Accessibility Policy

Overview and Statement of Organizational Commitment

Mackenzie Financial Corporation (the “Company”) is committed to providing access to the Company’s financial products and services to individuals with disabilities in a timely manner, consistent with the requirements of the Accessibility for Ontarians with Disabilities Act, 2005 (collectively, the “AODA”) as well as the Accessibility for Manitobans Act, 2013 (collectively, the “AMA”).

This Policy specifically addresses the requirements of AODA and AMA and describes how the Company will comply with those requirements and what individuals may expect from the Company. These requirements do not replace or limit any requirements that have been established under human rights or other legislation.

The Policy applies to every person who works with and deals with the public (including third parties) on behalf of the Company, regardless of their location.

The Policy is meant to benefit individuals with a wide range of disabilities, as defined below. Whether a person’s disability is apparent or not, all individuals shall be treated with dignity, courtesy and have their need for accommodation respected.

In the Policy, an individual with a disability includes those with any physical, mental, intellectual, cognitive, learning, communication, or sensory impairment—or a functional limitation—whether permanent, temporary or episodic in nature, evident or not, that, in interaction with a barrier, hinders a person’s full and equal participation in society. For the complete definition of disability, and other definitions, see the Definitions Section at the end of this document.

General

The Company will make reasonable efforts to ensure that all individuals, including those living with disabilities, have the same opportunity to access the products and services provided by the Company. The Company will strive to be consistent with the following principles when establishing policies, practices, and procedures:

• Products and services will be made available in a manner that respects dignity, independence, and equal opportunity for all. They will be integrated for all members of the public, with temporary or permanent alternative measures provided as necessary to ensure individuals with disabilities can access, use, or benefit from them.
• The Company will seek to provide fair and accessible employment practices.
• The Company will strive to provide barrier-free access to our premises and technology platforms.

Customer Service

Assistive Devices

An assistive device is any device that is designed, made or adapted to assist an individual with a disability in carrying out activities. An individual will be able to use their own assistive devices to access the Company’s premises, systems, products and services, except where this may reasonably pose a security or health risk to the individual or others.

In situations where the use of an assistive device could reasonably pose a security or health risk, the Company may make other reasonable measures available to assist the individual with the disability. It is the responsibility of the individual with a disability to ensure that their assistive device is operated in a safe and controlled manner at all times.

Support Persons

An individual with a disability who is accompanied by a support person will be permitted to enter the Company’s premises as appropriate with their support person unless this access creates a security, health or safety risk.

The Company may require a person with a disability to be accompanied by a support person when on the Company’s premises, but only if a support person is necessary to protect the security, health or safety of the person with a disability or others on the premises.

Due to the sensitive nature of discussions that may occur in the presence of a support person, the Company may request that the individual with a disability consent to the discussion of confidential information in the support person's presence. Should an individual with a disability have reservations about disclosing confidential information in the presence of the support person, they may request the support person's absence during such discussions.

Service Animals

An individual with a disability accompanied by a service animal will typically be granted access to premises owned or leased by the Company, with the service animal allowed to remain with them. If legal restrictions prevent the service animal's access, the Company will endeavor to arrange alternative accommodations to facilitate access.

The individual with a disability is responsible for the care and control of the service animal at all times.

Technology

When acquiring new technology that enable public users to access the Company’s financial products or services, the Company will prioritize the consideration of accessibility features. Preference will be given to technology options that are accessible.

Information & Communication

When communicating with individuals with disabilities, the Company will consider their specific needs. Upon request, the Company will provide or arrange accessible formats and supports to facilitate communication with individuals with disabilities. This will be done promptly and at a cost no higher than that charged to others.

Upon request and where applicable, the Company will provide emergency procedures, plans, and public safety information in accessible formats or with appropriate communication supports to customers. 

The Company will ensure that its internet websites and web content adhere at a minimum to the requirements of the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0.

Review

This Policy shall be reviewed, approved, and updated as necessary.

Accessibility Plan

The Company has a multi-year accessibility plan to identify and remove barriers and meet requirements as per accessibility legislation. The accessibility plan is reviewed and updated as required, but not less frequently than every five years.

Employment

The Company will notify applicants that accommodation is available for persons with disabilities during the recruitment process. Successful applicants will be notified about the Company’s policies for accommodating individuals with disabilities as part of their offer. If a selected individual requests accommodation, the Company shall consult with the applicant and provide, or arrange for the provision of a suitable accommodation in a manner that considers the applicant’s needs. In addition, a written process for the development and maintenance of documented individual accommodation plan will be developed.

The Company has a documented return to work process and will support employees returning to work due to disability and requiring disability-related accommodations.

The Company will take into account the needs of its employees with disabilities including individual accommodation plans as applicable, when providing career development, performance management and when considering redeployment.

Workplace Emergency Response

The Company shall provide individualized workplace emergency response information to the Company’s employees who have a disability, if the disability is such that the individualized information is necessary, and if the Company’s employee or member of the Consultant Network makes the Company aware of the need for accommodation due to the individual’s disability. The Company shall provide this information as soon as practicable after becoming aware of the need for accommodation.

Where an employee requires assistance, the Company shall, with the consent of the individual, provide the workplace emergency response information to the person designated by the Company to provide assistance.

The Company shall review the individualized workplace emergency response information developed when the employee moves to a different location at the Company, when the individual’s overall accommodations needs or plans are reviewed, and, when the Company reviews its general emergency response policies.

Training

The Company will ensure that all employees, management with oversight responsibilities, and others who deal with members of the public (including third parties) on behalf of the Company (regardless of their location), are offered training on AODA and AMA requirements as well as associated Customer Service Regulations along with the appropriate Human Rights Codes.

Built Environment

Where the Company owns real estate property that includes public spaces, and undertakes to build new structures or make major changes to existing structural features, the Company is committed to meeting the design and accessibility requirements of accessibility building code and legislation. Some of this work may be phased to tie in with organizational modernization efforts. 

Notice of Service Disruption

The Company will, when possible, provide notice in the event of a disruption in the facilities or services usually used by individuals with disabilities.

Feedback and Concerns

Feedback regarding the Company’s application of this policy may be made by e-mail, telephone, in person, or any format that better meets the communication needs of the person providing it.

The Company will ensure that every process for receiving and responding to feedback is accessible to persons with disabilities. It will do this by providing or arranging for the provision of accessible formats and communication supports upon request.

Further information on how to provide feedback and the actions the Company will take on receiving notice of a concern is available from the Company’s website: Accessibility | Mackenzie Investments