Accessibility Policy

CrossSafety Companies

Effective Date	June 1, 2026
Next Scheduled Review	June 1, 2027 (annual)
Approved By	John H Murphy, Chief Executive Officer

1. Purpose

CrossSafety is committed to providing a workplace and client experience that respects the dignity and independence of persons with disabilities. This Policy establishes the principles and requirements by which CrossSafety identifies, removes, and prevents barriers to accessibility in the goods, services, employment, information, and facilities we provide. This is consistent with one of our key values – inclusivity.

This Policy is issued in compliance with the Accessibility for Ontarians with Disabilities Act, 2005 (AODA), Ontario Regulation 191/11 (the Integrated Accessibility Standards Regulation, or IASR), and the Ontario Human Rights Code.

2. Scope

This Policy applies to:

All employees, officers, and directors of CrossSafety, including those of its subsidiaries and predecessor entities;
Contractors, consultants, agents, and volunteers acting on behalf of CrossSafety;
All locations from which CrossSafety operates, and all client sites at which CrossSafety personnel deliver services;
All third parties who develop or deliver goods, services, or facilities on behalf of CrossSafety.

3. Statement of Commitment

CrossSafety is committed to treating all persons in a way that supports dignity and independence. We believe in equal opportunity and recognize our obligation to meet the accessibility needs of persons with disabilities in a timely manner. We will achieve this by identifying, removing, and preventing barriers to accessibility, and by meeting our obligations under the AODA and all related regulations.

4. General Principles

All goods, services, employment practices, and facilities provided by CrossSafety shall be delivered in a way that respects the following four principles:

Dignity — Persons with disabilities will be treated as valued customers, employees, and members of the community, as deserving of effective and full service as any other person.
Independence — Persons with disabilities will be supported in doing things on their own without unnecessary help or interference from others.
Integration — Persons with disabilities will benefit from the same goods, services, and facilities, in the same place and in the same or similar way as other persons, unless an alternate measure is necessary to enable a person with a disability to access them.
Equal Opportunity — Persons with disabilities will have the same chances, options, benefits, and results as others.

5. Workplace Accommodation Process

CrossSafety is committed to a fair, individualized, and confidential process for assessing requests for workplace accommodation. The process is as follows:

An employee or applicant submits a request for accommodation, in writing where reasonably possible, to their direct supervisor or to Human Resources.
Human Resources, in consultation with the employee or applicant, identifies the accessibility need and may request supporting medical or functional information from a regulated health professional. The nature of the disability is not required to be disclosed.
CrossSafety, in consultation with the employee, develops a written Individual Accommodation Plan that identifies accommodations to be provided, timelines, and any individualized workplace emergency response information.
The plan is provided to the employee in a format that takes their accessibility needs into account.
The plan is reviewed at least annually, when the employee’s work duties change, when the nature of the disability changes, or when CrossSafety reviews its general accommodation practices.
CrossSafety reserves the right to decline an accommodation request only where the accommodation would constitute undue hardship having regard to the cost of accommodation, outside sources of funding, and health and safety requirements.

6. Feedback Process

Feedback regarding the manner in which CrossSafety provides goods, services, employment, or facilities to persons with disabilities is welcomed and encouraged. Feedback may be provided in person, by telephone, in writing, by email, or by any other accessible format or communication support requested.

7. Multi-Year Accessibility Plan

CrossSafety has established a Multi-Year Accessibility Plan that outlines the Company’s strategy to prevent and remove barriers and to meet its requirements under the IASR. The Multi-Year Accessibility Plan is posted on the CrossSafety website, is provided in an accessible format upon request, is reviewed and updated at least once every five years, and is supported by status reports each calendar year.

8. Roles and Responsibilities

Chief Executive Officer — holds ultimate accountability for compliance with the AODA and this Policy.

Managers and Supervisors — ensure their teams complete required training, respond appropriately to accommodation requests, and apply this Policy in day-to-day decision-making.

All Employees and Contractors — comply with this Policy, complete required training, and treat all colleagues, clients, and visitors in accordance with the principles set out herein.

9. Review and Amendment

This Policy is reviewed annually and updated as necessary to reflect changes in legislation, organizational structure, or operating practice.

Approved: John H Murphy, Chief Executive Officer

Multi-Year Accessibility Plan

2026 – 2030 | CrossSafety

Plan Period

January 1, 2026 – December 31, 2030

This five-year plan sets out how CrossSafety will continue to identify, remove, and prevent barriers to accessibility across everything we do — the way we hire, the way we train, the way we communicate with clients, and the way our colleagues with disabilities experience their work at CrossSafety. We have done meaningful work already; this plan describes what comes next.

1. Where We Are Today

CrossSafety has invested in foundational accessibility before issuing this Plan. As of the effective date:

Physical Premises — All CrossSafety offices currently comply with applicable accessibility design features under the Ontario Building Code and the Accessibility Standards for the Design of Public Spaces, including accessible entrances, washrooms, and circulation routes.
Workstation Ergonomics — All office workstations are equipped with ergonomic seating and variable-height (sit-stand) desks, providing a base of physical adjustability available to all employees, including those with disabilities.
Web Presence — The crosssafety.com website meets the WCAG 2.0 Level AA conformance level required by the IASR for public-facing web content.
Service Delivery — CrossSafety welcomes service animals, support persons, and personal assistive devices at its offices and at client sites under CrossSafety control.

This Plan builds on those foundations. The actions that follow are organized by IASR standard and then mapped to a year-by-year implementation schedule in Section 11.

2. General Requirements

What we have done

Established an Accessibility Policy approved by the CEO.

What we will do

Publish the Accessibility Policy and this Multi-Year Accessibility Plan on the public website by Q3 2026.
File the AODA Accessibility Compliance Report on the Ontario filing portal by the December 31, 2026 deadline, and every three years thereafter.
Publish an annual status report each February describing progress against this Plan.
Review and update this Plan in 2030 in advance of the 2031–2035 cycle.

3. Customer Service

What we have done

Welcomed service animals, support persons, and personal assistive devices on CrossSafety premises.
Established a website feedback mailbox.

What we will do

Implement a notice-of-disruption protocol for any temporary disruption to facilities or services that persons with disabilities rely upon, including posting on the website.
Train all client-facing personnel — consultants, trainers, project managers, and reception staff — on accessible customer service expectations.

4. Information and Communications

What we have done

Brought crosssafety.com to WCAG 2.0 Level AA conformance.

What we will do

Establish an Accessible Document Standard for client deliverables (reports, proposals, training materials) covering heading structure, alt text, table structure, reading order, color contrast, and meaningful link text. Roll out to all consulting and training teams.
Revise the active library of standard CrossSafety training materials (presentations, handouts, exams) so that they are produced in accessible format by default.
Establish a process for providing accessible formats and communication supports on request — large print, screen-reader-compatible PDF or HTML, accessible video captioning, sign-language interpretation.
Audit emergency procedures, plans, and public safety information prepared by CrossSafety and ensure they are available in accessible format on request.
Track web content accessibility against WCAG 2.1 Level AA as a forward-looking target, in line with widely adopted private-sector practice.

5. Employment

What we have done

Provided ergonomic seating and variable-height desks to all office-based employees as a baseline.
Considered accommodation requests on a case-by-case basis through Human Resources.
Added an explicit accommodation availability statement to all external and internal job postings and to the careers page.
Notify applicants individually, when invited to assessment or interview, that accommodations are available on request.
Included a notification of accessibility supports in every new employment contract.

What we will do

Document a written Individual Accommodation Plan procedure, including a standard form, with timelines and review triggers.
Update our written Return-to-Work procedure for employees absent due to disability, integrating accessibility considerations with existing disability management practices.
Embed accessibility considerations into performance management, career development, and redeployment processes through manager guidance and training where applicable.
Provide individualized workplace emergency response information to employees with disabilities, where the disability is such that the information is necessary, in coordination with site emergency response plans for each office and significant client site.
Establish a confidential, voluntary disability self-identification mechanism for workforce data purposes.

6. Training

What we have done

Provided AODA awareness training as part of new-hire orientation.

What we will do

Refresh training whenever this Policy or applicable legislation is materially amended.
Provide enhanced training for managers and supervisors on accommodation, return-to-work, and accessible performance conversations, as warranted.

7. Procurement

What we have done

Considered accessibility informally on a case-by-case basis when acquiring goods and services.

What we will do

Prioritize accessibility in procurement of any new website, learning management system, document management system, or other workforce-facing technology.

8. Design of Public Spaces

What we have done

All CrossSafety facilities currently comply with applicable accessibility design features.

What we will do

Apply the Design of Public Spaces standards to any new construction or significant redevelopment of CrossSafety-controlled public space during the Plan period.

9. Year-by-Year Action Plan

The table below maps the actions described above to a target completion year. Annual status reports will refresh this schedule.

Year	Priority Actions
2026	• Publish Accessibility Policy and this Plan on the public website. • File the AODA Accessibility Compliance Report (due December 31, 2026). • Document Individual Accommodation Plan and Return-to-Work procedures.
2027	• Issue Accessible Document Standard for client deliverables and training materials. • Begin revision of the standard training library. • Launch enhanced manager training on accommodation and return-to-work.
2028	• Publish annual status report (February 2028). • Complete amendments to the standard training library. • Embed accessibility into performance management and career development cycles. • Implement individualized workplace emergency response information process.
2029	• Publish annual status report (February 2029). • File AODA Accessibility Compliance Report (due December 31, 2029). • Refresh IASR + Human Rights Code training.
2030	• Publish annual status report (February 2030). • Complete five-year review and develop the 2031–2035 Multi-Year Accessibility Plan.

10. Accessible Formats and Feedback

This Plan is available in accessible formats and with communication supports, on request, at no additional cost. To request an accessible format, or to provide feedback on accessibility at CrossSafety, please contact us:

[email protected]
Telephone: 416 495 1314 1 888 732 4347
Mail: 18 Wynford Drive, Suite 617, Toronto, Ontario M3C 3S2

All feedback is treated confidentially and is used to improve our accessibility practices.