Accessible Customer Service Policy

Purpose

At Club Monaco, we are committed to providing exceptional customer service to all of our clients. Making services accessible to persons with disabilities is an important part of this commitment to superior customer service.

We strive to provide our services in a way that respects the dignity and independence of people with disabilities. We are also committed to giving people with disabilities the same opportunity to access our services and allowing them to benefit from the same services in the same place and in a similar way as other clients.

This policy establishes our commitment to accessible customer service under the Accessibility for Ontarians with Disabilities Act, 2005 and the customer service standard requirements under Ontario Regulation 191/11, The Integrated Accessibility Standards Regulations.

Application

Club Monaco’s Accessible Customer Service Policy (“the Policy”) applies to all of our employees and managers, and to any third parties (e.g., contractors) who we may arrange to provide our goods and services on our behalf. This policy applies to the extent that members of the public interact with our representatives directly and are able to directly access our services, products, and premises.

Communication

When communicating with people with disabilities, we will do so in ways that take into account their disability. Accordingly, we will train any staff who communicate with clients on how to interact and communicate with people with various types of disabilities.

Assistive devices

People with disabilities are welcome to use their own personal assistive devices (e.g., white cane, wheelchair, hearing and visual aids) in order to access or use our facilities and obtain our services, to the extent that those facilities and services are made available and accessible to the general public. We will train our staff to become familiar with various assistive devices that may be used by clients with disabilities while accessing our services. We will also ensure that staff know how to use assistive devices that are available for clients on our premises.

Service animals and support persons

People with disabilities who are accompanied by a service animal are welcome on all parts of our premises that are open to the public and other third parties. Clients may keep the animal with him/her unless excluded by law, in which case, we will consider alternative measures to access to our services. Our staff and others dealing with the public on our behalf will be trained on how to interact with people with disabilities who are accompanied by a service animal.

Any person with a disability who is accompanied by a support person will be allowed to enter our facilities with his or her support person. At no time will a person with a disability who is accompanied by a support person be prevented from having access to his or her support person while on our premises.

Notice of temporary disruption

In the event of a planned or unexpected disruption in facilities or services usually used by people with disabilities, Club Monaco will post a notice about the reason for the disruption, its anticipated duration, and a description of alternative facilities or services, if available. The notice will be placed at or near the affected facility or service and/or through other means (e.g., website) where necessary.

Training for staff

We will provide training to all Club Monaco employees, all persons who are involved in the development and approval of Club Monaco policies, and all other persons who provide goods, services or facilities on behalf of Club Monaco. This training will be provided shortly after staff commence their duties and/or upon changes to this Policy, practices and procedures.

Training will include the following:

• The purposes of the Accessibility for Ontarians with Disabilities Act, 2005 and the requirements of the customer service standard
• How to interact and communicate with people with various types of disabilities
• How to interact with people with disabilities who use an assistive device or require the assistance of a service animal or a support person
• How to use various assistive devices available on our premises, if any
• What to do if a person with a disability is having difficulty in accessing our facilities and services
• Club Monaco policies, practices and procedures relating to the customer service standard.

Feedback process

We welcome any feedback on our goods, services, and facilities from people with disabilities. Please send your comments to the following:

Club Monaco Corp.
Global People Practices (“GPP”)
625 Madison Avenue
New York, New York 10022

Make a Difference Hotline (1-877-4POLORL).
Alternatively, as another option you can also email GPP at:
[email protected]

All feedback, including complaints, will be handled as quickly as possible. We will consider your comments carefully, and you can expect to hear from us within a reasonable period of time. Please understand that some inquiries may take longer to address.

Note: copies of documents required under the Accessibility for Ontarians with Disabilities Act, 2005 are available upon request. Please notify us in advance if you require such documents in an alternative or accessible format.

Current Version Date: April 30, 2018

Accessibility Policy and Multi-Year Accessibility Plan

In compliance with Ontario Regulation 191/11 under the Accessibility for Ontarians with Disabilities Act, 2005 (“AODA”) Introduction

The Integrated Accessibility Standards Regulations (“IASR”) under the AODA require that Club Monaco establish, implement, maintain and document its accessibility policies and multi-year accessibility plan (the “Accessibility Plan”), which outlines Club Monaco’ strategy for preventing and removing barriers for persons with disabilities and to meet our requirements under the IASR and the AODA.

The Accessibility Policy and Multi-Year Accessibility Plan will be publicly available, including in an accessible format upon request. The Accessibility Plan will be reviewed and updated, if applicable, at least once every five years.

Application

The Accessibility Policy and Multi-Year Accessibility Plan applies to all employees and customers of Club Monaco in Ontario, and, where indicated, to any independent contactors providing services on behalf of Club Monaco in Ontario.

Our Commitment

In fulfilling our mission, Club Monaco strives to treat all individuals in a manner that allows them to maintain their dignity and independence. Club Monaco promotes integration and equal opportunity and is committed to meeting the needs of people with disabilities in a timely manner. We will seek to achieve this by preventing and removing barriers to accessibility and by meeting accessibility requirements under the AODA. This Accessibility Policy and Multi-Year Accessibility Plan sets out Club Monaco’ policy on how we will achieve accessibility generally, as well as in employment, and information and communications.

Under the IASR, the following accessibility strategies set out the requirements that are applicable to Club Monaco:

• Training;
• Information and Communication;
• Employment; and
• Design of Public Spaces Standards.

Accessibility Standards for Customer Service

In accordance with its customer service standard requirements under the IASR, Club Monaco is committed to providing exceptional customer service to all of its customers and clients. For more information, please refer to Club Monaco’ Accessible Customer Service Policy.

Accessible Emergency Information

Club Monaco is committed to providing the customers and clients with publicly available emergency information in an accessible way upon request.

Club Monaco will also provide employees with disabilities with individualized emergency response information when necessary.

Integrated Accessibility Standards Regulations (IASR)

The following sets out how Club Monaco is committed to complying with the IASR.

1.     Training

Club Monaco is committed to providing training on the requirements of the accessibility standards referred to in the IASR and on the Human Rights Code, as it pertains to persons with disabilities.

In accordance with the IASR, Club Monaco will:

• determine and ensure that appropriate training on the requirements of the IASR and on the Human Rights Code as it pertains to persons with disabilities, is provided to all employees and volunteers, all other persons providing goods and services on behalf of Club Monaco in Ontario, and persons participating in the development and approval of Club Monaco’ policies;
• ensure training is appropriate to the duties of the persons referenced above;
• ensure that the training is provided to persons referenced above as soon as practicable;
• keep and maintain a record of the training provided, including the dates that the training was provided and the number of individuals to whom it was provided; and
• ensure that training is provided on any changes to Club Monaco’ policies on an ongoing basis.

Required Legislative Compliance: January 1, 2015 2.     Information and Communication

Club Monaco is committed to making company information and communications accessible to persons with disabilities. Club Monaco will incorporate new accessibility requirements under the information and communication standards to ensure that its information and communications systems and platforms are accessible and are provided, upon request, in accessible formats that meet the needs of persons with disabilities.

        a.     Feedback, Accessible Formats and Communication Supports In accordance with the IASR, Club Monaco will:

• ensure that existing and new processes for receiving and responding to feedback are accessible to persons with disabilities by providing or arranging for the provision of accessible formats and communication supports, upon request and in a timely manner;
• more broadly, as a general principle where accessible formats and communication supports for persons with disabilities are requested:
• • provide or arrange for the provision of such accessible formats and communication supports;
  • consult with the person making the request to determine the suitability of the accessible format or communication support;
  • provide or arrange for the provision of accessible formats and communication supports in a timely manner that takes into account the person’s accessibility needs due to disability, and at a cost no more than the regular cost charged to other persons; and
• notify the public about the availability of accessible formats and communication supports.

Legislative Compliance Deadline:         January 1, 2015 – feedback         January 1, 2016 – accessible formats and communication supports. Accessible Websites and Web Content

While Club Monaco does not currently have any Ontario-based web sites, in accordance with the IASR, Club Monaco will work toward making any future Ontario-based websites and web content conform with the World Wide Consortium Web Content Accessibility Guidelines (WCAG 2.0) Level AA in the future.

3.     Employment        a.     Recruitment

Club Monaco is committed to fair and accessible employment recruiting practices that attract and retain employees with disabilities. This includes providing accessibility across all stages of the employment cycle.

In accordance with the IASR, Club Monaco will do the following:

Legislative Compliance Deadline: January 1, 2016

        b.    Informing Employees of Supports and General Provision of Accessible Formats and Communications Supports

In accordance with the IASR, Club Monaco will inform all employees of policies that support employees with disabilities, including, but not limited to, policies on the provision of job accommodations that take into account an employee’s accessibility needs due to a disability. This will include:

• informing current employees and new hires of Club Monaco’ policies supporting employees with disabilities, including, but not limited to, policies on the provision of job accommodations that take into account an employee’s needs due to disability;
• providing information as soon as practicable after the new employee begins employment, specifically in the orientation process;
• keeping employees up to date on changes to existing policies on job accommodations with respect to disabilities;
• where an employee with a disability so requests it, Club Monaco will provide or arrange for provision of suitable accessible formats and communications supports for:
• • information that is needed in order to perform the employee’s job;
  • information that is generally available to employees in the workplace; and
  • in meeting the obligations to provide the information that is set out above, Club Monaco will consult with the requesting employee in determining the suitability of an accessible format or communication support.

Legislative Compliance Deadline: January 1, 2016         c.    Documented Individual Accommodation Plans/Return to Work Process

Club Monaco will incorporate new accessibility requirements under the IASR 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.

Club Monaco’ existing policies and practices include steps that Club Monaco will take to accommodate employees with disabilities and to facilitate employees’ return to work after absence due to disability.

Club Monaco will review and assess existing policies to ensure that they include steps that Club Monaco will take to accommodate employees with disabilities and to facilitate employees’ return to work after absence due to disability. Club Monaco will also 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, Club Monaco will ensure that the process for the development of documented individual accommodation plans includes the following elements:

• information regarding the manner in which the employee requesting accommodation can participate in the development of the plan;
• information regarding the means by which the employee is assessed on an individual basis;
• information regarding the manner in which Club Monaco can request an evaluation by an outside medical or other expert, at Club Monaco’ expense, to assist Club Monaco in determining if and how accommodation can be achieved;
• steps to protect the privacy of the employee’s personal information;
• information regarding the frequency with which individual accommodation plans will be reviewed and updated and the manner in which this will be done;
• the reasons for a denial if an individual accommodation plan is denied;
• information regarding the means of providing the individual accommodation plan in a format that takes into account the employee’s accessibility needs;
• the following will be included if individual accommodation plans are established:
• • 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.

Club Monaco will ensure that the return to work process as set out in its existing policies outlines:

• the steps Club Monaco will take to facilitate the employee’s return to work after a disability-related absence;
• the development of a written individualized return to work plan for such employees; and
• the use of individual accommodation plans, as discussed above, in the return to work process.

Legislative Compliance Deadline: January 1, 2016         d.    Performance Management, Career Development and Redeployment Club Monaco will 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;
• when providing career development and advancement to employees with disabilities; and
• when redeploying employees with disabilities.

In accordance with the IASR, the Club Monaco will:

• review, assess and, as necessary, modify existing policies, procedures and practices to ensure compliance with the IASR;
• take the accessibility needs of employees with disabilities and, as applicable, their individualized accommodation plans, into account when:
• • assessing performance;
  • managing career development and advancement; and
  • redeployment is required.
• review, assess and, as necessary, include in performance management workshops, accessibility criteria;
• take into account the accessibility needs of employees with disabilities when providing career development and advancement to its employees with disabilities, including notification of the ability to provide accommodations on internal job postings; and
• take into account the accessibility needs of employees with disabilities when redeploying employees, including review and, as necessary, modification of employee transfer checklist.

Legislative Compliance Deadline: January 1, 2016 5.     Design of Public Spaces

While Club Monaco has no current plans to engage in new construction or significant redevelopment of its facilities at present, Club Monaco will meet the Accessibility Standards for all built obligations should any such construction take place in the future.

Club Monaco will put procedures in place to prevent service disruption to its accessible parts of public spaces. In the event of a service disruption, Club Monaco will notify the public of the service disruption and alternatives available.

Legislative Compliance Deadline: January 1, 2017 Information and Feedback

For more information on this accessibility plan or to provide feedback, please contact the Global People Practices at:

• Phone: Make a Difference Hotline (1-877-4POLORL)
• Email: [email protected]

All feedback including complaints, will be handled as quickly as possible. We will consider your comments carefully, as you can expect to hear from us within a reasonable period of time. Please understand that some inquiries may take longer to address.Club Monaco will be providing or arranging for accessible formats and communication supports, on request.