The Company recognizes that the Government of Ontario supports the full inclusion of persons with disabilities as set out in the Ontario Human Rights Code (the “Code”), and the Accessibility for Ontarians with Disabilities Act, 2005 (the “AODA”). It is the goal of the Ontario government to make Ontario accessible by 2025.

Under the AODA and its Regulations, the following accessibility standards set requirements that are applicable to The Company:

• Customer Service;
• Information and Communications;
• Employment; and
• Proposed Accessibility Standards for the Built Environment

COMMITMENT
The Company is committed to providing its goods and services in a way that respects the dignity and independence of persons with disabilities. This commitment will be integrated wherever possible and will ensure that persons with disabilities will benefit from the same goods and services, in the same place and in a similar way as other customers.

The Company is committed to ensuring that every Associate and customer receives equitable treatment with respect to employment and services, without discrimination, and receives accommodation where required, in accordance with the provisions of the Code and the AODA and its Regulations. The Company will meet the accessibility needs of persons with disabilities in a timely manner.

POLICY APPLICATION
This policy applies to all individuals entitled to the protections set out in the AODA and its regulations, including customers and Associates of The Company.

DEFINITION OF DISABILITY
The AODA defines “disability” as:

“Any degree of physical disability, 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 impediment, 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;

• a condition of mental impairment or a developmental disability,
• a learning disability, or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language,
• a mental disorder, or
• an injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997.”

Where required, The Company will consult with the disabled individual to understand his or her specific accessibility needs, and then make all reasonable efforts to meet those individual needs in a timely manner.

MEANS OF ACHIEVING THE COMPANY’S ACCESSIBILITY OBJECTIVES
This policy, related policies and DCL International Ltd. – Multi-Year Accessibility Plan outlines The Company’s., strategies and actions to prevent and remove barriers to accessibility and to meet the requirements under the AODA and its Regulations.

ACCESSIBLE FORMATS
All of the aforementioned documents are available in accessible formats upon request (In progress).

Action	Compliance Date	Responsibility	Status
PART 1 - GENERAL
Accessibility Policies * Develop and implement Integrated Accessibility Standards Policy. * Make the Policy publicly available and provide in an accessible format, upon request. * Review & update as required	Jan 1, 2014	Human Resources	Complete
Develop a multi-year accessibility plan * A Multi Year Accessibility Plan was developed. * Post multi-year accessibility plan on website and provide in an accessible format, upon request.	Jan 1, 2014	Human Resources	Complete
* Review and update the plan at least once every five years.	Jan 1, 2019	Human Resources, President, CEO & CFO	Plan to be reviewed and updated by Jan 1, 2019
Training * Ensure that training is developed on the IASR and the Human Rights Code as it pertains to persons with disabilities and is provided by Jan 1, 2015 to employees, volunteers, persons who participate in developing policies and others who provide goods, services or facilities on behalf of Ticketmaster Canada. Update training as required.	Jan 1, 2015 & Ongoing	Human Resources	Complete
PART 2- INFORMATION AND COMMUNICATION STANDARDS
Feedback processes *Ensure that processes for receiving and responding to feedback are accessible and meet the requirements of the IASR.	Jan 1, 2015 & Ongoing	Human Resources
Accessible formats and communication supports *Upon request, to the extent practicable, provide for provision of accessible formats and communication supports for persons with disabilities. * Consult with person making the request to determine suitability of accessible format or communication support. * Put a statement on the website that we shall, upon request, provide or arrange for the provision of accessible formats and communication supports for persons with disabilities at a cost no more than regular cost charged to other persons.	Jan 1, 2016 & Ongoing	Human Resources & Marketing Manager	In Progress
Emergency procedures, plans or public safety information * Emergency procedures, plans or public safety information, that is publicly available, shall be provided in an accessible format or with appropriate communication supports, upon request as soon as practicable.	Jan 1, 2012 & Ongoing	Human Resources & JHSC Team	Complete
Accessible websites and web content * Websites and web content published after 2012 to conform to WCAG 2.0 Level A initially and increasing to WCAG 2.0 Level AA by Jan 1, 2021 to the extent practicable other than criteria 1.2.4 (captions) and 1.2.5 (pre-recorded audio descriptions).	Beginning Jan 1, 2014 & ongoing through to Jan 1, 2021.	Marketing Manager	Complete
PART 3- EMPLOYMENT STANDARDS
Recruitment, Assessment, Selection * Review and update existing recruitment, policies, procedures and processes. * Specify that accommodation is available for applicants with disabilities on the website and on job postings. * Inform applicants about the availability of accommodations: when called for an interview, during the selection process, at the time of the job offer and as soon as practicable after the new employee begins – specifically at orientation. * If selected applicant requests accommodation, consult with the applicant and arrange for provision of suitable accommodation in a manner that takes into account the applicant's accessibility needs due to a disability.	January 1, 2016 & Ongoing	Human Resources	In Progress
Informing employees of supports * Inform current employees and new hires as soon as practicable after they begin employment of policies supporting employees with disabilities. * Keep employees up to date on changes to policies/procedures relating to accommodation.	January 1, 2016	Human Resources	In Progress
Performance management, career development, advancement and redeployment * Review and update existing policies, practices to ensure compliance with IASR * Take the accessibility needs of employees with disabilities and, as applicable, individual accommodation plans, into account as part of performance management processes, when assessing performance, providing career development & advancement opportunities and considering redeployment.	January 1, 2016	Human Resources	In Progress
Part 4- Design of Public Space Standards
Obtaining service – Make service counters, queuing guide and waiting areas accessible. * Where practicable, all indoor or outdoor newly constructed service counters and fixed queuing guides and all newly constructed or redeveloped waiting areas will conform to all of the required elements in accordance with the provisions of the IASR.	January 1, 2017	Human Resources, President, CEO, CFO	In Progress
Maintain the accessible parts of our public spaces. * Identify preventative and emergency maintenance procedures & alternatives & procedures for handling disruptions and alternatives in accordance with the provisions of the IASR.	January 1, 2017	Human Resources, President, CEO, CFO	In Progress
Make parking accessible * Where practicable, new and redeveloped parking areas meet certain technical requirements in accordance with the provisions of the IASR.	January 1, 2017	Human Resources, President, CEO, CFO	In Progress
Make exterior paths of travel accessible. * Where practicable, new and redeveloped exterior paths of travel that are outdoor sidewalks or walkways designed and constructed for pedestrian travel and are intended to serve a functional purpose (includes stairs, ramps, curb ramps, depressed curbs, pedestrian signals, rest areas) and not to provide a recreational experience meet certain technical requirements in accordance with the provisions of the IASR.	January 1, 2017	Human Resources, President, CEO, CFO	In Progress

Human Resources Policy
Integrated Accessibility Standards Policy
Effective January 1, 2014

Purpose

This policy outlines DCL International Ltd., commitment to and process by which the Company will achieve accessibility by meeting the phased in requirements of the Integrated Accessibility Standards Regulation, Ontario Regulation 191/11 under the Accessibility for Ontarians with Disabilities Act, 2005 (AODA).

Scope

This policy applies to:

1. Employees who deal with the public or other third parties on behalf of DCL International Ltd.
2. All persons who participate in the development of the Company policies, practices and procedures governing accessibility
3. Customers, Contractors/Subcontractors, Visitors, Applicants for employment that may require accommodation and any other third party providing good or services on the Companies behalf.

Responsibility

The President and the Human Resources Generalist must create an environment that provides accessibility and ensure that the company achieves compliance with the AODA legislation. All Employees must adhere to the established company policies.

Definitions

Accommodation – means the special arrangements made or assistance provided so persons with disabilities can participate in the experience available to persons without disabilities.

Disability – the term disability as defined by the Accessibility for Ontarians with Disabilities Act, 2005, and the Ontario Human Rights Code, refers to:

• any degree of physical disability, 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 impediment, 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;
• a condition of mental impairment or a developmental disability;
• a learning disability, or dysfunction in one or more of the processes involved in understanding or using symbols or spoken language;
• a mental disorder; or
• an injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997.

General Principles
In accordance with the Integrated Accessibility Standards, Ontario Regulation 191/11, this policy outlines the commitment of DCL International Ltd., to progress toward improved accessibility by meeting the phased in requirements of the Integrated Accessibility Standards Regulation, Ontario Regulation 191/11 under the Accessibility for Ontarians with Disabilities Act, 2005. DCL Ltd., herein details procedures to ensure we maintain compliance with all the standards under the AODA as they become law.

A. Commitment of DCL International Ltd., to achieve accessibility

• DCL International Ltd. 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 and meeting accessibility requirements under the Accessibility for Ontarians with Disabilities Act.
• DCL International Ltd. will make every reasonable effort to develop and maintain policies, practices and procedures that are consistent with the principles of dignity, independence, integration and equal opportunity. DCL International Ltd. will progress toward improved accessibility by meeting the phased in requirements of the Integrated Accessibility Standards Regulation, Ontario Regulation 191/11 under the Accessibility for Ontarians with Disabilities Act, 2005.
• DCL International Ltd. is committed to providing information to or communicating with a person with a disability and will endeavor to do so in a manner that takes into account the persons disability

B. Multi-year Accessibility Plan

• By January 1, 2014, DCL International Ltd. will develop a multi-year Accessibility Plan outlining the strategy to prevent and remove barriers and address the current & future requirements of AODA and the Integrated Regulation Standards.
• Action Plan:
  • Assess current policies, practices, procedures, premises, access to goods & services and information & communication systems to identify barriers to persons with disabilities.
  • Address the identified barriers and develop a five year plan for the removal and prevention of these barriers.
  • Update the plan every five years
  • Post on the company’s website the availability of the Accessibility Plan
  • Upon request provide the plan in an appropriate alternative accessible format in a timely manner and at a cost no more than the regular cost to other people.
  • Submit required information to the government as required.

C. Policies and Procedures to maintain compliance with the Integrated Standards under the AODA

• The Company will develop procedures to address “Information & Communication” and “Employment” as prescribed by the Integrated Accessibility Standards.

Information & Communication Jan 1, 2016

• DCL International Ltd. is committed to meeting the communication needs of people with disabilities. We will consult with people with disabilities to determine their information and communication needs.
• By January 1, 2016, DCL International Ltd. will provide accessible information and communications that take into account a person’s disability and post on the company’s website the availability of accessible formats and communication supports and provide them in a timely manner and at a cost no more than the regular cost to other people.
• New websites and web content will conform to WCAG 2.0 Level A (mandatory Jan 1, 2014)
• By January 1, 2021, all current websites & web content will conform to WCAG 2.0 Level AA.

Information – refers to knowledge, data and facts that convey meaning and that exist in any format such as text, audio, digital or images.
Exceptions - the Information and Communications Standard does not apply to the following:

1. Products and product labels, except as specifically provided by this Part.
2. Unconvertible information or communications.
3. Information that the obligated organization does not control directly or indirectly through a contractual relationship.

Feedback - The regulation only applies to organizations that have processes for receiving and responding to feedback. Organizations that do not have a feedback processes are not required to create such processes. Under the Customer Service Standard, DCL International Ltd. has establish a customer service feedback process for receiving and responding to feedback specifically about the manner in which they provide accessible goods or services to people with disabilities.

Employment Jan 1, 2016
Emergency Response

• The company will provide individualized workplace emergency response information to Employees who have disclosed a disability and with their consent, provide the workplace emergency response information to the person designated to provide them assistance.
• The individualized workplace emergency response information will be reviewed/revised,
  1. when the Employees moves to a different location in the organization;
  2. when the Employee’s accommodations needs change or plans are reviewed; and
  3. when the employer reviews its general emergency response policies.

Recruitment

• The Human Resources Generalist will specify that accommodation is available for job applicants with disabilities on the Company website and job advertisements
• The Human Resources Generalist will inform candidates, when called for an interview, during the selection process and in the job offer that accommodations are available upon request in relation to the materials or processes to be used.
• If a selected applicant requests an accommodation, the Human Resources Generalist will consult with the applicant and provide or arrange for the provision of suitable accommodation in a manner that takes into account the applicant’s accessibility needs due to disability.
• When making an offer of employment, the Human Resources Generalist will notify the successful applicant of its policies for accommodating employees with disabilities.
• The Human Resources Generalist will inform all Employee’s of DCL International Ltd. policies used to support its Employee’s with disabilities, including policies on the provision of job accommodations that take into account an Employee’s accessibility needs due to disability and will provide updated information to all Employees whenever there is a change to existing policies on the provision of job accommodations.
• Individualized Plans
  The Human Resources Generalist will:
  • - Develop individual accommodation plan for Employees with disabilities
  • - Develop a return to work process for Employees absent due to disabilities that require accommodation to return to work
  • - Ensure the accessibility needs and individual accommodation plan of the Employee are taken into account when assessing their performance, managing their career development, advancement and redeployment.

D. Training January 1, 2015
DCL International Ltd. will train Employees dealing with customers and the public on behalf of DCL International Ltd. or involved in development of related policies on the requirements of the Integrated Regulation Standards and the Ontario Human Rights Code as it relates to persons with disabilities. The Company will provide training to other Employees as appropriate to the duties of the Employee.

Training Components;

• Purpose of the Accessibility for Ontarians with Disabilities Act, 2005.
• Requirements of Accessibility Standards for Customer Service, Ontario Regulation 429/07.
• Requirements of the Integrated Accessibility Standards, Ontario Regulation 191/11.
• Applicable portions of the Ontario Human Rights Code, 1990 (disability related obligations)

Training Schedule:
Initial training will be completed by January 1, 2015. Training will be provided to new Employees or contract Employees who deal with the public, during orientation. Revised training will be provided in the event of changes to legislation, procedures and/or practices.

Record of Training:
The Human Resources Generalist will keep a binder of training that includes the dates training was provided and the number of employees who attended the training.

Accessible Formats of Documents & Communication Supports

• Upon request DCL International Ltd. will provide or arrange for the provision of information in an accessible format that takes into account the individual’s disability, in a timely manner and at a cost no more than the regular cost to other people. If the information is unconvertible, upon request, the Company will provide an explanation as to why it is unconvertible and provide a summary of the unconvertible information or communications.

Requesting Information or Providing Feedback:
Individuals may request an “AODA Feedback” form or may provide feedback verbally (in person or by telephone) or written (handwritten or email). Individuals that provide formal feedback will receive acknowledgement of their feedback, along with any resulting actions based on concerns or complaints that were submitted. If you have any questions, concerns or feedback regarding this policy or its related procedures please contact:

• Human Resources Generalist
• 905-660-6450 x238
• 241 Bradwick Drive, Concord, ON
• [email protected]

This policy and its related procedures will be reviewed as required in the event of legislative changes.

REFERENCES:

• Accessibility for Ontarians with Disabilities Act, 2005
• Integrated Accessibility Standards Ontario Regulation 191/11
• Ontario Human Rights Code, 1990