The purpose of this Policy is to establish how Monsanto Canada Inc. ("Monsanto") will provide access to goods or services to the public and other third parties that do business with Monsanto (“Customers”) with disabilities in a manner that is consistent with the principles of independence, dignity, integration and equality of opportunity, and that is in compliance with Ontario Regulation 429/07 (the “Customer Service Standard”) under the Accessibility for Ontarians with Disabilities Act (“AODA”).
Monsanto recognizes the importance of:
- Providing access to goods and services for individuals with disabilities;[i]
- Openly communicating and responding to the needs of Customers with disabilities in order to provide them with excellent customer service; and
- Complying with the mandatory Customer Service Standard addressed under the AODA.[ii]
This Policy applies to all Monsanto employees and contractors, including but not limited to senior management, managers, supervisors, full-time employees, part-time employees, off-site employees, in-store employees, telephone support employees, website support staff, students, apprentices and volunteers (“Employees and Contractors”).
Employees and Contractors will communicate with Customers with disabilities in a manner that takes into account their disabilities. Employees and Contractors will consider how a Customer’s disability may affect the way that he or she expresses, receives or processes communications and, where possible, they will ask the Customer how to best communicate with him or her.
Assistive devices that may be used by individuals with disabilities will be welcome on Monsanto premises open to the public or other third parties, including but not limited to canes, crutches, walkers, wheelchairs, scooters, oxygen tanks, screen readers, listening devices, speech amplification devices, magnification devices, note-taking devices, and communication boards. Monsanto will take steps to ensure that Employees and Contractors are familiar with such assistive devices.
Monsanto welcomes guide dogs[iii] or other animals that serve[iv] individuals with disabilities in those areas of Monsanto's premises that are open to Customers and will permit the Customer to keep the service animal with him or her, except for those animals that are otherwise excluded by law from the premises. In the event that a service animal is otherwise excluded by law from the premises, Monsanto will provide the applicable Customer with an alternative method of obtaining, using or benefitting from its goods or services.
Monsanto welcomes persons who support individuals with disabilities to accompany them onto Monsanto premises open to the public or other third parties. Monsanto will ensure that Customers who so require have access to their support persons while on the premises.[v] Such support persons need not be paid, professional support workers. They may be volunteers, family members or friends who provide support to the Customer. Support persons will be asked to follow any rules or requirements that are specific to the goods or services provided by Monsanto. Monsanto will seek the consent of the Customer before confidential information is discussed in front of the support person. Monsanto will require a support person to accompany a Customer when on the premises when it determines that such an arrangement is necessary to protect his or her health and safety or that of others on the premises.
Temporary Unavailability of Access to Goods or Services for Customers with Disabilities
In the event that a facility, service or system offered by Monsanto to Customers with disabilities[vi] is expected in advance to become temporarily unavailable, in whole or in part, Monsanto will provide advance notice of the disruption at the entrance to its premises and by the service or facility, at a reasonable time in advance of the disruption and during the disruption. If the disruption is unexpected, the notice will be provided as soon as the anticipated disruption becomes known to Monsanto. The notices will:
- Explain the reason for and anticipated length of the disruption[vii]; and
- Provide a description of and indicate the location of an alternative facility or service that is accessible to individuals with disabilities, if available.
All Employees and Contractors who interact with Customers on Monsanto's behalf or who are involved in developing Monsanto's policies, practice and procedures on the provision of goods and services will:
· Be provided with an overview of the AODA and the Customer Service Standard;
· Be trained how to interact, communicate and assist people with disabilities, and in particular, people with assistive devices and those who require the assistance of a guide dog, service animal or support person;
· Be made aware of the policies and procedures created by Monsanto in accordance with the Customer Service Standard; and
· Be trained how to help a person with a disability who is having difficulty accessing Monsanto's goods or services.
This training will also be provided on an ongoing basis as soon as practicable:
- To Employees and Contractors who, after January 1, 2012, are assigned duties that include interaction with Customers on Monsanto's behalf or who are involved in developing Monsanto's policies, practices and procedures on the provision of goods and services; and
- Whenever Monsanto's policies change with respect to customer service accessibility for individuals with disabilities, to all Employees and Contractors who interact with Customers on Monsanto's behalf or who are involved in developing Monsanto's policies, practices and procedures on the provision of goods or services.
Monsanto will keep a log of all of the training it will provide documenting who was trained, on what and when.
Customer Access to This Policy and Related Documents
A notice advising customers how they can request a copy of this Policy and all related documents will be posted on the Monsanto website and at the entrance to its premises. Monsanto will strive to provide Customers with disabilities who request a copy of this Policy with a format that takes into account their disability.
Monsanto invites feedback on the way that it provides goods or services to individuals with disabilities. Those who wish to provide such feedback are encouraged to do so:
· In person;
· By telephone;
· In writing;
· Via email;
All feedback will be directed to the Monsanto Canada ESH Lead or Monsanto Canada Law Lead. Any feedback that is in the nature of a complaint should be addressed to:
Monsanto Canada Inc.
900 One Research Rd.
The details of this Feedback Process will be provided on the Monsanto Canada website and in a notice that will be posted at the entrance to Monsanto's premises in Ontario.
[i] The definition of disability under the AODA is the same as the definition of disability in the Ontario Human Rights Code. The definition includes disabilities that vary in severity, some that are visible and others that are not as well as those the effects of which may come and go.
[ii] The AODA became law in 2005, and is intended to implement and enforce mandatory accessibility standards in Ontario, with the goal of increasing access to goods or services for individuals with disabilities. Under the AODA, the Ontario government will create mandatory standards in 5 key areas, including:
1. Customer Service
2. Information and Communications
5. Built Environment
The "Customer Service" area of regulation is addressed in the Customer Service Standard, and deals with the customer service aspects of offering goods or services to customers who have various disabilities; it was passed in 2008, and the public sector had to comply with this regulation by January 1, 2010. Private sector organizations must comply with the Customer Service Standard by January 1, 2012. In doing so, they must implement a Policy such as this one.
[iii] The Customer Service Standard defines a “guide dog” as a guide dog as defined in section 1 of the Blind Persons’ Rights Act.
[iv] The Customer Service Standard provides that an animal is a “service animal” (a) if it is readily apparent that the animal is used by the person for reasons relating to his or her disability; or (b) if the person provides a letter from a physician or nurse confirming that the person requires the animal for reasons relating to the disability.
[v] If the provider charges an admission fee for admission to its premises, the Policy must clearly state how this will be handled with reference to support persons. The Customer Service Standard does not require that support persons be admitted for free or at a reduced admission price. This is left to the discretion of the provider. If there is an admission fee the provider may wish to waive it in relation to support persons (so that a individual with a disability will not have to pay two admission fees), charge support persons only a percentage of the admission fee, or charge support persons the same admission fee that applies to everyone entering the premises. The Policy must indicate that customers will be notified in advance of how admission fees will be handled in relation to support persons (e.g., through a notice posted at the entrance to the premises and/or on the Provider’s website).
[vi] For example, a ramp, escalator, elevator, accessible washroom, amplification system, note-taking or TTY (Telephone Teletype) services.
[vii] For example, repair or scheduled maintenance for an anticipated duration of two days.