the employer to provide assistance to the employee.

With employee`s consent, RMG provides information to the Emergency Response Staff assigned to the person requesting assistance. In the event that the assigned Emergency Response Staff is not available during the time of the incident, the person requiring assistance will identify themselves to the fire warden, manager, or any other employee in the area so an Emergency Response Staff can be assigned and assist the employee.

Compliant

January 1, 2012

27. (3) Employers shall provide the information required under this section as soon as practicable after the employer becomes aware of the need for accommodation due to the employee’s disability.

RMG provides the information required as soon as it becomes aware of the need for accommodation due to the employee’s disability.

Compliant

January 1, 2012

27. (4) Every employer shall review the individualized workplace emergency response information,

a) when the employee moves to a different location in the organization
b) When the employee’s overall accommodations needs or plans are reviewed; and
c) When the employer reviews its general emergency response policies.

RMG reviews annually the individualized workplace emergency response information.

Compliant

January 1, 2012

10. Recruitment – General

22. Every employer shall notify its employees and the public about the availability of accommodation for applicants with disabilities in its recruitment processes.

RMG continues to develop and implement employment practices to encourage people with disabilities to participate fully in all aspects of the organization by:

  • Notifying candidates about the availability of accommodations for applicants with disabilities by including a statement in all internal and external job postings;
  • Identifying and removing workplace barriers;
  • Inclusive employment practices for recruitment, retention and employee development;
  • Providing managers with accessibility training, tools and templates to support employee/workplace accommodations and address non-discrimination;
  • Notifying successful applicants of the Accessibility policies in place at RMG.

Continuously reviewing standards and best practices related to accessible employment.

Compliant

January 1, 2016

11. Recruitment, Assessment or Selection Process

23. (1) During a recruitment process, an employer shall notify job applicants, when they are individually selected to participate in an assessment or selection process, that accommodations are available upon request in relation to the materials or processes to be used.

RMG continues to develop and implement employment practices to encourage people with disabilities to participate fully in all aspects of the organization by:

  • Notifying successful applicants of the Accessibility policies in place at RMG

Compliant

January 1, 2016

23. (2) If a selected applicant requests an accommodation, the employer shall consult with the applicant and provide or arrange for the provision of a suitable accommodation in a manner that takes into account the applicant’s accessibility needs due to disability.

RMG will consult with applicants and provide or arrange for the provision of a suitable accommodation in a manner that takes into account the applicant’s accessibility needs due to disability.

Compliant

January 1, 2016

12. Notice to Successful Applicants

24. Every employer shall, when making offers of employment, notify the successful applicant of its policies for accommodating employees with disabilities.

RMG notifies successful applicants regarding its policies for accommodating employees with disabilities when making offers of employment.

Compliant

January 1, 2016

13. Informing Employees of Supports

25. (1) Every employer shall inform its employees of its policies used to support its employees with disabilities, including but not limited to, policies, on the provision of job accommodations that take into account an employee’s accessibility needs due to disability.

RMG informs employees of its policies and any updates to those policies used to support employees with disabilities, including policies on the provision of job accommodations that take into account an employee’s accessibility needs due to disability. This information will be provided to new employees as soon as is practicable after commencing employment.

Compliant

January 1, 2016

25. (2) Employers shall provide the information required under this section to new employees as soon as practicable after they begin their employment.

Training provided to all employees on AODA was provided in December 2012.

New employees are required to complete online training within 2 weeks of their hire date.

Compliant

January 1, 2016

25. (3) Employers shall provide updated information to its employees whenever there is a change to existing policy on the provision of job accommodations that take into account an employee’s accessibility needs due to disability.

Upon a change to an existing policy, RMG will take into account an employee’s accessibility needs.

Compliant

January 1, 2016

14. Accessible Formats & Communication Supports for Employees

26. (1) In addition to its obligations under section 12, where an employee with a disability so requests it, every employer shall consult with the employee to provide or arrange for the provision of accessible formats and communication supports for,

(a) Information that is needed in order to perform the employee’s job; and
(b) Information that is generally available to employees in the workplace.

Upon request of an employee with a disability, RMG will consult with the employee to provide, or arrange for the provision of, accessible formats and communication supports for information that is needed to perform his/her job, and information that is generally available to other employees.
In determining the suitability of an accessible format or communication support, RMG will consult with the employee making the request.

Compliant

January 1, 2016

26. (2) The employer shall consult with the employee making the request in determining the suitability of an accessible format or communication support.

Upon request of an employee with a disability, RMG will consult with the employee making the request in determining the suitability of an accessible format or communication support.

Compliant

January 1, 2016

15. Documented Individual Accommodation Plans

28. (1) Employers, other than employers that are small organizations, shall develop and have in place a written process for the development of documented individual accommodation plans for employees with disabilities.

Individualized response plans created for employees with disabilities.

Compliant

January 1, 2016

28. (2) The process for the development of documented individual accommodation plans shall include the following elements:

  • The manner in which an employee requesting accommodation can participate in the development of the individual accommodation plan.
  • The means by which the employee is assessed on an individual basis.
  • The manner in which the employer can request an evaluation by an outside medical or other expert, at the employer’s expense, to determine if and how accommodation can be achieved.
  • The manner in which the employee can request the participation of a representative from their bargaining agent, where the employee is represented by a bargaining, or other representative from the workplace, where the employee is not represented by a bargaining agent, in the development of the accommodation plan.
  • The steps taken to protect the privacy of the employee’s personal.
  • The frequency with which the individual accommodation plan will be reviewed and updated and the manner in which it will be done.
  • If an individual accommodation plan is denied, the manner in which the reasons for the denial will be provided to the employee.
  • The means of providing the individual accommodation plan in a format that takes into account the employee’s accessibility needs due to disability.

RMG has a step by step process documentation plan that outlines all the elements required under the regulation.

Compliant

January 1, 2016

16. Return to Work Process

29. (1) Every employer, other than an employer that is a small organization,

(a) shall develop and have in place a return to work process for its employees which have been absent form work due to a disability and require disability-related accommodations in order to return to work; and
(b) shall document the process

a) RMG has developed a return to work process which details the specific plans for employees returning to work following a disability related absence and who require accommodation to return to work.

b) RMG has a documented a return to work process in place.

Compliant

January 1, 2016

29. (2) The return to work process shall,

(a) Outline the steps the employer will take to facilities the return to work of employees who were absent because their disability required them to be away from work; and

(b) Use individual documented accommodation plans, as described in section 28, as part of the process

a) RMG’s return to work process outlines the steps it will take to facilitate the return to work of employees absent due to disability or a disability-related leave.

b) RMG uses and will continue to use Individual Accommodation plans as part of the process.

Compliant

January 1, 2016

29. (3) The return to work process referenced in this section does not replace or override any other return to work process created by or under any other statute.

The Return to Work Process does not replace or override any other return to work process required by other statute.

Compliant

January 1, 2016

17. Performance Management

30. (1) An employer that uses performance management in respect of its employees shall take into account the accessibilities, as well as individual accommodation plans, when using its performance management process in respect of employees with disability.

RMG takes into consideration employees with disabilities, as well as individual accommodation plans during the performance review and management process.

Compliant

January 1, 2016

18. Career Development & Advancement

31. (1) An employer that provides career development and advancement to its employees shall take into account the accessibility needs of its employees with disabilities as well as any individual accommodation plans, when providing career advancement to its employees with disabilities.

RMG takes into consideration employees with disabilities, as well as individual accommodation plans during the career development and advancement review and management process.

Compliant

January 1, 2016

19. Redeployment

31. (1) An employer that uses redeployment shall take into account the accessibility needs of its employees with disabilities, as well as individual accommodation plans, when deploying employees with disabilities.

RMG takes into consideration employees with disabilities, as well as individual accommodation plans during the deployment process.

Compliant

January 1, 2016

PART IV – Transportation Standard
# Initiative Requirement Outlined in the Act RMG’s Actions Status Compliance Date
20. Transportation

Sections 34 – 80.

Although this standard does not apply to RMG, RMG will continue to monitor all transportation related regulations as outlined in AODA for future compliance.

Not Applicable

January 1, 2017

PART V – Built Environment Standard
# Initiative Requirement Outlined in the Act RMG’s Actions Status Compliance Date
21. Waiting Area

80.43 (1) When constructing a new waiting area or redeveloping an existing waiting area, where the seating is fixed to the floor, a minimum of three per cent of the new seating must be accessible, but in no case shall there be fewer than one accessible seating space

RMG has taken into consideration accessible seating space in the waiting area, and will continue to keep it accessible.

Compliant

January 1, 2017

(2) For the purposes of this section, accessible seating is a space in the seating area where an individual using a mobility aid can wait.

RMG has and will continue to provide accessible seating space in the seating area where an individual using a mobility aid can wait.