Accessibility Program – Integrated Standards for Accessibility & Multi-Year Plan

Statement of Commitment

CI Financial and its affiliates (“CI”) are committed to providing an accommodating environment to all individuals (employees and customers), whatever their ability, and ensuring all services are received in an accessible and timely manner.

CI is committed to maintaining current and effective processes by consulting with key stakeholders who will aide in the overall ability to enhance the accessibility to persons with disabilities.

CI will incorporate training at all staff levels and within new employee orientation materials to ensure all employees are aware of the possible needs of both the colleagues and the public they may be serving.

Accessibility Policy

Creating and maintaining an inclusive environment for all employees, contractors, and the general public is a priority for CI to ensure all individuals feel comfortable and secure while working in, or as patrons of, our business.

CI continues to actively learn about and create accessible methods for which to navigate and/or access services that are beneficial to everyone.

Accessibility Plan

CI’s goal is to enhance its working environment and customer service areas to be accessible and welcoming. Allowing employees to function effectively according to their needs, and customers to receive services efficiently in a manner they can use and understand, will contribute to CI being an attractive place of employment and service provider for exceptional employees and the general public, respectively.

CI will strive to achieve the goal of becoming an accessible business with continuous short- and long-term initiatives focusing on the needs of persons with disabilities. These include but are not limited to:

• Staying abreast of industry initiatives and requirements
• Updating and maintaining our policies and procedures with accessibility in mind
• Ongoing monitoring of necessary changes or updates with respect to infrastructure
• Consulting with employees with disabilities to better understand the needs for accessibility
• Reviewing staff and customer feedback

Training

CI provides training to corporate employees, people managers, contractors, summer students, co-op students, and temporary employees with respect to the Accessibility for Ontarians with Disabilities Act, 2005 (“AODA”) & The Accessibility for Manitobans Act, 2013 (“AMA”) as it relates to our business and persons with disabilities, as colleagues and/or customers. CI’s corporate training program will be provided upon hiring.

CI provides training to employees during onboarding and orientation, and access to trainings throughout the year.

Information & Communications

CI will continue to provide accessible communications and materials at no cost pertaining to the specific needs of an individual in a timely fashion by committing to the following: 

• Maintaining policies and procedures for creating accessible material for varying departments
• Educate employees, advisors, volunteers and contractors on how to identify, prevent and remove barriers to accessible communication
• Continue to commit to ensuring processes to provide feedback are accessible to all individuals with disabilities, upon request
• Continue to commit to ensuring all public information is readily available in an accessible format by request for specialized formatting
• All existing websites and content are compliant with the Web Content Accessibility Guidelines (“WCAG”) Standard 2.1 Level AA

Employment Accessibility Standards

CI is committed to offering fair and accessible employment practices. We notify internal personnel and the general public of our ability to accommodate people with disabilities during a recruitment and/or assessment period and also upon hiring.

• CI has developed policies for individual accommodation plans and return-to-work policies for existing employees who may have been absent due to a disability and require assistance to continue in their position
• CI also takes steps to ensure the accessibility needs of employees with disabilities are taken into account during performance management, career development and redeployment
• CI is committed to ensuring all employees have a safe and accessible work area and takes required steps to remove any identified barriers that prove problematic to employees with disabilities
• CI is committed to an ‘open door’ approach for all staff and invites anyone to contact the policy area should an accessibility issue arise. We will work with the affected individual(s) to find a reasonable solution that is acceptable to all parties involved

Design of Public Spaces

CI is committed to meeting the accessibility standards by relying on the building(s) external management services to address any and all public spaces. At CI, waiting areas have procedures for preventative, emergency maintenance, and temporary disruptions when accessible elements are not in working order.

Contact Information

Please contact us by

• Completing Accessibility Customer Service - Feedback Form
• By Phone at – Client Services: 1-800-792-9355 
• By Email at – service@ci.com

Accessible formats of this document are available free upon request. Please use the contact information above to request a format that meets your specific needs.

Multi-Year Plan

CI has committed to a multi-year accessibility plan since January 1, 2012. Since the inception of the multi-year plan, CI has fulfilled commitments and made progress in making our goods and services more available and in the removal of barriers to provide people with disabilities greater access. 

We acknowledge that there is more progress to be made and continue to fulfill the commitments made in the multi-year plan and associated legislation.

Below is a road map of the actions that have been taken in accordance with AODA & AMA regulation, along with the actions that have and will be implemented.

AODA Customer Service Standard Requirements – Completed

• Created and posted the Customer Service Policy on CI’s external website and company intranet.
• Provided and continues to provide training to corporate employees, contractors, summer students, co-op students, and temporary employees with respect to Ontario’s Accessibility Standards as it relates to our business and persons with disabilities, as colleagues and/or customers.
• CI’s corporate training program is provided upon hiring through onboarding. CI provided all corporate employees the necessary training to meet the requirements under Accessibility laws and this was completed on January 1, 2015.

AMA Customer Service Standard Requirements – Completed

• Created and posted the Customer Service Policy on CI’s external website and company intranet.
• Provided and continues to provide training to corporate employees, contractors, summer students, co-op students, and temporary employees with respect to Accessibility in the Workplace (i.e., Ontario & Manitoba Accessibility Standards) as it relates to our business and persons with disabilities, as colleagues and/or customers.
• CI’s corporate training program is provided upon hiring through onboarding. CI provides all corporate employees the necessary training to meet the requirements under Accessibility laws.

General Requirements

Initiative	Requirement		Action	Status		Compliance Date
1.1 Establishment of Accessibility Policies	Every obligated organization shall develop implement and maintain policies governing how the organization achieves or will achieve accessibility through meeting its requirements under the accessibility standards referred to in this Regulation.	The policy is completed and posted on the company’s various external website and on the company intranet. The policy is updated to be inclusive of The Accessibility for Manitobans Act.			Completed Completed	January 1, 2014
1.2 Accessibility Plans	Large organizations shall, a)  Establish, implement, maintain and document a multi-year accessibility plan, which outlines the organization’s strategy to prevent and remove barriers and meet its requirements under this Regulation; b) Post the accessibility plan on their website, if any, and provide the plan in an accessible format upon request; and c) Review and update the accessibility plan at least once every five years	Process developed and posted on the company’s various external website and the company intranet. The policy is updated to be inclusive of The Accessibility for Manitobans Act.			Completed Completed	January 1, 2014 Last Update: April 1, 2025

Information and Communications Standards

Initiative	Requirement	Action	Status	Compliance Date
1.3 Training	Every obligated organization shall ensure that training is provided on the requirements of the accessibility standards referred to in this Regulation 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.	CI provides training to corporate employees, people managers, contractors, summer students, co-op students and temporary employees with respect to Ontario and Manitoba’s Accessibility Standards as it relates to our business and persons with disabilities, as colleagues and/or customers. CI’s corporate training program is provided upon hiring.  CI will ensure all corporate employees are provided the necessary training to meet the Accessibility laws by January 1, 2015. CI’s Board of Directors received training. CI will maintain training records reflecting employee’s understanding of Accessibility Standards in Ontario and Manitoba and the applicable Human Rights code	Completed	January 1, 2015
2.1 Feedback	Every obligated organization that has processes for receiving and responding to feedback shall ensure that the processes are accessible to persons with disabilities by providing or arranging for accessible formats and communications supports, upon request.	Feedback processes are available in an accessible manner, upon request.  CI will also provide accessible formats and communication for individuals with disability supports upon request.	Completed	January 1, 2015
2.2 Accessible Formats & Communication Supports	Except as otherwise provided, every obligated organization shall upon request provide or arrange for the provision of accessible formats and communication supports for persons with disabilities: a) in a timely manner that takes into account the person’s accessibility needs due to disability; and b) at a cost that is no more than the regular cost charged to other persons.	A process is in place through the Customer Service Centre and Human Resources to handle requests for accessible or alternative formats. The process is posted on the CI Internet at www.ci.com	Completed	January 1, 2016
	The obligated organization shall consult with the person making the request in determining the suitability of an accessible format or communication support.	A process is in place through Client Services and Human Resources to handle requests for accessible or alternative formats.	Completed	January 1, 2016
	Every obligated organization shall notify the public about the availability of accessible formats and communication supports.	The process is posted on the CI Internet at www.ci.com	Completed	January 1, 2016

Information and Communications Standards (Continued)

Initiative	Requirement	Action	Status	Compliance Date
2.3 Emergency procedure, plans or public safety information	If an obligated organization prepares emergency procedures, plans or public safety information and makes the information available to the public, the obligated organization shall provide the information in an accessible format or with appropriate communication supports, as soon as practicable, upon request.	The organization has the ability to provide emergency procedures and/or plans in an accessible format upon request.	Completed	January 1, 2012
	Obligated organizations that prepare emergency procedures, plans or public safety information and make the information available to the public shall meet the requirements of this section by January 1, 2012.		Completed	January 1, 2012
2.4 Accessible Websites & Web Content	Large organizations shall make their internet websites and web content conform with the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0, initially at Level A and increasing to Level AA, and shall do so in accordance with the schedule set out in this section.	All updated and/or new websites and content comply with the ‘Web Content Accessibility Guidelines (WCAG) Standard 2.0 Level AA All existing websites and content comply with the ‘Web Content Accessibility Guidelines (WCAG)’Standard 2.0 Level AA	Completed Completed	January 1, 2014 January 1, 2021
	Training programs for employees who are responsible for web content and maintenance.	CI has developed a training program for employees responsible for web content and creation to complete CI is working towards becoming (WCAG) Standard 2.1 compliant for all websites and content	In progress	April 7, 2025
	CI has made their internet websites and web content conform with the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.1 AA	All updated and/or new websites and content comply with the ‘Web Content Accessibility Guidelines (WCAG) Standard 2.1 Level AA	Completed	December 31,2024

Employment Standard

Initiative	Requirement	Action	Status	Compliance Date
3.1 Recruitment, General	Every employer shall notify its employees and the public about the availability of accommodation for applicants with disabilities in its recruitment process.	CI notifies its employees and the public about the availability of accommodation for applicants with disabilities in our recruitment process by including a statement that accommodation is available throughout the recruitment process in every job posting, whether such posting is made internally or externally.	Completed	January 1, 2016
3.2 Recruitment, Assessment or Selection Process	During a recruitment process, an employer shall 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.	When CI notifies job applicants that they have been selected to participate further in the recruitment process, CI notifies those job applicants that accommodations are available upon request during the assessment process by including a statement to this effect in its communication to applicants.	Completed	January 1, 2016
	If a selected applicant requests an accommodation, the employer shall consult with the applicant and provide or arrange for the provision of a suitable accommodation on a manner that takes into account the applicant’s accessibility needs due to disability.	If a selected applicant requests an accommodation, CI 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 individual accessibility needs due to disability.	Completed	January 1, 2016
3.3 Notice to Successful Applicants	Every employer shall, when making offers of employment, notify the successful applicant of its policies for accommodating employees with disabilities.	When making offers of employment, CI notifies the successful applicant by including a statement of its policies for accommodating employees in the offer letter with contact information. This statement clearly identifies how the successful applicant can gain access to a copy of CI’s policies for accommodating employees with disabilities	Completed	January 1, 2016
3.4 Informing Employees of Supports	Every employer shall inform its employees of its policies used to support 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.	CI informs its employees of its policies regarding employees with disabilities by posting a statement on the company intranet  This statement informs CI’s employees about policies relating to the provision of job accommodations that take into account an employee’s accessibility needs due to disability. Copies of CI’s policies are available on our company intranet and will be accessible to all employees.	Completed	January 1, 2016
	Employers shall provide the information required under this section to new employees as soon as practicable after they begin their employment.	CI provides the above information to new employees as soon as practicable after commencing employment through Orientation and training through CI’s Learning Management System.	Completed	January 1, 2016
	Employers shall 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.	CI shall provide updated information to its Employees whenever there is a change to its existing policies on the provision of job accommodations by updating our company intranet website.	Completed	January 1, 2016
3.5 Accessible Formats and Communication Supports for Employees	In addition to its obligations under section, where an employee with a disability so requests it, every employer shall 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	Upon the request of an employee with a disability, CI will consult with the employee to provide, or arrange for the provision of, accessible formats and communication supports for information that is needed to perform the employee’s job and information that is generally available to other employees	Completed and continuing	January 1, 2016
	The employer shall consult with the employee making the request in determining the suitability of an accessible format or communication support.	In determining the suitability of an accessible format or communication support, CI will consult with the employee making the request.	Completed and continuing	January 1, 2016
3.6 Workplace Emergency Response Information	Every employer shall provide individualized workplace emergency response information to employees who have a disability in such that the individualized information is necessary and the employer is aware of the need for accommodation due to the employee’s disability	Process developed All existing and new hires in Ontario are provided with training on our workplace emergency response. Upon request for an individualized workplace emergency response plan, employees will be provided with one, that will take into consideration their disability and requirements.	Completed	January 1, 2012
3.7 Documented Individual Accommodation Plans	If an employee who receives individualized workplace emergency response information requires assistance and with the employee’s consent, the employer shall provide the workplace emergency response information to the person designated by the employer to provide assistance to the employee.	Part of the process, employee consent received.	Completed	January 1, 2012
	Employers shall provide the information required under this section as soon as practicable after the employer becomes aware of the need for accommodation due to the employee’s disability.	Part of the process	Completed	January 1, 2012
	Every employer shall 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 the employer reviews its general emergency response policies.	Part of the process	Completed	January 1, 2012
	Employers, other than employers that are small organizations, shall develop and have in place a written process for the development of documented individual accommodation plans for employees with disabilities	CI has a written process for the development of documented individual accommodation plans for employees with disabilities This written process is available to employees on the company intranet	Completed	January 1, 2016
	The process for the development of documented individual accommodation plans shall include the following elements: The manner in which an employee requesting accommodation can participate in the development of the individual accommodation plan. The means by which the employee is assessed on an individual basis. The manner in which the employer can request an evaluation by an outside medical or other expert, at the employer’s expense, to determine if accommodation can be achieved and, if so, how accommodation can be achieved. The steps taken to protect the privacy of the employee’s personal information. The frequency with which the individual accommodation plan will be reviewed and updated and the manner in which it will be done. If an individual accommodation plan is denied, the manner in which the reasons for the denial will be provided to the employee. The means of providing the individual accommodation plan in a format that takes into account the employee’s accessibility needs due to disability.	CI’s written process for the development of individual accommodation plans addresses: The manner in which an employee requesting accommodation can participate in the development of their individual accommodation plan The means by which the employee is assessed on an individual basis The manner in which the employer can request an evaluation by an outside medical or other expert in order to determine if accommodation can be achieved and, if so, how. Any external evaluation will be at CI’s expense. The manner in which the employee can request the participation of a representative from CI The steps taken to protect the privacy of the employee’s medical information How often the individual accommodation plan will be reviewed and updated, and how this update will be accomplished The means of providing the individual accommodation plan in a format that takes into account the employee’s accessibility needs due to disability	Completed	January 1, 2016
3.8 Return to Work Process	Every employer, other than an employer that is a small organization, a) Shall develop and have in place a 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; and b) Shall document the process.	CI has a documented 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	Completed	January 1, 2016
	The return to work process shall, a) Outline the steps the employer will take to facilitate the return to work of employees who were absent because their disability required them to be away from work; and b) Use documented individual accommodation plans, as part of the process.	The documented return to work process outlines the steps CI will take to facilitate the return to work and includes documented individual accommodation plans as part of the process	Completed	January 1, 2016
	The return to work process referenced in this section does not replace or override any other return to work process created by or under any other statute.	CI’s documented return to work process does not replace or override any other return to work process created by or under any other statute	Completed	January 1, 2016
3.9 Performance Management	An employer that uses performance management in respect of its employees shall take into account the accessibility needs of employees with disabilities, as well as individual accommodation plans, when using its performance management process in respect of employees with disabilities.	CI takes into account the accessibility needs of employees with disabilities, as well as individual accommodation plans, when matters of performance management arise	Completed and continuing	January 1, 2016
3.10 Career Development & Advancement	An employer that provides career development and advancement to its employees shall take into account the accessibility needs of its employees with disabilities as well as any individual accommodation plans, when providing career development and advancement to its employees with disabilities.	CI takes into account the accessibility needs of employees with disabilities, as well as individual accommodation plans, when providing career development and advancement to employees	Completed and continuing	January 1, 2016
3.11 Redeployment	An employer that uses redeployment shall take into account the accessibility needs of its employees with disabilities, as well as individual accommodation plans, when redeploying employees with disabilities.	CI takes into account the accessibility needs of employees with disabilities, as well as individual accommodation plans, when redeploying employees.	Completed and continuing	January 1, 2016

Transportation Standard

Initiative	Requirement	Action	Status	Compliance Date
4.1 Transportation	Sections 34 – 80 of the AODA, O. Reg. 191/11: Integrated Accessibility Standards Regulation.	The standard is not applicable in Ontario and/or Manitoba; however, CI will continue to track transportation-related regulations to ensure compliance in the future.	Not Applicable	January 1, 2017

Design of Public Spaces

Initiative	Requirement	Action	Status	Compliance Date
5.1 Waiting Area	When constructing a new waiting area or redeveloping an existing waiting area, where the seating is fixed to the floor, a minimum of three per cent of the new seating must be accessible, but in no case shall there be fewer than one accessible seating space.	CI has ensured accessible seating space in the waiting area and will continue to provide and maintain it, allowing individuals using mobility aids to wait comfortably.	Completed	January 1, 2017
	For the purposes of this section, accessible seating is a space in the seating area where an individual using a mobility aid can wait.		Completed	January 1, 2017
	Obligated organizations, other than small organizations, shall ensure that their multi-year accessibility plans include the following: Procedures for preventative and emergency maintenance of the accessible elements in public spaces as required under this Part.		In progress
	Procedures for dealing with temporary disruptions when accessible elements required under this Part are not in working order.		In progress