1.0 Purpose

Transpharmation “The Company” is committed to providing inclusive, barrier-free employment, facilities, and services that are free from discrimination as required under the Ontario Human Rights Code (Code) and the Accessibility for Ontarians with Disabilities Act (AODA). The goal of the company’s Accessibility Policy is to foster an inclusive community and workplace. The company will fulfil its duty to accommodate by promoting inclusive employment practices, facilities, and by exploring accommodation for persons and/or groups who request it based on the prohibited grounds in the policy.

2.0 Application

This Policy applies to all employees of the Company.

3.0 Policy Elements

The company recognizes its duty to accommodate to the point of undue hardship and commits itself to an accommodation process that respects the Code principles of dignity and privacy, inclusion and individualization. The company’s commitment extends to all aspects of employment, use of facilities and the provision of services. Employment activities include: recruitment, assessment and selection, orientation, working conditions, promotion, training, performance management, career development, workforce transition, leaves of absence, return to work and redeployment.

Systemic Assessment

The proactive review of existing policies, rules, practices and procedures to identify and eliminate barriers to access and inclusion. Ensuring policies, standards and practices are barrier-free can minimize the need for individual assessments/accommodation.

Individual Assessment

Accommodation is assessed and delivered on an individual basis for persons who make their needs known. Each request must be considered individually in order to assess appropriate accommodation. Requests for accommodation must be dealt with in a timely manner so individuals can fully participate in all aspects of employment, use of facilities, except where evidence does not support the need for accommodation or where undue hardship can be demonstrated.

Dignity and Privacy

Individuals must be accommodated in ways that respect their dignity and right to privacy. Information relating to specific requests for accommodation will be treated as confidential and will only be used for the purpose of assessing and implementing accommodation options advertisement solutions. The company will comply with all privacy, confidentiality and security requirements of the Municipal Freedom of Information and Protection of Privacy Act.

Legal Obligations and Limit

Exploring accommodation is a legal obligation for all employers, facility and service providers under the Code and related jurisprudence; failure to explore requests for accommodation in good faith related to any of the Code’s prohibited grounds may constitute discrimination and a breach of the Code. Even where it is determined that accommodation is not required, employers have a legal duty to fully explore every request for accommodation in good faith.

4.0 Definitions


Means access. It refers to the absence of barriers that prevent individuals and/or groups from fully participating in all aspects of employment and service provision. The term is often linked to people with disabilities and their rights to access.


With respect to discrimination, it includes attitudes and designs that prevent people from fully participating in employment, use of facilities. Individuals and groups can experience discrimination as a result of physical (building design), attitudinal (stereotypes or prejudices) or systemic barriers. Systemic barriers are formal or informal policies, practices or rules which, when applied in the same way to everyone, may have the effect of excluding or restricting the participation of some individuals, e.g., a work schedule or community meeting those conflicts with religious observance requirements.

Duty to Accommodate

The obligation of an employer and facility is to take steps to eliminate the disadvantage caused by systemic, attitudinal, or physical barriers that exclude individuals or groups protected under the Code from participating in all aspects of employment, use of facilities. There is a procedural obligation to explore all accommodation options, and a substantive obligation to implement an accommodation that is reasonable. Every accommodation request must be fully considered and may be refused only if no Code-related need is substantiated or if undue hardship can be demonstrated.

Employee Accommodation

  1. Universal Accommodation - A proactive process of identifying and eliminating barriers for everyone. This can be done through the initial design of and/or modifying facilities, policies, programs, procedures and practices, and ensuring that potential barriers are identified and removed. In some cases, new policies, programs, procedures and practices are required to eliminate barriers and achieve equitable outcomes
  2. Individual Accommodation - An adaptation or adjustment that may be required to enable an employee to perform his or her essential job responsibilities effectively and/or a service recipient to participate in a Company program. For employees, this may involve purchasing equipment, modifying some duties or hours of the job, reassignment of the employee, or providing additional supports such as sign language interpretation. For service delivery, this may involve modifying facilities and programs, ensuring program delivery does not conflict with religious requirements/sincerely held beliefs, the provision of communications in alternative formats, making attendant care available, etc.

Protected/Prohibited Grounds

Protections in the Code, that every person has the right to equal treatment on the basis of the following: race, ancestry, place of origin, colour, ethnic origin, citizenship, creed, sex, sexual orientation, gender identity, gender expression, receipt of public assistance, sexual orientation, age, record of offences, marital status, family status, or disability.

Undue Hardship

Refers to the extent to which an employer, facility and/or service provider must attempt to accommodate the needs of an employee, job applicant and/or service recipient who has demonstrated that accommodation is required on grounds protected in the Code. However, language or literacy issues may be included under the grounds of ancestry, ethnic origin or place of origin and/or disability.

Bona fide accommodation requests require more than a minimal effort on the part of the company. The company must take all reasonable steps to determine if an employee, job applicant can be accommodated. However, there are limits on how much the company is required to do. If the company can show that further efforts to accommodate would create undue hardship for it, the company has met its legal obligations.

The three factors under the Code that can be considered in determining undue hardship are:

  1. cost of the accommodation, i.e., whether or not the cost threatens the viability of Transpharmation;
  2. outside sources of funding, if any, i.e., whether the company can access special funding, such as grants to alleviate some of the direct costs of the accommodation;
  3. health and safety requirements, if any.

5.0 Roles and Responsibilities


  • Managing the accommodation process by individually assessing requests in good faith, considering all options, resolving disagreements, and documenting, monitoring and evaluating employment, service and facility accommodation solutions.
  • Consulting the Human Rights Office before denying an accommodation request.

Employees, Job Applicants:

  • Identifying needs and initiating requests for accommodation.
  • Providing evidence to support accommodation needs and to support the assessment of accommodation options/solutions.
  • Participating in good faith, in the assessment and implementation of accommodation solutions.

Human Resources:

  • Providing advice to support management in the assessment and implementation of accommodation.
  • Ensuring accommodation is incorporated into human resources policies, processes, practices, etc.

6.0 Maintenance and Repairs of Accessible Areas

  • Scheduled maintenance and/or repairs, or any disruption of accessible areas of the facility will be posted onsite and communicated with visitors in advance.
  • Posted notice will include reason for disruption, its anticipated duration, and a description of alternative services or facilities if available.
  • In consultation with the individual requesting accessibility, an employee of the company may be assigned to assist the individual requiring accessible areas as determined by the solution derived from the discussion with the individual.

Effective Date: 2023-12-14
This policy will be reviewed and updated at least once every 5 years.