Accessibility Policy and Plan

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 Lotek employees, customers and visitors. This is achieved by following the objectives and requirements outlined in legislation such as the Accessibility for Ontarians with Disabilities Act, 2005 (the “AODA”).

Background and Purpose

Under the legislation (such as the AODA, and the Integrated Accessibility Standards Regulation (“IASR”)) standards are established to address barriers that people with disabilities face. The purpose of Lotek’s Accessibility Policy (“LAP”) is to outline Lotek’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. No changes will be made to this policy before considering the impact on people with disabilities.

Lotek has also provided our Multi-Year Accessibility Plan (“MAP”). This MAP outlines the steps the Lotek has taken and will take to prevent and remove barriers to accessibility. It will be reviewed and updated at least once every five (5) years.

General

Statement of Commitment

Lotek’s statement of commitment can be found at the top of this document

Multi-Year Accessibility Plan
Lotek’s MAP can be found below this document.

Communication

Lotek will take the necessary steps to ensure that all employees communicate with individuals with disabilities in a manner that takes into account their disabilities. Lotek will train staff who communicate with individuals including customers on how to interact and communicate with people with various types of disabilities and where possible and appropriate, they will ask the individual directly how to effectively communicate with them.

Customer Service
Lotek’s goal is to ensure that persons with disabilities are provided equal opportunity to obtain, use and benefit from our equipment and services. Reasonable efforts will be made to ensure that:

  • Equipment and services are provided in a manner that respects the dignity and independence of persons with disabilities
  • We provide accessible invoicing – invoices will be provided in alternate formats, whenever possible, upon request

Assistive Devices
Assistive devices that may be used by individuals with disabilities are welcome on the Company’s premises. We will take steps to ensure that employees are familiar with various assistive devices that may be used by customers with disabilities while accessing our equipment or services.

Service Animals
Lotek welcomes guide dogs or other animals that serve individuals with disabilities and, with the exception of those animals that are otherwise excluded by law, will allow the individual to keep the service animal with him or her in areas of our premises that are open to the public. In the event that a service animal is otherwise excluded by law from the premises, Lotek will make every effort to provide the disabled individual with an alternative method of obtaining, using or benefiting from our equipment or services.

Support Persons
Lotek welcomes persons who support individuals with disabilities to accompany them in areas of the Company’s premises that are open to the public. Lotek will ensure that disabled individuals have access to their support person while on the premises. Consent from the person with a disability is required when communicating private information related to the person with a disability, in the presence of a support person.

Notice of Temporary Disruption
Lotek will provide customers with notice in the event of a planned or unexpected disruption in the facilities or services usually used by people with disabilities. This 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 has and will continue to provide accessibility training to all employees and others who deal with the public or third parties on our behalf, as well as those involved in the development and approvals of customer service policies, practices and procedures.
Staff are and will continue to be trained on policies, practices and procedures that affect the way equipment and services are provided to people with disabilities. Staff are also trained on an ongoing basis when changes are made to these policies, practices and procedures. This training is also provided to staff as part of our new employee orientation. Training includes:

  • An overview of the AODA, the LAP, and the MAP;
  • How to interact, communicate and assist people with disabilities
  • How to assist a person with a disability who is experiencing difficulty accessing Lotek’s equipment or service

Employment
Lotek is committed to fair and accessible employment practices. We take the following steps to notify the public and staff that, when requested, Lotek will accommodate people with disabilities during the recruitment and assessment processes and when people are hired:

  • Ensure that all advertisements encourage qualified candidates with disabilities to apply, and provide accommodation upon request in relation to the materials or processes to be used
  • Provide necessary feedback to those who were not successful in the interview process
  • Keep well documented interview notes to ensure that decisions are made solely on experience, education and skills necessary to be successful in the position

Workplace Emergency Response Information
Lotek 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 if Lotek is aware of the need for accommodation due to the employee’s disability. Lotek will provide this information as soon as practical after becoming aware of the need for accommodation.

Documented Individual Accommodation Plans
Lotek will maintain a written process for the development of documented individual accommodation plans for employees with disabilities, if the disability is such that the individualized information is necessary, and if Lotek is aware of the need for accommodation due to the employee’s disability. Lotek will provide this information as soon as practical after becoming aware of the need for accommodation.
Lotek will take the following steps to develop and put in place a process for developing individual accommodation plans and return-to-work policies for employees that have been absent due to a disability:

  • Have employee treating physician fill out a functional ability form so the company can determine what the employee cannot do during their recovery or ongoing work
  • Work with all managers to find alternative work tasks to accommodate the disability

Feedback/Contact/Alternative Formats

Our goal is to meet and exceed expectations while serving customers with disabilities. Comments on our services regarding how well those expectations are met are welcome and appreciated. For more information, questions, or to provide feedback on this Policy, please contact Denise at our Human Resources department:

  • By Phone: 905-836-6680
  • 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 free 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”)

Lotek’s MAP outlines the strategies and actions that Lotek has and will put in place to improve opportunities for people with disabilities. These are also the actions Lotek is taking to meet its requirements under legislation.

MAP – Policies and Training

Lotek has and will continue to implement policies and provide training to employees on Ontario’s accessibility laws and on the Human Rights Code as it relates to people with disabilities in accordance with the AODA. Training will be provided in a way that best suits the duties of employees by taking the following steps:

  • Implementing policies outlining Lotek’s commitment to accessibility
  • Providing training to our employees on accessibility and human rights legislation, as it pertains to people with disabilities
  • Using Training Modules developed and provided by AccessForward

MAP – Customer Service

Lotek is committed to serving all customers including people with disabilities – we achieve this by:

  • Training our employees to serve customers of all abilities
  • Making the Lotek accessibility policy available to employees, volunteers and customers so they can know what to expect
  • Welcoming all service animals and support persons
  • Accepting feedback and comments on how we can better provide service to customers with disabilities

MAP – Information and Communication

Lotek currently provides accessible formats and communication supports for persons with disabilities upon request. Lotek consults will the person making such a request to determine the suitability of an accessible format or communication support. Lotek is also committed to ensuring all Lotek internet websites and web content conform with the AODA’s requirements.

MAP – Employment

Lotek is committed to serving all employees and prospective employees including people with disabilities – we achieve this by:

  • Providing individualized workplace emergency response information to employees who have a disability where Lotek is aware of the need for accommodation
  • Documenting processes for developing individual accommodation plans and return-to-work plans where required
  • Making our employment processes for hiring, retention and career development accessible
  • Accepting feedback and comments on how we can better provide service to employees and prospective employees with disabilities

MAP – Feedback/Contact/Alternative Formats

Our goal is to meet and exceed expectations while serving customers with disabilities. Comments on our services regarding how well those expectations are met are welcome and appreciated. For more information, questions, or to provide feedback on the MAP, please contact Denise at 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 free 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 August 1, 2023