Accessibility Canada Act – Accessibility Plan

PURPOSE

At Louis Dreyfus Company Canada ULC (the Organization), we strive to treat all people with respect and in a manner that allows them to maintain their dignity and independence. The Organization is firmly committed to meeting all of the obligations of the Accessible Canada Act (ACA) with respect to appropriate accommodation for persons with disabilities.

The purposes of this Accessibility Plan are to:

Ensure that workplace accommodation requirements are determined on a case-by-case basis for Job Applicants and/or Employees with a Disability (all as defined below);
Achieve a work environment that promotes dignity, integration, and equal opportunity and is supportive of Job Applicants and Employees;
Comply with all applicable legislation and the requirements of the applicable Collective Bargaining Agreements (defined below); and
Establish an efficient process for accommodating Disability that is consistent with the principles of confidentiality and shared responsibility.

Accommodating Disability in the workplace is a shared responsibility that includes the Organization, Job Applicants, and Employees, along with any other relevant parties as needed (e.g., the Union and applicable health care professionals).

This Accessibility Plan will include information on the identification and removal of barriers, and the prevention of new barriers, in the areas described in Section 5 of the ACA, which are:

Employment;
The built environment;
Information and communication technologies (ICT);
Communication, other than ICT;
The procurement of goods, services, and facilities;
The design and delivery of programs and services; and
Transportation.

DEFINITIONS

Barrier is defined by the ACA as anything — including anything physical, architectural, technological or attitudinal, anything that is based on information or communications, or anything that is the result of a policy or a practice — that hinders the full and equal participation in society of persons with an impairment, including a physical, mental, intellectual, cognitive, learning, communication or sensory impairment or a functional limitation.

Disability(ies), as defined in the ACA means any impairment, including a physical, mental, intellectual, cognitive, learning, communication, or sensory impairment — or a functional limitation — whether permanent, temporary or episodic in nature, or evident or not, that, in interaction with a barrier, hinders a person’s full and equal participation in society.

GENERAL

1. Feedback

Mary-Beth Price, Regional Head of Human Resources – North America, is responsible for receiving feedback on behalf of the Organization. The Regional Head of Human Resources – North America can be contacted at mailing address: 40 Danbury Road, Wilton Connecticut, 06897; email: [email protected]; or telephone: 1-203-761-2192. Please contact the Regional Head of Human Resources – North America for any information regarding the Organization’s Accessibility Plan, including:

A copy of the Accessibility Plan in one of the alternate formats described in subsection 8(2) of the regulations;
A description of the Organization’s feedback process in one of the alternate formats described in subsection 9(5) of the regulations; and
To provide feedback to the Organization.

2. Executive Summary of Accessibility Plan

In 2019, the Parliament of Canada enacted the Accessible Canada Act (the Act). This Act aims to identify and remove existing barriers to accessibility, and prevent new barriers, in specific areas identified under the Act, by the year 2040. The Act requires federally regulated entities to report to the public on their policies and practices in relation to the identification and removal of barriers by developing and publishing accessibility plans, feedback processes, and progress reports.

Louis Dreyfus Company Canada ULC (the Company) is a global business that employs and works with thousands of people worldwide, and respect for diversity and inclusion is part of the Company’s values. The Company’s CEO has demonstrated continuous commitment towards diversity and inclusion goals, and is committed to providing a safe, accessible, respectful and inclusive work environment to all. The Company currently has 166 employees at three different work locations in Canada: Yorkton, Saskatchewan; Calgary, Alberta; and, Port Cartier, Quebec. The Company has several policies regarding accessibility and accommodation requests, including but not limited to: the Canada Policy Manual; Equal Employment Opportunity Policy; SHE (Safety, Health & Environment) Policies; Non-Discrimination, Anti-Harassment and Anti-Violence policy; Return to Work program; Leave of Absence policies; Maternity-Related Reassignment/Accommodation; etc. The Company also encourages all employees to actively participate with the country HR Manager for questions and concerns about one’s employment, including questions and concerns about accessibility. Any accessibility requests will be treated with upmost respect, confidentiality, comfort, sensitivity and urgency, and the country HR Manager will work closely with Facility Management and the Regional Head of Human Resources to ensure appropriate remedies have been implemented for the employee.

The following accessibility plan is designed to outline the activities undertaken by the Company to ensure that, to the extent possible, employees are able to complete their tasks and participate in Company events and initiatives without barriers. In addition to the activities undertaken, this accessibility plan also outlines the steps that the Company plans to take to improve access and participation to those employees who require it. Please know that the accessibility plan is a living document and as such, based on the feedback received, it will be updated from time to time.

AREAS DESCRIBED UNDER SECTION 5 OF THE ACA

1. Employment Identified barriers:

Recruitment (representation in employee roles and candidates pools);
Onboarding and Training (tailored training and active recruitment of person with disabilities); and
Accommodation Support (policies that detail accommodation information and requests).

Goals:

Explore partnerships with associations or groups that would better reach people with disabilities;
Monitor the distribution of candidates who identify as having a disability with the distribution of employees who identify as having a disability to ensure there are no barriers; and
Simplify the request/approval process for accommodations to ensure easier access while protecting dignity and psychological safety of the employee.

2. The built environment Identified barriers:

Physical structures (issues with office/plant facilities and signage);
Workspaces (spaces that take into account sound, ergonomics, work platforms and working at heights, smell, dust, external weather conditions, and other accommodations for persons with disabilities and that can be easily tailored to meet these needs.); and
Emergency Measures (procedures that do not create obstacles).

Goals:

Perform an INT audit to identify facility gaps;
Increase signage visibility;
Create a process for employees to share their specific workplace needs;
Inform employees of the process for any accessibility question related to the building; and
Evaluate ways to include emergency measures for visual and hearing impairments.

3. Information and communication technologies (ICT)

Identified barriers:

Understanding accommodation and ICT tools;
Diverse offerings of tools to persons with disabilities;
Intranet accessibility;
Lack of awareness;
Internal expertise on accessibility; and
Access to accessible technological equipment or software.

Goals:

Offer training to management and employees to increase awareness and knowledge of accessibility issues including the tools, technologies and equipment used by people with disabilities;
Continuous research about new technology to adapt to business and accessibility requirements;
Improve the process and visibility by which employees can access specialized equipment (brail keyboards) and technology.

4. Communication, other than ICT

Identified barriers:

Multimedia (ensuring content accessibility in all formats, WCAG 2.0 compliance);
Events (content accessibility at events); and
Written Communications (writing styles and access).

Goals:

Avoiding jargon and complex syntax in communications;
Providing subtitles and/or descriptive audio upon request; and
Providing sign language interpretation upon request.

5. The procurement of goods, services and facilities

Identified barriers:

Supply chain (discussing deals with vendors/suppliers that facilitate accessibility); and
Procurement (promote accessibility at the procurement stage for goods and services).

Goals:

Conducting audits on our third-party applications where applicable;
Reminding vendors about WCAG principles; and
Ensuring third-party applications respect WCAG standards.

6. The design and delivery of programs and services

Identified barriers:

Program delivery (consistency in program and service delivery);
Program design (format and program design).

Goals:

Provide content that is accessible (color contrast for visual accessibility, accessibility of PDFs, text transcriptions etc.);
Ensure visual elements (images, typography etc.) are readable.

7. Transportation

Identified barriers:

Travel to external events;
Parking

Goals:

Offering, as needed, adaptive transportation to events located outside of the employee campus;
Offering, as needed, parking to employees with mobility reductions; and
Offering employees and candidates information about accessible entrances and offering mobility reduced parking to candidates.

CONSULTATIONS

The Organization is committed to ensuring that its Accessibility Plan and accompanying Accessibility Policy is tailored to meet the needs of persons with disabilities. The Organization has taken efforts to consult with persons with disabilities and listen to their concerns about identifying, removing and preventing barriers in all areas of its activities.

1. Whom We Consulted

a. Employees

b. Union Shop Stewards

2. When Consultations Occurred

a. OH&S Committee Meetings – 4 meetings have occurred in the last 12 months, with 10+ participants each time from employees and management at Yorkton, Saskatchewan b. ERC (Employee Relation Committee) Meetings – 4 meetings have occurred in the last 12 months, with 4+ participants each time from union members and management team at Yorkton, Saskatchewan

3. How Consultations were Conducted

a. The Organization can confirm that is currently no employees who have formally self-disclosed disability status or have requested for accessibilityor consultations.

4. Results of Consultations

a. Does not apply.

BUDGET AND RESOURCES

At this time, there is no specific line item for the above improvements as these improvements will fall into various general categories such as operational budget, employee engagement budget, etc. In terms of current resources available, these include:

– Presence of elevators and/or ramps into all main offices – Main level restrooms – EthicsPoint reporting (confidential and comprehensive tool to report misconduct in the workplace) – Anonymous employee surveys – Canada Policy Manual, which includes Equal Employment Opportunity Policy, Non-Discrimination Anti- Harassment and Anti-Violence policy, Leave of Absence Policies, Maternity-Related Reassignment/Accommodation – SHE (Safety, Health & Environment) Policies, including Return to Work forms – Active presence onsite unions (2 of the 3 Canadian work locations has unionized industrial hourly workers to assist with representation and consultations)

TRAINING

We will provide training that is consistent with our Accessibility Policy and this Accessibility Plan. Training will be provided to all members of our Organization, including employees, volunteers and others who deal with the public or other third parties on their behalf, and all those who are involved in the development and approvals of customer service policies, practices and procedures.

This training will be provided as soon as reasonably practicable after staff commence their duties. The content and delivery of training may vary in accordance with the trainees’ duties and responsibility and will include the following:

The purposes of the ACA and its requirements;
The Canadian Human Rights Act as it pertains to persons with disabilities;
How to interact, communicate and consult with people with various types of disabilities, including use of accessible communication formats;
How to accommodate individuals that require the assistance of a service animal or a support person;
How to provide, receive and escalate feedback provided with respect to accessibility questions and concerns; and
Our policies, practices and procedures relating to providing services to people with disabilities The Organization will maintain a record of the training provided, including the training dates, and the name and number of individuals to whom it was provided.

We may provide additional training as changes in legislation or workplace condition requirements.