Accessibility For Ontarians With Disabilities (AODA) Policy and Plan
Accessibility Policy And Multi-Year Accessibility Plan
This Accessibility Policy and Multi-Year Accessibility Plan outline the actions that Mylan Pharmaceuticals ULC and BGP Pharma ULC (“Mylan”) has and will put in place to improve accessibility and opportunities for people with disabilities in accordance with the Accessibility for Ontarians with Disabilities Act, 2005 (“AODA”) and its associated regulations, including the Accessibility Standards for Customer Service (“SCS”) and the Integrated Accessibility Standards (“IAS”). The Accessibility Plan will be reviewed every five years.
*This Policy does not replace existing legal obligations under the Human Rights Code R.S.O. 1990, c. H.19, as it may be amended from time to time, or any other applicable laws respecting the accommodation of persons with disabilities.
STATEMENT OF COMMITMENT
Mylan is committed and guided by the four core principles of Dignity, Independence, Integration and Equal Opportunity and supports the full inclusion of persons as set out in the Canadian Charter of Rights and Freedoms, and the AODA.
We are committed to meeting the needs of persons with disabilities in a timely manner, and will do so by preventing and removing barriers to accessibility and meeting accessibility requirements under the AODA, SCS and IAS.
GENERAL ACCESSIBILITY STANDARDS
Training
Mylan will ensure that training is provided on the requirements of the accessibility standards
referred to in the IAS and on the Human Rights Code as it pertains to persons with disabilities to:
(a) all employees, and volunteers;
(b) all persons who participate in developing the organization’s policies; and
(c) all other persons who provide goods, services or facilities on behalf of the organization
The training on the requirements of the accessibility standards and on the Human Rights
Code shall be appropriate to the duties of the employees, volunteers and other persons.
The training will be provided as soon as practicable after the employee is hired, and Mylan will provide training in respect of any changes to the policies pursuant to the IAS on an ongoing basis. Mylan will keep a record of the training provided, including the dates on which the training is provided and the number of individuals to whom it is provided.
Emergency procedure, plans or public safety information
Emergency procedures, plans or public safety information made available to the public will be provided in an accessible format or with appropriate communication supports, as soon as practicable, upon request.
Self-Service Kiosks
Alternate arrangements for on-site registration of visitors and contractors will be made when the use of the self-serve registration kiosk is not an accessible format for registration for the visitor or contractor.
Service Animals
Service animals are welcome on the parts of our premises where the public or third parties have access to the premises, except in areas prohibited by law or in Good Manufacturing Practice (GMP)/Good Laboratory Practice (GLP) restricted areas (such as in the laboratory and warehouse areas of Mylan). Where such a case arises, alternate arrangements will be arranged, i.e. teleconference or the use of a support person.
Support Persons
If a support person accompanies a person with a disability, both parties are permitted to enter Mylan’s premises together, and that the person with a disability is not prevented from having access to the support person. Mylan may require a person with a disability to be accompanied by a support person when on the organization's premises, but only if a support person is necessary to protect the health and safety of the person with a disability, or the health and safety of others on the premises. Access will be in accordance with normal security procedures. Support persons may be paid professional support workers, volunteers, family members, or friends.
Assistive Devices
All assistive devices are permitted in all areas where it is safe to use them. Examples of areas that may be unsafe include the rooftop and areas requiring electrical devices to be rated as intrinsically safe.
Examples of assistive devices include wheelchairs, canes, walkers, oxygen tanks, scooters, listening devices, and magnification devices. This list is not all inclusive. Assistive devices are not provided to the general public by Mylan.
However, assistive devices required by an employee with a disability to perform his or her duties, will be provided. These types of assisted devices include modifications to technology (i.e. voice recognition software, alternate mouse choices, screen-reading software, telephones equipped with telecommunications devices for persons who are deaf, deafened or hard of hearing, etc.). Medical documentation of the need for a company issued assistive device may be required and, if so required, it should be provided to Human Relations.
Temporary Disruptions
Advance notice of planned disruptions in services, facilities or systems offered to individuals with a disability will be provided. Examples of planned disruptions include preventative or routine maintenance.
If there is an unexpected disruption due to a power failure or system failure, notice will be provided as soon as possible after the disruption is identified.
In both cases, a notice indicating the reason for the disruption and its anticipated duration will be posted in a conspicuous place on the premises of the company, by posting it on Mylan’s website, or by such other method as is reasonable in the circumstances. This notice will also describe any alternative services, facilities, or systems put in place for the duration of the disruption.
INFORMATION AND COMMUNICATION STANDARDS
Telephone Services
Mylan is committed to providing accessible telephone service. We train our staff to communicate with people over the telephone in clear and plain language, and to speak clearly and slowly.
Mylan will offer to communicate by mail or electronic mail if telephone communication is not suitable to the needs of a person with disabilities.
Accessible Formats and Communication Supports
Upon request, Mylan will provide or arrange for the provision of accessible formats and communication supports for persons with disabilities in a timely manner. Mylan will consult with the individual making the request to determine the suitability of an accessible format or communication support, which may include, but are not limited to, the spoken word, accessible electronic format, accessible audio formats, and large print.
If Mylan is unable to convert the information or communications into an accessible format, Mylan will provide the requester with an explanation as to why the information or communication are unconvertible and a summary of the unconvertible information or communications.
Websites
Mylan will take reasonable steps to ensure that all websites controlled by Mylan, and content on those sites published after January 1, 2012 (other than live captions and pre-recorded audio descriptions), conform with WCAG 2.0, Level AA by January 1, 2021, except where meeting the requirement is not practicable.
Feedback Process
Mylan will ensure that the 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.
Feedback for receiving and responding to feedback about the manner in which Mylan provides goods or services to persons with disabilities may be provided in person, by telephone, in writing, or by delivering an electronic text by email or on diskette or otherwise.
EMPLOYMENT STANDARDS
Recruitment
Mylan shall notify its employees and the public about the availability of accommodation for applicants with disabilities in its recruitment processes.
Recruitment, Assessment or Selection Process
During a recruitment process, Mylan will notify job applicants, when they are individually selected to participate in an assessment or selection process, that accommodations are available upon request in relation to the materials or processes to be used.
If a selected applicant requests an accommodation, Mylan will consult with the applicant and provide or arrange for the provision of a suitable accommodation in a manner that takes into account the applicant’s accessibility needs due to disability.
Notice to Successful Applicants
When making offers of employment, Mylan will notify the successful applicant of its policies for accommodating employees with disabilities.
Informing Employees of Supports
Mylan will inform its employees of its policies used to support its 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 disability. Mylan will provide this information to new employees as soon as practicable after they begin their employment.
Mylan will provide updated information to its employees whenever there is a change to existing policies on the provision of job accommodations that take into account an employee’s accessibility needs due to disability.
Accessible Formats and Communication Supports for Employees
Upon request by an employee with a disability, Mylan will consult with the employee to provide or arrange for the provision of accessible formats and communication supports for (a) information that is needed in order to perform the employee’s job, and (b) information that is generally available to employees in the workplace.
Mylan will consult with the employee making the request in determining the suitability of an accessible format or communication support.
Individualized Workplace Emergency Response Information (IWERI)
Mylan will provide IWERI to employees who have a disability, if the disability is such that the individualized information is necessary, and if Mylan is aware of the need for accommodation due to the employee’s disability (i.e., the employee will be required to disclose the need to Human Relations).
If an employee who receives IWERI requires assistance and with the employee’s consent, Mylan will provide the workplace emergency response information to the person designated by Mylan to provide assistance to the employee. Mylan will provide the information required as soon as practicable after Mylan becomes aware of the need for accommodation due to the employee’s disability.
Mylan will review the individualized workplace emergency response information, (a) when the employee moves to a different location in the organization; (b) when the employee’s overall accommodations needs or plans are reviewed; and (c) when Mylan reviews its general emergency response policies.
Documented Individual Accommodation Plans
Mylan will develop and put in place a written process for the development of documented individual accommodation plans for employees with disabilities.
If requested, individual accommodation plans shall include any information regarding accessible formats and communication supports provided. In addition, the plans will include individualized workplace emergency response information (where required), and will identify any other accommodation that is to be provided.
Return to Work Process
Mylan will develop and have in place a documented return to work process for its employees who have been absent from work due to a disability and require disability-related accommodations in order to return to work. The return to work process will outline the steps Mylan will take to facilitate the return to work of employees who were absent because their disability required them to be away from work and will use documented individual accommodation plans as part of the process.
The return to work process does not replace or override any other return to work process created by or under any other statute.
Performance Management, Career Development and Advancement & Redeployment
Mylan will take into account 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.
CONTACT
Contact Information
For any questions about our accessibility policy and multi-year accessibility plan, you may contact us by:
- phone: 416.236.2631
- e-mail: aoda@mylan.ca
- fax: 416-236-6059
- mail, or in person at:
85 Advance Road
Etobicoke, Ontario
M8Z 2S6
Attention: Director, Human Resources
Accessible/alternative formats of this document are also available upon request.
MULTI-YEAR ACCESSIBILITY PLAN
By January 1, 2012
- Update Statement of Human Rights to include AODA Policy and the Standards for Customer Service Policy.
- Develop and provide training, on an ongoing basis, in accordance with s. 6 of the AODA Standards for Customer Service to Customer Service, Reception, and Ontario Sales Reps.
- Take reasonable steps to ensure emergency procedures, plans or public safety information can be provided in an alternate accessible format upon request.
- Take reasonable steps to ensure emergency response information can be provided in an alternate accessible format upon request.
- Update Accessibility Policy in Statement of Human Rights to include requirements of IAS (Integrated Accessibility Standards regulation).
- Implement, Review and Update Multi-Year Accessibility Plan at least once every five years. Post Multi-Year Accessibility Plan on Mike Canada and Mike-EHS pages.
- Make the Accessibility Policy and Plan publicly available, and have these documents available in an accessible format upon request.
- Provide Training, on an ongoing basis, to employees, volunteers, and other staff members who provide goods, services or facilities on behalf of Mylan, on the requirements set out in the Integrated Accessibility Standards and on the Ontario Human Rights Code as it relates to people with disabilities, in accordance with the requirements of the IAS.
- Take reasonable steps to ensure that Mylan’s existing feedback processes are accessible to people with disabilities upon request Provide customers and clients with publicly available emergency information in an accessible way upon request. Provide individualized workplace emergency response information to employees with disabilities if Mylan is made aware of the need for accommodation.
- Take reasonable steps to ensure that all new websites controlled by Mylan, and content on those sites published after January 1, 2012, conform with WCAG 2.0, Level A, except where meeting the requirement is not practicable.
- Set up standing meetings with the AODA committee to make plans for the requirements for 2016.
- Set up meetings with Marketing and IT Q1 to help them prepare for 2016 and beyond.
- Prepare for provision of information and communication in accessible formats and with communication supports, including the notification to the public about the availability of accessible formats and communication supports.
- Review the IAS Employment Standard requirements and update Accessibility Policy in Statement of Human Rights to include Information and Communications Standard and Employment Standard requirements not previously included.
- Prepare to implement the IAS Employment Standards requirements including:
- Notifying the public and staff that, when requested, it will accommodate people with disabilities during the recruitment and assessment processes and when people are hired;
- Developing and putting into place a process for developing individual accommodation plans for employees with disabilities and putting individual accommodation plans into place as necessary;
- Developing and putting into place a return to work process for employees who have been absent from work due to a disability and require disability-related accommodations in order to return to work; and
- Ensuring the accessibility needs of employees with disabilities are taken into account if using performance management, career development and advancement, or redeployment processes.
- Provide training to all employees on support systems. Include accessible formats and communication supports.
- Items 3, 4, 5, 6, as above (2015) to be implemented.
- Mylan will meet the Design of Public Spaces Standards when building or making major modification to its public spaces.
- Take reasonable steps to ensure all internet websites controlled Mylan, and the web content on those sites published after January 1, 2012 (other than live captions and prerecorded audio descriptions), conforms with WCAG 2.0 Level AA by January 1, 2021.