Trans-Northern Pipelines Inc. (TNPI) is committed to identifying, removing, and preventing barriers which may impede or hinder any person from accessing our programs, goods, services, or facilities as the result of a disability. The goal is for TNPI to achieve accessibility through meeting our requirements under the Accessible Canada Act (the “ACA”).
Our Accessibility Plan (the “Plan”) outlines the steps TNPI is taking to meet all relevant ACA requirements and to improve accessibility for people with disabilities.
Although regulations are in place, there are some details under the ACA which have not yet been clearly defined (i.e. requirements for Web Content Accessibility Guidelines). As a result, TNPI has enlisted the expertise of professional accessibility consultants, all of whom are persons with disabilities. Canadian Accessibility Professionals (formerly Accessibility Professionals of Ontario) brings lifetimes of lived experience to their work. As accredited members of the Rick Hansen Foundation Accessibility Certification Program, they are among the leaders in the country when it comes to guiding organizations on a path to true accessibility and inclusion. TNPI is also pleased to work with Canadian Accessibility Professionals to create a full and comprehensive set of accessibility policies and procedures to ensure our staff are completely aware of our organization’s obligations under the ACA, including how to recognize and remove barriers to persons with disabilities.
TNPI is committed to a plan and documentation which reflects the spirit of the ACA. A process will be implemented enabling the Senior Management Team to respond to feedback regarding the manner in which TNPI is implementing this Plan going forward, including any barriers or accessibility issues encountered by employees, clients, stakeholders, contracted representatives, and the general public. When an area of improvement has been suggested regarding accessibility, the appropriate representatives of TNPI will review the information and make every effort to address the suggestion in a manner satisfactory to all parties, without causing undue hardship to the organization.
Nadia Zorzi, Team Lead, HR Operations, is designated to receive feedback on behalf of TNPI with respect to accessibility matters and this Plan.
The public is invited to communicate with TNPI in one of the following ways:
- Email: [email protected]
- Mail: 45 Vogell Road, Suite 310, Richmond Hill, ON L4B 3P6
Alternatively, the Feedback Form may be completed and sent to [email protected]. Information about TNPI’s Feedback Process can be found in Schedule A and the Feedback Form can be found in Schedule B.
The Act will be implemented in recognition of, and in accordance with, the following principles:
- All people must be treated with dignity, regardless of their disabilities or circumstance.
- All people must have the same opportunity to make for themselves the lives that they are able and wish to have.
- All people must have barrier-free access to full and equal participation in society.
- All people must have meaningful options and be free to make their own choices, with support if needed.
- Policies, programs, and structures will consider the disabilities of people and the different ways that they interact with their environments.
- People with disabilities must be involved in the development and design of policies, programs, services, and structures.
- The development and revision of accessibility standards and the making of regulations must be done with the objective of achieving the highest level of accessibility and inclusion for everyone.
Barrier means anything physical, architectural, technological, or attitudinal, including information or communications or anything that is the result of a policy or a practice – that hinders the full and equal participation in society of people with an impairment, including a physical, intellectual, cognitive, learning, communication, or sensory impairment of a functional limitation.
Disability means any impairment, including a physical, intellectual, cognitive, learning, communication, or sensory impairment – or a functional limitation – whether permanent, temporary, or episodic in nature, or evident of not, that, in interaction with a barrier, hinders a person’s full and equal participation in society.
Areas Described under Section 5 of the Accessible Canada Act (ACA)
TNPI is committed to identifying, removing, and preventing barriers in the following areas, as described in section 5 of the ACA:
- The built environment.
- Information and communication technologies (ICT).
- Communication, other than information and communication technologies.
- The procurement of goods, services, and facilities.
- The design and delivery of programs and services (if applicable); and
- Transportation (if and when it becomes applicable.
The following sections aim to describe how TNPI will fulfill this commitment.
TNPI is dedicated to creating a culture of true accessibility throughout the organization, including employment practices which are equitable and as accessible as possible.
TNPI is implementing an Accessibility Policy, including many elements of this Plan and direct action to promote its concrete impact within the organization. This policy will align with our current company standards, including:
Workplace Violence and Harassment Prevention Policy
This policy promotes a workplace that is respectful, preventing barriers that are discriminatory, unsafe, or violent in nature.
Flexible Work Policy
A significant number of employees are working remotely at this time on a regular basis. TNPI is flexible with remote-work arrangements, and this helps to remove and prevent barriers for people with disabilities at work.
Recruitment and Selection
Job postings continue to reference our commitment to providing equal opportunities to all candidates and to meeting the needs of people with disabilities in an agreed upon manner.
Candidates invited to participate in the interview process will be advised that if they require an accommodation, we will work with them to meet their needs.
Employment agreements will indicate that TNPI can engage in an accommodation process for any employee who requests it and comply with its legal obligations in this context.
b) Built Environment
TNPI will work with Canadian Accessibility Professionals to assess our current physical locations and workspaces. Additionally, we may call upon Canadian Accessibility Professionals to assist in the pursuit or procurement of any additional office or workspace. The goal is to ensure that any physical spaces under TNPI’s operational control is as accessible and inclusive as possible, in line with the Canadian Standards Association’s accessibility guidelines, and any applicable Provincial accessibility codes. The CSA accessibility guidelines represent the baseline for any Rick Hansen Accessibility Certification Program rating. In the spirit of maintaining an inclusive environment wherever possible, TNPI will continue to work with people with disabilities to achieve barrier-free design and construction whenever any modifications to our offices or workspaces are proposed.
c) Information and Communication Technologies (ICT)
New or significantly refreshed content of all websites and other digital properties owned by TNPI will be compliant with the current requirements of the ACA. Although a target has not yet been specified in the relevant regulations, achieving, and maintaining WCAG (Web Content Accessibility Guidelines), 2.1 Level AA will be considered as our minimum goal.
d) Communication, Other than ICT
TNPI will use accessible communication strategies to provide information for people with disabilities. Communication between TNPI and its employees, clients, stakeholders, contracted representatives and the public will be conducted in a manner that considers a person’s Disability.
Employees will work with any person with a Disability to determine the appropriate form of communication that meets their individual needs.
Alternate formats may include, for example:
- Print/large print
e) Procurement of Goods, Services and Facilities
TNPI will consider accessibility a top priority during the procurement of goods, services, and facilities, as required or is reasonably possible.
f) Design and Delivery of Programs and Services (if applicable)
TNPI will take accessibility into consideration when designing or modifying any programs or processes related to service delivery.
This section of the ACA does not apply to TNPI.
TNPI has retained the services of Canadian Accessibility Professionals, a widely recognized organization made up entirely of people who live with disabilities, to create our Accessibility Plan and Policy. TNPI will continue to consult with people with disabilities on an ongoing basis to ensure equal access to our goods, services, or facilities.
TNPI will train employees on the requirements of the ACA and the newly developed policies. New employees will be trained within 3 months of their start date. Employees will be trained on any changes or updates to these policies, practices, and procedures as soon as possible upon implementation.
TNPI will prepare and publish progress reports respecting the implementation of our Accessibility Plan, as required by the ACA. Feedback received by TNPI will be addressed in the progress reports, including how the feedback was taken into consideration.
TNPI will review and update our Accessibility Plan every 3 years.
Schedule A: Feedback Process
- The party initiating the feedback is welcome to include their name, or it can be provided anonymously by email, mail, phone, or via the Feedback Form. If feedback is submitted anonymously, TNPI may not be able to acknowledge receipt.
- A representative of TNPI will contact the party initiating the feedback, if applicable, and discuss the feedback using a manner that considers the accessibility concerns identified in the feedback.
- If the feedback necessitates escalation, the Feedback Form will be distributed to TNPI Senior Officers for review.
- TNPI will consider the feedback and review the underlying accessibility concerns and Barriers it identifies.
- TNPI will consider changes to eliminate these, barriers.
- Appropriate changes will be implemented, where applicable, to address any relevant accessibility concerns.
- When appropriate, Employees, clients, stakeholders, contracted representatives and/or the public will be informed of changes applicable to the relevant parties.
- A representative of TNPI will contact the party having initiated the feedback to advise of the steps taken to improve accessibility, where applicable. Where no Barriers have been identified or no steps are taken, for any reason, TNPI will still communicate with the party having initiated the feedback to conclude the feedback conversation.
Schedule B: Feedback Form
The Schedule B: Feedback Form can be downloaded here.