LOTEK ACCESSIBILITY POLICY

STATEMENT OF COMMITMENT

Lotek Wireless Inc. (“Lotek”) is committed to treating all people in a way that allows them to maintain their dignity and independence. We believe in integration and equal opportunity. We are committed to meeting the needs of people with disabilities by creating and maintaining an accessible environment for all employees, customers and visitors. This commitment is guided by the Accessibility for Ontarians with Disabilities Act, 2005 (the “AODA”) and related regulations.

Background and Purpose

Under the legislation (such as the AODA, and the Integrated Accessibility Standards Regulation (“IASR”)), standards are established to remove and prevent barriers faced by individuals with disabilities. The purpose of Lotek’s Accessibility Policy (“LAP”) is to outline the company’s responsibilities under the legislation. LAP is guided by the principles of Dignity, Independence, Integration and Equal Opportunity – Any policy that does not respect these principles will be modified or removed. Changes to this policy will consider the impact on individuals with disabilities.

Lotek has also developed a Multi-Year Accessibility Plan (“MAP”) that outlines the steps Lotek has taken and will continue to take to identify, prevent and remove barriers to accessibility. The MAP will be reviewed and updated at least once every five (5) years

Communication
Lotek’s MAP can be found below this document.

Communication
Lotek is committed to ensuring communication with individuals with disabilities is respectful and effective. Employees will be trained on how to communicate appropriately with people with various types of disabilities and when necessary, will ask individuals directly how they prefer to communicate.

Customer Service
Lotek strives to ensure that individuals with disabilities have equal access to our services. Reasonable efforts will be made to:

• Provide services in a way that respects the dignity and independence of individuals with disabilities;
• Offer accessible invoicing in alternate formats, whenever possible, upon request.

Assistive Devices
Individuals with disabilities are welcome to use assistive devices on our premises. The company will ensure employees are familiar with common assistive devices that may be used by customers to access our premises.

Service Animals
Service animals accompanying individuals with disabilities are welcome in public areas of company premises, unless prohibited by law. In such cases, we will explain why the animal is excluded and alternative arrangements may be made to provide access to our services.

Support Persons
Support persons accompanying individuals with disabilities are welcome in public areas of company’s premises. With the individual’s consent, support persons may assist in accessing our services. Consent from the person with a disability is required prior to any communication.

Notice of Temporary Disruption
Lotek will provide prompt notice in the event of a planned or unexpected disruption in the facilities or services usually used by individuals with disabilities. The notice will explain the reason for the disruption, the anticipated duration and a description of alternative facilities or services, if available. This posting will be available where appropriate given the circumstances.

Training for Staff
Lotek is committed to providing accessibility training to all employees and others who deal with the public.
Training is conducted as soon as practicable upon hiring and whenever policies are updated. Records of completed training are maintained as required. Topics for training include:

• An overview of the AODA and the requirements of the Integrated Accessibility Standards Regulation (“IASR”);
• Lotek’s accessibility policy;
• The Ontario Human Rights Code as it relates to persons with disabilities;
• Role-specific training on applicable standards, such as:”
  -Customer Service
  -Employment
  -Information and Communication

Employment Practices
Lotek is committed to fair and accessible employment practices. We:

• Ensure that all job postings encourage applicants with disabilities to apply and provide accommodation upon request;
• Provide feedback to unsuccessful candidates;
• Maintain detailed interview notes to ensure that hiring decisions are based on qualifications, and as fair, evidence based, and equitable as reasonably possible.

Workplace Emergency Response Information
Lotek will provide individualized workplace emergency response information to employees who have a disability, if needed, based on known accommodation requirements. Lotek will provide this information as soon as practical after becoming aware of the need for accommodation.

Individual Accommodation Plans and Return to Work
Lotek will maintain a documented process for developing individual Accommodation Plans and managing Return to Work (RTW) procedures. Employees requesting accommodation will work with HR and their manager to develop an individualized plan, which may include temporary or permanent job modifications. All information will be handled confidentially, and plans will be reviewed and adjusted as needed.

Feedback/Contact/Alternative Formats

Lotek welcomes feedback on how well we provide services to individuals with disabilities. To request documents in accessible formats, or for more information, questions, or feedback on this Policy, please contact Denise in our Human Resources department:

• By Phone: 905-836-2909
• By Email: employment@lotek.com
• By Mail: 115 Pony Drive, Newmarket, ON, L3Y 7B5

Accessible formats of this document, and those referenced within this document are available upon request. Lotek will ensure that our website (web content) conforms to the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0, at Level AA except where this is impractical.

LOTEK ACCESSIBILITY PLAN

Multi-Year Accessibility Plan (“MAP”)

As part of our commitment to accessibility and in compliance with the Accessibility for Ontarians with Disabilities Act (AODA), Lotek has developed a Multi-Year Accessibility Plan (MAP). This plan outlines the steps we will take to identify, prevent, and remove barriers to accessibility across our workplace and services. The plan is publicly available on our website and is reviewed and updated at least every five years to ensure it remains current and effective. Lotek’s MAP outlines the strategies and actions the company has implemented and will continue to implement to improve accessibility and opportunities for people with disabilities. It also describes the actions the company is taking to meet its requirements under applicable legislation.

MAP – Policies and Training

Lotek has implemented accessibility policies and provides training to employees on AODA and the Human Rights Code as they relate to people with disabilities. We are:

• Developing and implementing accessibility policies that reflect Lotek’s commitment to accessibility;
• Providing in-house training on accessibility and human rights legislation, as it pertains to people with disabilities.

MAP – Customer Service

Lotek is committed to providing inclusive service by:

• Training our employees on customer interactions for all abilities;
• Sharing Lotek’s accessibility policy with employees and customers;
• Welcoming service animals and support persons;
• Accepting feedback on how we can better provide service to customers with disabilities.

MAP – Information and Communication

Lotek provides accessible formats and communication supports for persons with disabilities upon request. Lotek consults will the person making such a request to determine appropriate solutions. Lotek is also committed to ensuring all internet websites and web content conform with WCAG 2.0 Level AA compliance.

MAP – Employment

Lotek supports employees and applicants with disabilities by:

• Providing individualized workplace emergency response information;
• Maintaining individual accommodation and return-to-work plans where required;
• Ensuring accessible hiring, retention and career development practices;
• Welcoming feedback on how we can better provide service to employees and applicants with disabilities.

MAP – Feedback/Contact/Alternative Formats

We welcome feedback on how well we provide services to those with disabilities. To request documents in accessible formats, or for more information, questions, or feedback on the MAP, please contact Denise in our Human Resources department:

• By Phone: 905-836-6680
• By Email: employment@lotek.com
• By Mail: 115 Pony Drive, Newmarket, ON, L3Y 7B5

Lotek’s last accessibility compliance report confirming compliance with its accessibility obligations was submitted as of August 1, 2023.
Accessible formats of this document, and those referenced within this document are available upon request.
Lotek will ensure that our website (web content) conforms to the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0, at Level AA except where this is impracticable.
Lotek is also committed to providing accessible invoicing to all customers. For this reason, invoices will be provided in alternate formats, whenever possible, upon request.

The Lotek Accessibility Policy and Plan was updated on April 1, 2026.