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Accessibility for Ontarians with Disabilities Act

Rubicon Publishing Inc. (“Rubicon”) is committed to providing an accessible and inclusive environment in which all individuals have equal access to its services as required by the Accessibility Standards for Customer Service, O. Regulation 429/07 (ASCS) made under the Accessibility for Ontarians with Disabilities Act, 2005.

To that end, Rubicon is committed to the objectives of the AODA and the Ontario Human Rights Code. Rubicon will continue to provide its goods and services to persons with disabilities consistent with the core principles of independence, dignity, integration and equality of opportunity. 

Availability of documents

Copies of Rubicon’s policies developed and implemented to meet the requirements of the ASCS are available upon request. If required to provide a copy of our policies to a person with a disability, Rubicon will provide the person with the policies or the information contained in the policies in a format that takes the person’s disability into account and as agreed upon by Rubicon and the person with a disability.

Multi-year accessibility plan

Customer Service

Rubicon strives at all times to provide service to customers and business partners in a way that respects the dignity and independence of persons with disabilities. Rubicon is also committed to giving people with disabilities the same opportunity to communicate with us and to benefit from the same level of customer service, in the same place and in a similar way as other customers. 

Rubicon will take the following steps to ensure it continues to meet AODA requirements:

  • Provide training on accessible customer service to all new employees who interact with third parties. 
  • Review and update policies and standards regularly to ensure high quality, accessible customer service. 
  • Review all customer feedback and take appropriate action. 
  • Continue to implement facility access protocol by requesting that signs are posted in our office to advise third parties where alternate facilities may be accessed  while repairs to existing facilities are completed. 

Please refer to our Customer Service Policy for more details on the above.  

Information and Communications

Rubicon will take the following steps to ensure its policies and information are accessible to people with disabilities upon request:

  • Upon request, provide or arrange for information in accessible formats and/or provide communication supports for people with disabilities.
  • Ensure that information is provided in a timely manner, at no extra cost, and that the person making the request is consulted in order to determine the most appropriate format or support.
  • Train all applicable staff in the availability of communications in accessible formats and to whom requests should be forwarded and ensure that specific people (Human Resources, Marketing, Information Technology) are aware of the importance of responding to information requests.

Websites and Web Content

Rubicon meets many of the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) at 2.0 Levels A and AA, and is on a path to comply fully with WCAG 2.0 Level AA. We will continue to work with our web development group as well as utilizing online accessibility validator tools to identify and address any accessibility problems.

Rubicon will continue to take the following steps to ensure it continues to meet AODA requirements:

  • Work with our web development group to ensure WCAG 2.0 Level A/Level AA are met as required, and compliance is maintained as part of regular updates.
  • Conduct an assessment of the Company’s website and conduct testing for accessibility.

Feedback

Rubicon will take the following steps to ensure any feedback processes are accessible to people with disabilities:

  • Encourage feedback about our accessibility, including customer service, website, and employment practices.
  • Feedback can be submitted by any of the channels provided under “Contact Us” online, including by telephone at 1-800-336-0980 (toll free).
  • Rubicon will ensure all publicly available information is made accessible upon request.
  • Post on our website that we can provide accessible information upon request.
  • If a person with a disability asks for it, we will work with them to determine how to meet their needs within a reasonable timeframe.

Integrated Accessibility Standards Regulation

Part 1 (General)

Rubicon’s Accessibility Policy affirms its commitment to meeting the accessibility needs of persons with disabilities in a timely manner and governs the way that it will achieve accessibility. Rubicon has created its Multi-Year Accessibility Plan outlining the company’s strategy for identifying, removing, and preventing barriers to accessibility. The plan can be provided in alternate formats upon request. The plan will be reviewed and updated at least once every five years.

Ongoing Initiatives

In fulfilling its commitment to meeting these customer service related objectives, Rubicon will:

  • Ensure that all Ontario-based employees are trained* on the requirements of the accessibility standards referred to in the AODA regulation and on the Human Rights Code, as it pertains to persons with disabilities and maintain records of such training.
  • Continue to provide training on accessibility and client service standards to all new Ontario-based employees as part of their on-boarding.
  • Review and update policies and standards regularly to ensure high quality, accessible client service.
  • Review all client feedback and take appropriate action.

*Note: Rubicon implemented an in-house training program in July 2023.

Part 2 (Information and Communications)

Rubicon will follow best practices when improving, developing, implementing, and maintaining information and communications strategies and products to ensure that information and communications are available and accessible to people with disabilities. This includes websites, intranet sites, communication materials, telephone communications and face-to-face interactions. The goal is to achieve the most effective and efficient access to information for all users.

Ongoing Initiatives

In fulfilling its commitment to follow best practices in relation to communication and information strategies, Rubicon will:

  • Notify the public regarding the feedback process via its website.
  • Notify the public that accessible formats and communication support are available.
  • Provide information to all staff regarding the availability of communications in accessible formats.
  • Complete this initiative by January 31, 2024.

Accessible Websites and Web Content

Rubicon will:

  • Ensure that all new websites and web content comply with the World Wide Web Consortium (W3C) Web Content Accessibility Guidelines (WCAG) 2.0 at Level AA.
  • Conduct an assessment of the company’s public-facing website and testing for accessibility.
  • Establish a course of action and timelines to achieve web accessibility based on the results of the assessment and compliance with the law.
  • Complete this initiative by December 31, 2025.

Part 3 (Employment Standards)

Rubicon is committed to inclusive and accessible employment practices that attract and retain talented employees with disabilities.

Ongoing Initiatives

In fulfilling its commitment to providing inclusive and accessible employment practices, Rubicon will:

Evaluation and Review of Barriers

  • Review existing recruitment and employment practices and identify potential barriers to employment, including without limitation:
    • Methodology for advising of potential job opportunities.
    • Identification of barriers that may arise during the interview process.

Recruitment, Assessment or Selection Process

  • Inform job applicants who are selected for assessments or interviews during the recruitment process that accommodations are available upon request in relation to materials or processes to be used.
  • Consult with applicants requesting accommodation in order to provide suitable accommodation that takes into account the applicant’s accessibility needs.
  • Create systems to reduce or eliminate biases in recruitment processes (selection criteria, interview methodology).
  • Complete this initiative by December 31, 2023.

Notice to Successful Applicants

  • Notify successful applicants of policies for accommodating employees with disabilities when offering employment.  This notice will be included in the letter of offer to the successful applicant.
  • Complete this initiative by December 31, 2023.

Informing Employees of Supports

  • Inform all employees of policies for supporting employees with disabilities, including providing employment-related accommodations.
  • Provide new employees with this information during the orientation process.
  • Provide all employees with updated information whenever there is a change to existing policies on the provision of job accommodations.
  • Inform employees that their privacy will be respected and that any sharing of information about their accommodation needs will be discussed with them and plans for communication made with their consent.
  • Ensure that any updates to the accommodation policy is circulated to all employees through orientation and training.
  • Complete this initiative by December 31, 2023.

Accessible Formats and Communication Supports for Employees

  • Consult with employees with disabilities to provide them with the accessible formats and communication support they require to do their jobs effectively.
  • Complete this initiative by December 31, 2023.

Documented Individual Accommodation Plans

  • Prepare written accommodation plans for employees with disabilities indicating:
  • How an employee requesting accommodation can participate in the development of their individual accommodation plan.
  • How the employee will be assessed on an individual basis.
  • How Rubicon can request an evaluation by an outside medical or other expert, at the employer’s expense, to assist them in determining if and how accommodation can be achieved.
  • How the employee can request the participation of a representative from the workplace in the development of the accommodation plan.
  • The steps taken to protect the privacy of the employee’s personal information.
  • The frequency and manner in which the individual accommodation plan will be reviewed and updated.
  • If an individual accommodation plan is denied, how the reasons for the denial will be provided to the employee.
  • How the individual accommodation plans will be documented taking into account the employee’s accessibility needs due to disability.
  • Confirm to employees that:
    • All accommodation plans are private.
    • Each plan will include information on accessible formats and communication supports required, individual emergency response requirements and any other accommodation needed.
  • Train employees on the duty to accommodate, the accommodation process, how to support the accommodation process and how to access information and assistance.
  • Complete this initiative by June 30, 2024.

Return to Work

  • Continue to offer a return to work process.
  • Implement, as a part of the return to work process, a method of determining the essential job tasks or job functions and determining the method of accommodating the employee so that the employee can perform the essential duties of the position (with or without accommodation as the situation may arise).
  • Put in place a process to ensure that managers understand the accommodations being made as well as the privacy/communication concerns and agreements around the return to work accessibility requirements.
  • Confirm in a return to work policy, that an individual documented accommodation plan (see above) may be implemented to facilitate the return to work process.
  • Complete this initiative by June 30, 2024.

Performance Management

  • Take into account the accessibility needs of employees with disabilities with regard to performance management, including performance plans in accessible formats.
  • Review the existing performance management process to ensure that accessibility is built into the process.
  • Complete this initiative by December 31, 2023.

Career Development and Advancement

  • Take into account the accessibility needs of employees with disabilities with regard to career development and advancement, including coaching and feedback.
  • Review the existing career development and advancement process to ensure that accessibility is built into the process.
  • Complete this initiative by December 31, 2023.

Redeployment

  • Take into account the accessibility needs and individual accommodation plans of employees with disabilities when they are reassigned to other departments or jobs within Rubicon.
  • Complete this initiative by December 31, 2023.

Contact Information

If you have any questions regarding this policy or wish to provide feedback, please contact Rubicon’s Legal Department.

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