Accessibility Policy

This Accessibility Policy was last modified on May 5, 2025

Commitment Statement & Purpose

Peakhill Capital (Peakhill) is committed to identifying and meeting the accessibility needs of persons with disabilities in an effective, appropriate and timely manner, and to developing an inclusive, barrier-free environment, through compliance with the Accessibility for Ontarians with Disabilities Act, 2005 (“AODA”) and applicable provincial human rights legislation.

The purpose of this Policy is to set out the principles that guide Peakhill on our approach to accessibility for persons with disabilities through compliance with AODA and applicable human rights legislation.

Application and Scope

This Policy applies to all Peakhill employees (including persons who participate in developing Peakhill’s policies), volunteers and persons who provide goods, services or facilities on behalf of Peakhill.

Definitions

Terms set out in this Policy shall have the defined meaning set out in the AODA.

Requirements

1. Accessibility Policy & Commitment Statement

Peakhill will maintain this Policy to describe the principles that guide our path to accessibility as an organization and identify what Peakhill will do to meet the requirements of the AODA. This Policy is posted on our website. Upon request, Peakhill will provide a copy of this Policy in an accessible format.

2. Multi-Year Accessibility Plan

Peakhill has developed and will maintain a Multi-Year Accessibility Plan (the “Plan”) that outlines Peakhill ’s strategy to prevent and remove barriers from our workplace and meet its requirements under the Integrated Accessibility Standards. The Plan is outlined within this Policy and is posted on our website accordingly.

3. Provision of Service to Persons with Disabilities

Peakhill will provide its services and communicate with customers, members of the public and applicable third parties to whom we provide goods and services in a manner that takes into account a person’s disability and is compliant with the AODA and applicable human rights legislation.

Currently, Peakhill’s office premises are not open to the public. Where Peakhill welcomes invited guests or service providers to Peakhill’s offices who are accompanied by a service animal or a support person, Peakhill will accommodate access to the extent permitted by law. Further, in the event of a planned or unexpected disruption in services accessed by persons with disabilities in the future, Peakhill will comply with the AODA requirements in respect of notice of a temporary disruption, if applicable.

4. Training

Peakhill will provide relevant and applicable accessibility and disability-related human rights training to employees, volunteers and persons who participate in the development of Peakhill’s policies on accessibility.

Training will be provided as soon as practicable for existing employees and will be included as part of orientation for all new hires. Peakhill will also provide training, on an ongoing basis, with respect to changes made to this Policy, if any.

Records of the training provided will be maintained and will include: (i) the dates on which training was provided and (ii) the number of individuals to whom training is provided.

Where third parties are engaged to perform services in Ontario on behalf of Peakhill, we may require that such third parties provide an acknowledgment that their principals, employees, agents and volunteers receive any applicable training required by the AODA.

5. Information and Communications

Feedback:

Peakhill is committed to establishing and maintaining a process for receiving and responding to feedback about accessibility for persons with disabilities. Feedback regarding accessibility issues can be made to Peakhill by sending an email to [email protected]. Inquiries will be addressed as soon as practicable after receipt.

Peakhill will continue to ensure that our processes for receiving and responding to feedback are accessible to persons with disabilities by providing, or arranging for the provision of, accessible formats and communications supports, upon request.

Accessible formats and communication supports:

Upon request, Peakhill will provide or arrange for the provision of accessible formats and communication supports for persons with disabilities, including employees, in a timely manner that takes into account each person’s accessibility needs due to disability and (if applicable) at a cost that is no more than the regular cost charged to other persons. Peakhill will consult with the person making the request for an accessible format or communication support when determining the suitability of an accessible format or communication support. Peakhill will continue to advise the public about the availability of accessible formats and communication supports with respect to its feedback processes through a notification on our company website.

Accessible websites and web content:

Peakhill will ensure that any websites that our Ontario entity controls directly or through a contractual relationship that allows the Ontario entity to modify the content, including web content, on such sites, conform with the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0, except where meeting the requirement(s) is not practicable.

6. Employment

Peakhill’s policies and practices are intended to build an inclusive and accessible work environment that is free from discrimination and harassment on the basis of disability.

Recruitment and Hiring:

In our recruitment processes, Peakhill will advise our employees and the public about the availability of accommodation for applicants with disabilities. Peakhill will notify job applicants, when they are individually selected to participate further in an assessment or selection process, that accommodations are available upon request in relation to the materials or processes to be used and will work with the applicant to address any requests for accommodation up to the point of undue hardship.

Informing Employees of Supports:

We will notify our employees of Peakhill’s policies (and any updates to those policies) for supporting employees with disabilities, including our policies regarding the provision of job accommodation that take into account an employee’s accessibility needs due to disability to the point of undue hardship. This information will be provided to new hires as soon as practicable after they commence employment.

Workplace Emergency Response Information:

Peakhill will provide individualized workplace emergency response information to employees with disabilities where the disability is such that individualized information is necessary and Peakhill is aware of the need for accommodation. Where an employee who receives individualized workplace emergency response information requires assistance, Peakhill will designate a person to provide assistance and, with the employee’s consent, Peakhill will provide the workplace emergency response information to such person.

Peakhill will review individualized workplace emergency response information, at minimum, whenever the employee moves to a different location within Peakhill, the employee’s overall accommodation needs or plans are reviewed, or Peakhill reviews its general emergency response policies.

Documented Individual Accommodation Plans:

Peakhill will develop and maintain a written process for the development of documented individual accommodation plans for employees with disabilities. If requested, information regarding accessible formats and communications supports provided will also be included in individual accommodation plans. Additionally, the plans will include individualized workplace emergency response information (where required). Plans will also identify any other accommodation that is to be provided. Where an individualized accommodation plan is required, employees should contact People and Culture department to engage that process.

Return to Work Process:

Peakhill will develop and maintain a documented return to work process for its employees who have been absent from work due to a disability and who require disability-related accommodation in order to return to work. The return-to-work process will, as part of the process, outline the steps that Peakhill will take to facilitate the return to work and include documented individual accommodation plans. We note that this return-to-work process will not replace or override any other return to work process created by or under any other statute (for example, the Workplace Safety Insurance Act, 1997).

Performance Management, Career Development and Advancement & Redeployment:

Peakhill will consider 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.

 

 

Appendix – Multi-Year Accessibility Plan

As of the date of this Policy, Peakhill has achieved compliance with the applicable provisions and requirements of the AODA. Going forward, Peakhill will:

  1. Continue to train employees on AODA and applicable human rights legislation as it pertains to disability matters
  2. Continue to ensure compliance with web accessibility requirements
  3. Monitor and respond to feedback on accessibility matters
  4. Respond to accessibility-related requests, including in respect of the provision of information and communication supports and workplace accommodations
  5. Continue to evolve and update our Accessibility Policy and this Multi-Year Plan based on updated rules and regulations; in addition to feedback