AODA Policy

NORTON MCMULLEN LLP - MULTI-YEAR ACCESSIBILITY PLAN

I. Accessibility Policy: Statement of Commitment

Norton McMullen LLP (“Norton” and the “Firm”) is committed to supporting equal access and participation for people with disabilities. This includes our clients, our employees, and members of the public that attend our office.

The goal of the Accessibility for Ontarians with Disabilities Act, 2005 (the “AODA”) is to create a more accessible Ontario, by identifying, and to the extent possible, preventing, and eliminating barriers experienced by persons with a disability.

We believe in integration, and we are committed to meeting the needs of people with disabilities in a timely manner. Our accessibility policies are consistent with the principles of:

• independence;

• dignity;

• integration; and

• equality of opportunity for people with disabilities.

This Multi-Year Accessibility Plan will be posted online on the Firm’s intranet as well as in a conspicuous place on the Firm’s premises. It will also be made available upon request in an accessible format.

Date: This Multi-Year Accessibility Plan has been updated and published as of June 25, 2024. It will be updated at least once every five (5) years.

II. Employment

Norton notifies employees, job applicants, new hires, and the public about the availability of accommodation for applicants and employees with disabilities both during the recruitment process and in the course of employment.

During our assessment or selection process, we notify job applicants that accommodation is available upon request in relation to the materials or processes to be used. When accommodation is requested by an employee of a candidate, Norton will consult with person requesting accommodation to determine what accommodation to provide to ensure the Firm is taking into account their unique accessibility needs.

Norton will develop individual accommodation plans for employees with disabilities. Individual accommodation plans are written documents that list all accommodations that an employee with disabilities needs in order to make their jobs accessible. Norton will periodically review individual accommodation plans to assess if they are achieving their objective of making the workplace accessible.

Individualized workplace emergency response information will be provided to employees with disabilities, as necessary. If the employee consents, their individualized plan will be provided to a designated employee responsible for providing assistance in the event of an emergency.

Individualized workplace emergency response information shall be reviewed when the employee moves to a different location in the organization; when the employee’s overall accommodations needs or plans are reviewed; and when Norton reviews its general emergency response policies.

Norton will consider 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.

Norton will consider 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.

III. Training

We are committed to training all Norton employees, including those who develop the Firm’s accessibility policies as well as those who serve our clients on behalf of the Firm, in the following accessibility topics:

(a) The purpose of the AODA and how to offer accessible goods, services, and facilities to persons with disabilities;

(b) A review of duties and responsibilities under the Human Rights Code;

(d) How to interact with persons with a disability who use an assistive device or require the assistance of a service animal or support person;

(e) How to use equipment or devices made available on our premises to assist persons with a disability to obtain, use or benefit from our goods and services;

(f) What to do if a person with a disability is having difficulty accessing our premises and/or services; and

(g) Such other accessibility training required to perform a given role.

Documenting Training

Norton will keep records of the AODA training it provides, including the dates training is provided and the names of individuals to whom it is provided.

IV. Communication

Norton will communicate with people with disabilities in a manner that takes into account their disability. We ensure our accessibility policies, notices of disruption, and feedback policy are available in accessible formats or with communication supports, upon request and in a timely manner.

V. Assistive Devices, Service Animals, Support Persons

Assistive Devices

People with disabilities may use their personal assistive devices when accessing our services or facilities. In cases where the assistive device presents a significant and unavoidable health or safety concern or may not be permitted for other reasons, other measures will be used to ensure the person with a disability can access our goods, services or facilities.

Service Animals

Persons with a disability may enter premises operated by Norton accompanied by a service animal or guide dog, and keep the service animal or guide dog with them. Limited exceptions to access will be made for areas restricted to animals under the law. If a service animal or guide dog must be excluded by law, we explain why this is the case and explore alternative ways to meet the person’s needs.

The service animal or guide dog must be under the care and control of the person with a disability at all times while on Norton’s premises.

Support Persons

A person with a disability may enter premises owned and/or operated by Norton with a support person and have access to the support person while on the premises.

Norton may require a person with a disability to be accompanied by a support person when on the Firm’s premises, but only if, after consulting with the person with a disability the Firm determines that it is necessary to protect their safety or the safety of others and there is no other reasonable alternative.

VI. Accommodation and Return to Work

Norton is committed to accommodation and promoting a safe return to work after an employee’s injury or illness. Norton will consider the accessibility needs of its employees with disabilities, as well as individual accommodation plans, when redeploying employees with disabilities that are returning from a leave. Norton assess how to prevent and remove barriers to accessibility as reasonably necessary in compliance with both the AODA. Norton will also consider and implement reasonable accommodation as required under the Human Rights Code.

All Norton employees are required to cooperate, communicate, and participate in the successful implementation and execution of an accommodation and/or return to work program. This includes providing timely and complete documentation from medical professionals, as requested by Norton.

VII. Notice of Temporary Disruption

Norton will ensure that the accessible elements of its facilities are properly maintained. However, notice to the public will be provided if there is any disruption to facilities or services that are otherwise made available to persons with disabilities. The notice shall be posted in a conspicuous place on Norton’s premises that are impacted by the disruption. The notice shall also be posted on the Firm’s website and made available in accessible formats upon request.

The notice will include the reason for the disruption, the anticipated duration of the disruption, and a description of alternative facilities or services, if any are available.

VIII. Feedback Process

We welcome feedback regarding our accessibility initiatives, including how we provide access to our goods, services, and facilities to persons with disabilities. Please engage our Sr. Director Operations, David Austring, who can be reached at daustring@nmcpa.ca or 905-479-7001 Ext. 330.

Management will reply to accessibility feedback in a timely manner. We will ensure that our feedback processes are accessible to persons with disabilities by providing or arranging for the provision of accessible formats and communications supports, upon request.