Accessibility Policy and Multi-Year Accessibility Plan

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 Ralph Lauren Canada LP (“Ralph Lauren”) establish, implement, maintain and document its accessibility policies and multi-year accessibility plan (the “Accessibility Plan”), which outlines Ralph Lauren’ 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 Ralph Lauren in Ontario, and, where indicated, to any independent contractors providing services on behalf of Ralph Lauren in Ontario. This policy reflects the company’s obligations as an employer with fewer than 50 employees in Ontario.  Should that change, this document will be updated accordingly.

Our Commitment

In fulfilling our mission, Ralph Lauren strives to treat all individuals in a manner that allows them to maintain their dignity and independence.  Ralph Lauren 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 Ralph Lauren’ 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 Ralph Lauren:

  • 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, Ralph Lauren is committed to providing exceptional customer service to all of its customers and clients. For more information, please refer to Ralph Lauren’Accessible Customer Service Policy
Accessible Emergency Information

Ralph Lauren is committed to providing the customers and clients with publicly available emergency information in an accessible way upon request. 
Ralph Lauren will also provide employees with disabilities with individualized emergency response information when necessary.
Integrated Accessibility Standards Regulations (IASR)
The following sets out how Ralph Lauren is committed to complying with the IASR.

  • Training

Ralph Lauren 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, Ralph Lauren 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 Ralph Lauren in Ontario, and persons participating in the development and approval of Ralph Lauren’ 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 Ralph Lauren’ policies on an ongoing basis.

Required Legislative Compliance: January 1, 2016

  • Information and Communication
  • Ralph Lauren is committed to making company information and communications accessible to persons with disabilities. Ralph Lauren 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.

    1. Feedback, Accessible Formats and Communication Supports

    In accordance with the IASR, Ralph Lauren 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, 2016 – feedback
    January 1, 2017 – accessible formats and communication supports.
    Accessible Websites and Web Content
    While Ralph Lauren does not currently have any Ontario-based web sites, in accordance with the IASR, Ralph Lauren 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. 

    • Employment

    a.  Recruitment
    Ralph Lauren 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, Ralph Lauren will do the following:

    • Recruitment General

    Ralph Lauren will notify employees and the public of the availability of accommodation for applicants with disabilities in the recruitment process. This will include:

    • review and, as necessary, modification of existing recruitment policies, procedures and processes;
    • specifying that accommodation is available for applicants with disabilities, on Ralph Lauren’ website and on job postings; and
    • Recruitment, assessment and selection

    Ralph Lauren will notify job applicants, when they are individually selected to participate in an assessment or selection process and inform them that accommodations are available upon request in relation to the materials or processes to be used in the assessment/selection process. This will include:

    • a review and, as necessary, modification of existing recruitment policies,  procedures and processes;
    • inclusion of availability of accommodation notice as part of the script in the scheduling of an interview and/or assessment; and
    • if a selected applicant requests an accommodation, a consultation with the applicant and arrangement for provision of suitable accommodations in a manner that takes into account the applicant’s accessibility needs due to the disability; and
    •   Notice to Successful Applicants

    When making offers of employment, Ralph Lauren will notify the successful applicant of its policies for accommodating employees with disabilities. This will include:

    • a review and, as necessary, modification of existing recruitment policies, procedures and processes; and
    • inclusion of notification of Ralph Lauren’ policies on accommodating employees with disabilities in offer of employment letters.

    Legislative Compliance Deadline: January 1, 2017

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

    In accordance with the IASR, Ralph Lauren 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 Ralph Lauren’ 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, Ralph Lauren 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, Ralph Lauren will consult with the requesting employee in determining the suitability of an accessible format or communication support.

    Legislative Compliance Deadline: January 1, 2017

    1. Documented Individual Accommodation Plans/Return to Work Process

    Ralph Lauren 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.
    Ralph Lauren’ existing policies and practices include steps that Ralph Lauren will take to accommodate employees with disabilities and to facilitate employees’ return to work after absence due to disability.
    Ralph Lauren will review and assess existing policies to ensure that they include steps that Ralph Lauren will take to accommodate employees with disabilities and to facilitate employees’ return to work after absence due to disability. Ralph Lauren 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, Ralph Lauren 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 Ralph Lauren can request an evaluation by an outside medical or other expert, at Ralph Lauren’ expense, to assist Ralph Lauren 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.

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

      • the steps Ralph Lauren 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, 2017

    1. Performance Management, Career Development and Redeployment

    Ralph Lauren 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 Ralph Lauren 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, 2017

    5.       Design of Public Spaces

    While Ralph Lauren has no current plans to engage in new construction or significant redevelopment of its facilities at present, Ralph Lauren will meet the Accessibility Standards for all built obligations should any such construction take place in the future.  
    Ralph Lauren will put procedures in place to prevent service disruption to its accessible parts of public spaces.  In the event of a service disruption, Ralph Lauren will notify the public of the service disruption and alternatives available. 
    Legislative Compliance Deadline: January 1, 2018

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

    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.

    Ralph Lauren will providing or arranging for accessible formats and communication supports, on request.