Accessibility

PART I: Overview

1. Introduction

The goal of the Accessibility for Ontarians with Disabilities Act, 2005 (the ‘AODA‘) is to create a more accessible Ontario, by identifying, and to the extent possible, preventing, and eliminating barriers experienced by persons with a disability.

The Accessibility Standards for Customer Service, Ontario Regulation 429/07 (the ‘Customer Service Standard‘) was established under the AODA to ensure goods and services are, where at all possible, equally accessible to every member of the public.

The Integrated Accessibility Standards, Ontario Regulation 191/11 (the ‘Integrated Accessibility Standard‘) establishes particular accessibility standards for information and communications, employment, transportation and the design of public spaces.

In accordance with the AODA, the Customer Service Standard and the Integrated Accessibility Standard, we at Delvinia Holdings Inc. and our related companies including Asking Canadians and Delvinia Custom Solutions (collectively, the ‘Company‘) have prepared this Policy.

This Policy includes:

2. Statement of Organizational Commitment;
3. A Multi-year Accessibility Plan; and
4. A Customer Service Policy.

PART II: Statement of Organizational Commitment

We are committed to meet the accessibility needs of persons with disabilities in a timely manner. We will achieve this vision by preventing and removing barriers to accessibility and by meeting the accessibility requirements under the Integrated Accessibility Standards.

It is our vision and goal to prevent and eliminate, to the extent possible, barriers experienced by persons with a disability at the Company.

PART III: Multi-year Accessibility Plan

1. Overview of our Multi-year Accessibility Plan

Our Multi-year Accessibility Plan is a roadmap for how we will improve our accessibility. The Multi-year Accessibility Plan outlines the ways we will prevent and remove barriers over the next number of years by identifying our goals and the timelines for establishing our goals.

2. Multi-year Accessibility Plan

Our Multi-year Accessibility Plan is a roadmap for how we will improve accessibility and outlines the ways in which we will achieve our goal over the next number of years. The components of the Multi-year Accessibility Plan are as follows:

• Delvinia has set up a process to respond to accessibility barriers persons may encounter during their participation in studies;
• Delvinia is making sure all new digital artefacts (including but not limited to websites, Apps,) created by our team conforms to AODA digital standards of W3C WAI WCAG 2.0 Level AA. This applies to all digital content produced or updated by Delvinia.
• Delvinia will ensure that any third-party vendor that we partner with or use throughout the course of this project is aware of and will conform to our web accessibility policy;
• Delvinia will also favor vendors based on their accessibility conformance claims;
• In order to validate AODA compliance Delvinia employs the following tools:
  • Colour Contrast: http://webaim.org/resources/contrastchecker/
  • Achecker: https://achecker.ca/checker/index.php
  • NVDA: https://www.nvaccess.org/
• Delvinia will make it clear to all parties at the beginning of a project that artefacts are reviewed for AODA compliance using only these tools.

PART IV: Customer Service Standard Policy

1. Application
The Customer Service Standard Policy applies to all persons who, on behalf of the Company, deal with members of the public or other third parties and to all persons responsible for the development, implementation or oversight of our policies, practices and procedures.

2. Providing goods and services to people with disabilities

Policies, Practices and Procedures
We will make all reasonable efforts to ensure that our policies, practices and procedures which impact the delivery of its goods and services to the public or to other third parties are consistent with the principles of dignity, equality of opportunity, integration and independence as defined above.

Communication
We strive to communicate with persons with a disability in a manner that takes into account the disability. Approaches for communication are set out in our accessibility training program.

All persons to whom this Customer Service Standard Policy applies will receive training on how to interact and communicate with persons with various types of disabilities.

3. Assistive Devices

Persons with a disability are permitted, where possible, to use their own assistive device when on our premises for the purposes of obtaining, using or benefiting from our goods and services.

If there is a physical, technological or other type of barrier that prevents the use of an assistive device on our premises we will make efforts to provide an alternative means of assistance to the person with a disability.

All persons to whom the Customer Service Standard Policy applies will receive training on how to interact with persons with disabilities who use assistive devices.

4. Accessibility at our Premises

Service Animals
Persons with a disability may enter our premises accompanied by a guide dog or service animal, and keep the guide dog or service animal with them, if the public has access to such premises and the guide dog or service animal is not otherwise excluded by law. If a guide dog or service animal must be excluded by law, we explain to our customer why this is the case and explore alternative ways to meet the customer’s needs.

All persons to whom the Customer Service Standard Policy applies will receive training on how to interact with persons with a disability accompanied by a guide dog or service animal.

Support Persons
A person with a disability may enter premises owned and/or operated by the Company with a support person and have access to the support person while on the premises. We may require a person with a disability to be accompanied by a support person where it is necessary to protect the health or safety of the person with a disability or the health or safety of others on the premises.

All persons to whom the Customer Service Standard Policy applies will receive training on how to interact with persons with a disability who are accompanied by a support person.

Notice of Temporary Disruptions
We will notify customers if there is a planned or unexpected disruption of a facility or service persons with a disability use to access our goods and services. The notice will be posted at:

https://www.delviniacs.com

The notice will include the following information:

• that a facility or service is unavailable;
• the anticipated duration of the disruption;
• the reason for the disruption; and
• alternative facilities or services, if available.

5. Training and Records

We will provide training, and ongoing training, to all persons to whom this the Customer Service Standard Policy applies. In particular, we will ensure the following persons receive training:

• every person who deals with members of the public or other third parties on behalf of the Company; and
• every person who participates in developing our policies, practices and procedures governing the provision of goods or services to members of the public or other third parties.

Training will include:

• an overview of the AODA and requirements of the Customer Service Standard;
• our plans to provide accessible customer service;
• a review of the Customer Service Standard Policy;
• how to interact and communicate with persons with various types of disabilities;
• how to interact with persons with a disability who use an assistive device or require the assistance of a service animal or support person;
• how to use equipment or devices made available on our premises to assist persons with a disability to obtain, use or benefit from our goods and services; and
• what to do if a person with a disability is having difficulty accessing our premises and/or services.

6. Documentation to be Made Available

This Policy, and related practices and protocols, shall be made available to any member of the public upon request.

Notification of same shall be posted on a high-traffic area at each premise to which this Policy applies.

PART V: Companies’ Relationships with Third Parties

The Integrated Accessibility Standards imposes various obligations on certain companies with respect to website accessibility. Delvinia licenses the use of its AskingCanadians’ surveys from a third party outside of the Province of Ontario that is not subject to the AODA and its regulations. Delvinia’s licensing arrangement with the third party does not provide Delvinia control over the functionality or the appearance of the website and content.

Delvinia is committed to working with any persons who encounter accessibility barriers generally and with respect to its website in particular. Delvinia encourages persons encountering accessibility barriers to reach out to it and Delvinia will work with the person to provide the communication in an alternative form.

PART VI: Feedback Procedure and Availability of Documentation

1. Receiving Feedback

We welcome and appreciates feedback regarding the Policy and its implementation. Feedback should be directed to the company in the following ways:

• Electronically: accessibility@delvinia.com
• Facsimile at: +416-364-9830

2. Responding to Feedback

Where possible, we will respond to complaints within two (2) weeks of the date that the complaint is received.

In certain circumstances we may be required to take more action to effectively address the complaint. In such circumstances the customer will receive an acknowledgement that the complaint has been received within two (2) weeks and we will respond to the complaint as soon as is practicable thereafter.

3. Format of Documents

We will provide documents, or the information contained in documents, required to be provided under the Standard, to a person with a disability in a format that takes the person’s disability into account. We will work with the person to find a format that is accessible.