Accessibility Policy and Multi Year Plan
- Summary
The Government of Ontario passed the Accessibility for Ontarians with Disabilities Act, 2005 (AODA). With this legislation, standards have been established for businesses and organizations in Ontario to identify, remove and prevent barriers so that people with disabilities will have more opportunities to participate in everyday life. The focus is on customer service, transportation, the built environment, information and communication, and employment. Arthur J. Gallagher & Co.'s Canadian subsidiaries, including but not limited to Arthur J. Gallagher Canada Limited, Gallagher Benefit Services (Canada) Group Inc., Gallagher Bassett Canada Inc. and Gallagher Re Canada Inc. ("Gallagher"or "we") 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 in a timely manner, and will do so by preventing and removing barriers to accessibility while meeting requirements under the AODA. Gallagher has developed this Accessibility Policy to set forth the principles of how it provides service and otherwise interacts with people with disabilities. Gallagher has also developed a Multi-Year Plan that describes how it intends to become a more accessible organization over time. This plan is set out further below and reviewed and updated at least every five years.
- Application of this Accessibility Policy
This Accessibility Policy applies to all Representatives of the Ontario operations of the following Gallagher businesses:- Arthur J. Gallagher Canada Limited
- Gallagher Benefit Services (Canada) Group Inc.
- Gallagher Bassett Canada Inc.
- Gallagher Re Canada Inc.
- Towerhill Insurance Underwriters Inc.
- Momentus Canada Inc.
- Cintran Claims Canada Limited
- AJG CANADA ULC, AJG NORTH AMERICA ULC
- Commitment to Accessible Information and Communications
(a) Accessible Formats and Communication Support
Upon request, Gallagher will provide:
(a) all organizational information and communications made available to Gallagher's customers and the public, including this Policy and Multi-Year Plan
(b) any publicly available emergency procedures, plans or public safety information to its customers and the public; and
(c) access to any processes for receiving and responding to feedback, in an accessible format or via accessible communication support.
Gallagher will consult with the person making the request to determine the suitability of any accessible format or communication support provided. This information and documentation will be provided as soon as is practicable, but specific timeframes may vary depending on the format requested.
(b) Website Accessibility
Except where doing so is not practicable, any new internet websites and any new web content and web-based applications will conform to the Web Content Accessibility Guidelines (WCAG) 2.0 Level A.
Gallagher continues to work towards increasing the accessibility of its internet website(s) so that by January 2021 its internet website(s) and the associated web content and web-based applications, published after January 2012, will conform to WCAG 2.0 Level AA (other than success criteria 1.2.4 and 1.2.5), except where doing so is not practicable.
(c) Feedback Regarding Accessibility
Gallagher welcomes feedback on how client and employee expectations are being met and potentially how they can be improved on regarding the use of our services. In particular, Gallagher encourages persons with disabilities to provide comments on the services they receive, including feedback regarding the accessibility of those services.
Feedback is encourage through the following formats:
Our Web Site:
Use the contact us section of the web site to forward any inquires or accommodation requests
By Mail:
Compliance Officer
Arthur J Gallagher Canada
181 University Avenue, Suite 1200
Toronto, Ontario, M5H 3M7
By Email:
Canada.compliance@ajg.com
Client, potential client, employee or applicant feedback should include the following:- Time and date of event
- Feedback concerning event
- Service be accessed
- Personnel involved
- Accommodation request
- Additional comments
- Voluntary inclusion of contact information
Feedback will be reviewed and appropriate action, if applicable, will be taken. Correspondence with the individual will take into account their accessibility needs and will be provided in accordance with Gallagher's commitment to accessible information and communication supports, described above.
- Accessible Employment
Gallagher is committed to fair and accessible employment practices and has implemented the following practices and procedures to promote the inclusion of applicants for employment and existing employees with disabilities in its workplace.
a. Recruitment
Gallagher notifies employees and the public about the availability of accommodations for applicants with disabilities during the recruitment process and when job applicants are individually selected to participate in an assessment or selection process. If a selected applicant requests an accommodation, Gallagher consults with the applicant and provides or arranges for the provision of a suitable accommodation (including with respect to any materials or processes used in the application process), taking into account the applicant's disability. When making offers of employment, Gallagher notifies successful applicants of its policies for accommodating employees with disabilities.
b. Employee Notification
Gallagher informs its employees of its policies used to support its employees with disabilities: (a) to new employees as soon as practicable after they begin their employment; and (b) whenever there is a change to existing policies on the provision of job accommodations that take into account accessibility needs due to a disability.
c. Accessible Formats and Communication Supports
Where an employee with a disability requests it, Gallagher will consult with the employee to provide or arrange for the provision of accessible formats and communication supports for: (a) information that is needed in order to perform the employee's job; and (b) employment information that is generally available to employees in the workplace. Gallagher will consult with the employee making the request in determining the suitability of an accessible format or communication support.
d. Individual Accommodation Plans
Gallagher has the desire to ensure that barriers in accommodation and return to work processes are eliminated and corporate policies surrounding accommodation and return to work are followed, where applicable. Each situation is looked at on a case-by-case situation, as each employee's situation is unique.
Where individual accommodation plan is related to a medical absences or return to work due to a medical absence, the company and the employee will work with our benefits provider to ensure a detail individual accommodation/return to work plan is put in place. This is normally provided directly from our benefits provider. If required for the individual, Gallagher will obtain an independent third party absence and disability management consultant to help ensure advocacy for the employees needs with consideration toward business factors.
Individualized Workplace Emergency Response Information
Gallagher shall provide Employees with individualized workplace emergency response information, in an accessible format or with appropriate communication supports, if their disability is such that individualized information is necessary and the Gallagher is aware of their need for accommodation.
1. Gallagher shall work with Employees who require individualized workplace emergency response information as soon as practicable upon receipt of a completed "Persons Requiring Assistance Form" from any such Employee. Individualized workplace emergency response information shall be shared with those designated to assist Employees in an emergency, where necessary with Employee consent.
2. Gallagher shall review individualized workplace emergency response information with Employees as required to ensure it is up to date. Individualized workplace emergency response information shall be reviewed where:
- the Employee moves to a different location in the organization;
- when the Employee's overall accommodation needs or plans are reviewed; and
- when company reviews its emergency response protocols.
Individual Accommodation Plans
Gallagher's existing policies include steps that Gallagher will take to accommodate employees with disabilities and to facilitate employees' return to work after absence due to disability. Gallagher will review and assess the existing policies to ensure that they include a process for the development of documented individual accommodation plans for employees with disabilities, if such plans are required. In accordance with the provisions of the IASR, Gallagher will ensure that the process for the development of documented individual accommodation plans includes the following elements:
- Gallagher's privacy policy protects the privacy of the employee's personal information;
- Employee will complete Individual Workplace Accommodation request form that will be reviewed by HR and the employees manager
- Each plan will be reviewed based on the agreement made when the individual plan is accepted. This could be reviewed weekly, monthly, quarterly etc. It will be done in a meeting format where the individual, HR and the manager will meet to review the plan.
- We encourage an employee to fully participate in their individual accommodation plan as they have a full understanding of their role and accommodation required. They can put forward ideas and suggestions for us to review discuss.
- If a plan is denied, we will meet with the individual to discuss the reasons for denial and follow up in with a written outline of the denial and the reasons.
- If we request an evaluation by an outside medical or other expert, we will put this request in writing the employee with a detailed outline of the information that we are looking to provided. We will work with our benefits provider to review
- The following will be included if individual accommodation plans are established:
- any individualized workplace emergency response information that is required;
- any information regarding accessible formats and communication supports that have been provided for or arranged, in order to provide the employee with:
- information that is needed in order to perform the employee's job;
- information that is generally available to employees in the workplace; and
- identify any other accommodation that is to be provided to the employee.
- The company will take into account the accessibility needs of employees with disabilities, as well as individual accommodation plans, when conducting performance management, providing career development and advancement to employees, or when redeploying employees.
e. Return to Work (RTW) Process and Accommodation Plans
Gallagher will ensure that the return to work process are set out in its existing policies outlines:
- Gallagher will outline the steps to facilitate the employee's return to work after a disability-related absence; which will include the development of a written individualized return to work plan for such employees; and the use of individual accommodation plans, as discussed above in point d, in the return to work process.
f. Performance Management, Career Development and Advancement and Redeployment
Gallagher takes into account the accommodation needs of its employees, including any individual accommodation plans of employees, when: (a) using performance management; (b) providing career development and advancement opportunities; and (c) redeploying employees.
g. Workplace Emergency Response Information
Gallagher provides individualized Workplace Emergency Response Information to employees who have a disability if the disability is such that the individualized information is necessary and the employer is aware of the need for accommodation due to the employee's disability. More details regarding this process can be found in the HR Manual.
- Training
Gallagher will provide training to all Representatives (employees and/or volunteers) in Ontario to increase awareness and encourage respect for the core principles of independence, dignity, integration and equality of opportunity for people with disabilities. Training will be provided through the company web based training portal (E-Learn) or in an alternate manner that best suits the Representative. Gallagher is an insurance brokerage and rarely do we have volunteers in the organization. When we have volunteers they would be provided the necessary training. We will train all staff that either develop policies or that provide services on our behalf related to the act.
This training will occur within four (4) months of the Representative's start date. Training will also be provided on an ongoing basis when changes are made to these policies, practices and procedures.
The training will address the following topics:- The purpose and requirements of the AODA, including the standards set out in the Regulations to the AODA
- The Human Rights Code as it relates to individuals with disabilities
- How to interact and communicate with people with various types of disabilities
- The purpose of assistive devices and how to interact with people who use them
- The purpose of service animals and how to interact with people who use them
- The purpose of support persons and how to interact with people who are accompanied by a support person
- What to do if a person with a disability is having difficulty accessing Gallagher services
Representatives will also be required to read the Gallagher policies in addition to any other internal documents on accessibility.
Through the E-Learn system, Gallagher will keep a record of all training provided under the AODA, including the individual who received the training, the dates on which the training was provided, the nature of the training and the successful completion of the assessment, if applicable.
- Accessible Customer Service
Gallagher has developed an Accessible Customer Service Policy setting out its commitment to providing equal access to its services for individuals with disabilities. A copy of this policy can be found at ajg.com/ca
- Design of Public Spaces
Gallagher will work with building management in each location to meet the standards for the public spaces and procedures will be put in place to prevent disruptions to the accessibility of public spaces. Public spaces include:- Outdoor paths of travel such as sidewalks, ramps, stairs and rest areas
- Parking spaces
- Reception areas
- Service Animals
We welcome people with disabilities and their service animals. Service animals are allowed on the parts of our premises that are open to the public. It should be noted that it is the responsibility of the person with a disability to ensure that his or her service animal is kept in control at all times. If the guide dog excluded by law, we will ensure other measures are available to enable a person with a disability to obtain the services we offer.
- Support Persons
A person with a disability, who needs to be accompanied by a support person will be allowed to do after a company representative consults the person with a disability and after considering the available evidence that the support person is necessary to protect the health or safety of the person with a disability or the health or safety of others on the premises. As well, there is no other reasonable way to protect the health or safety of the person with a disability and the health or safety of others on the premises.
- Multi-year Accessibility Plan
Gallagher consults with various internal and external resources to help ensure it maintains accessibility and compliance with its obligations under the AODA. Gallagher has developed the following Multi-Year Accessibility Plan in order to outline the policies and actions that it will or has put in place to improve opportunities for people with disabilities across the organization.
Summary of Accessibility Goal Related Provision of the Regulation Stats General Requirements Establish accessibility policies governing how Gallagher will meet its obligations under the AODA 3.(1) Complete - see further section 1 of this policy. Establish, implement and maintain a documented multi-year accessibility plan; post the plan on the website; review and update the plan at least once every five years 4.(1) Complete - see further section 8 of this policy Have regard to the accessibility for persons with disabilities when designing, procuring or acquiring self-service kiosks 6.(2) Not currently applicable Training on the requirements of the accessibility standards and on the Human Rights Code as it relates to persons with disabilities 7.(1) Complete as per section 5 of this policy Customer Service Standards Develop, implement and maintain policies governing the provision of Gallagher's services to persons with disabilities, and provide in an accessible format upon request 80.46 (1) Complete - see further sections 3.a and 6 of this policy Training on accessible customer service 80.49 (1) Complete as per section 5 of this policy Information and Communications Standards Ensure that feedback processes are accessible to persons with disabilities by providing or arranging for accessible formats and communications supports, upon request/td> 11.(1) Complete - see further section 3.c of this policy Upon request, provide or arrange for the provision of accessible formats and communication supports for persons with disabilities, in consultation with the individual, a) in a timely manner that takes into account the person's accessibility needs due to disability; and b) at a cost that is no more than the regular cost charged to other persons. Notify the public of the availability of these supports 12.(1), (2) and (3) Complete - see further section 3.a of this policy Provide any publicly available emergency response information in an accessible format, upon request 13. (1) Complete - see further section 3.a of this policy Ensure new internet websites and web content on those sites conform with WCAG 2.0 Level 14. (4)1 Complete By January 1, 2021, ensure all internet websites and web content conform with WCAG 2.0 Level AA, other than, i. success criteria 1.2.4 Captions (Live), and ii. success criteria 1.2.5 Audio Descriptions (Pre-recorded) 14. (4)2 Complete Employment Standards Notify Gallagher employees and the public about the availability of accommodation for applicants with disabilities in its recruitment processes 22 Complete - see further section 4.a of this policy During a recruitment process, notify job applicants when they are individually selected to participate in an assessment or selection process, that accommodations are available upon request in relation to the materials or processes to be used. 23 Complete - see further section 4.a of this policy Notify successful job applicant of Gallagher's policies for accommodating employees with disabilities 24 Complete - see further section 4.a of this policy Inform employees of Gallagher's policies used to support employees with disabilities 25 Complete - see further section 4.b of this policy Consult with a requesting employee in a manner that considers his or her disability to provide or arrange for the provision of accessible formats and communication supports for, (a) information that is needed in order to perform the employee's job; and (b) information that is generally available to employees in the workplace 26.1 and 26.2 Complete - see further section 4.c of this policy Provide individualized workplace emergency response information to employees who have a disability, if the disability is such that the individualized information is necessary and the employer is aware of the need for accommodation due to the employee's disability 27 Complete - see further section 4.d of this policy Develop and implement a written process for documenting individual accommodation plans for employees with disabilities 28 Complete - see further section 4.d of this policy Develop and implement a return to work process employees who have been absent from work due to a disability and require disability-related accommodations in order to return to work 29 Complete - see further section 4.e of this policy Take into account the accessibility needs of employees with disabilities, as well as individual accommodation plans, when using its performance management process in respect of employees with disabilities 30 Complete - see further section 4.f of this policy Take into account the accessibility needs of its employees with disabilities as well as any individual accommodation plans, when providing career development and advancement to its employees with disabilities 31 Complete - see further section 4.f of this policy Take into account the accessibility needs of its employees with disabilities, as well as individual accommodation plans, when redeploying employees with disabilities 32 Complete - see further section 4.f of this policy Design of Public Spaces Ensure that any new or redeveloped outdoor Paths of Travel (i.e. sidewalks, ramps, stairs, curb ramps, rest areas and accessible pedestrian signals) comply with the requirements of the AODA 80.22 Complete as per each building's requirements Ensure that any new or redeveloped parking (on and off street) complies with the requirements of the AODA 80.32 Complete as per each building's requirements Ensure that any newly constructed service counters and fixed queuing lines, and any newly constructed or redeveloped waiting areas, comply with the requirements of the AODA 80.40 Complete as per each building's requirements Develop procedures for preventative and emergency maintenance of the accessible elements in the above-noted public spaces and procedures for dealing with temporary disruptions when the above-noted accessible elements are not in working order 80.44 Complete as per each building's requirements - Availability of this Policy and Multi-Year Plan
A copy of this Policy and the Multi-Year Plan will be posted on Gallagher's corporate website. Upon request, Gallagher will provide or arrange for the provision of this Policy and Multi-Year Plan, or the information contained in this Policy and Multi-Year Plan, to the requesting individual in an accessible format or with a communication support in a timely manner that takes into account the person's accessibility needs due to disability and at no cost. In doing so, Gallagher will consult with the person making the request in determining the suitability of the format or communication support.
- Reports AJG Canada ULC, AJG North America ULC Accessibility Compliance Report 2023
- Definitions
"Accessible Formats" means any form of large print, clear text, recorded audio and electronic formats, Braille and other formats usable by persons with disabilities in order to conduct business with Gallagher.
"Communication Supports"means captioning, alternative and augmentative communication supports, plain language, sign language and other supports that facilitate effective communications in order to conduct business with Gallagher.
"Disability" as defined in the Ontario Human Rights Code means:
(a) any degree of physical infirmity, malformation or disfigurement that is caused by bodily injury, birth defect or illness and, without limiting the generality of the foregoing, includes diabetes mellitus, epilepsy, a brain injury, any degree of paralysis, amputation, lack of physical co- ordination, blindness or visual impairment, deafness or hearing impediment, muteness or speech impediment, or physical reliance on a guide dog, or other animal or on a wheelchair or other remedial appliance or device,
(b) a condition of mental impairment or a developmental disability,
(c) a learning disability, or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language,
(d) a mental disorder, or
(e) an injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997.
"Representatives"means employees, volunteers, others that provide goods or services on Gallagher's behalf, and all those who are involved in the development of Gallagher's policies, practices and procedures.
"Web Content Accessibility Guidelines" means the World Wide Web Consortium Recommendation, dated December 2008, entitled "Web Content Accessibility Guidelines (WCAG) 2.0".
"Website"means a collection of related webpages, images, videos, or other digital assets that are addressed relative to a common Uniform Resources Identifier (URI) and is accessible to the public.
Arthur J. Gallagher Canada Limited Accessibility Compliance Report 2023
Cintran Claims Canada Limited Accessibility Compliance Report 2023
Gallagher Benefits Services Accessibility Compliance Report 2023
Gallagher Re Canada Inc. Accessibility Compliance Report 2023
Momentus Canada Inc. Accessibility Compliance Report 2023
Towerhill Insurance Underwriters Accessibility Compliance Report 2023
