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CIDEL BANK & TRUST INC.,
CIDEL FINANCIAL INC.,
CIDEL TRUST SERVICES LTD.,
CIDEL BANK CANADA,
CIDEL TRUST COMPANY,
CIDEL ASSET MANAGEMENT INC.,
CIDEL (PTY) LIMITED

    1. Any electronic mail you receive from an employee or representative of Cidel Bank and Trust Inc, (“Cidel”) or any subsidiaries, including any attachments thereto (“the email”), is subject to the Cidel e-mail disclaimer (“disclaimer”) as set out herein.
    2. The email may contain information which is confidential and private in nature. If you are not the stated addressee (or such person authorized representative) you must –
      • notify the sender of this fact immediately by return e-mail, fax or telephone and delete the email from your system;
      • refrain from printing, copying, forwarding or otherwise disclosing any information contained in the email or any part thereof; and
      • refrain from reading, storing, using, selling or incorporating any information contained in the email into any database or mailing list for whatever reason, including for purposes of spamming or marketing.

Failure to do so may amount to the unlawful interception of a communication, the infringement of copyright and/or the infringement of the right to privacy.

    1. Neither Cidel, the sender of the email, or any other Cidel representative shall be liable for any loss, damage or expense of whatever nature (including without limitation that caused by the corruption or loss of data, damage to software programs and interruption of business operations) resulting directly or indirectly from the transmission of the email (including without limitation any malicious software code or viruses transmitted together with the email or any corruption to or loss of data contained in the email).
    2. The views and opinions expressed in the email do not necessarily reflect the views and opinions of Cidel. In particular, no Cidel representative or employee may send:
      • unsolicited commercial messages (“spam”)
      • messages that infringe any third party’s copyright, trademarks or other rights and interests (“infringing content”) and
      • messages containing content that is offensive, derogatory, defamatory or otherwise unlawful (“offensive content”)

If the email constitutes spam, contains infringing content or offensive content, or was otherwise sent for purposes unrelated to the official business of Cidel, Cidel shall not be liable for any loss, damage or expense of whatever nature resulting therefrom.

  1. Cidel reserves the right to read, monitor, access, block, delete, copy or otherwise intercept any email sent in reply to the email.
  2. Where the time or date on which the email was transmitted is in issue, unless the content thereof expressly provides otherwise, Cidel will be deemed to have-
    • sent the email once reflected as “sent” on our mail servers; and
    • received an email once reflected as “received” on our mail servers
  3. The disclaimer shall be governed by and interpreted in accordance with the laws and regulation of the country or territory that has the right to exercise jurisdiction over the matter. Jurisdiction of the applicable region shall supersede any terms contained in any email received by Cidel, insofar as these conflict with this disclaimer.

 

By accessing this Website, you acknowledge these terms of use and agree to be bound by them.  Cidel Bank & Trust Inc. (including its subsidiaries and affiliates, “Cidel”) reserves the right, in its sole discretion, to modify, alter or otherwise update these terms of use at any time and you agree to be bound by such modifications, alterations or upgrades.

Cidel is not responsible in any manner for direct, indirect, special or consequential damages, however caused, arising out of your use of this Website and/or any web browser, including any damages you may suffer if you transmit confidential or sensitive information to us or if we communicate such information to you at your request over the Internet. Links to other websites from this Website are for convenience only. No endorsement of any third party products, services or information is expressed or implied by any information, material or content referred to or included on, or linked from or to this Website.  This Website and the information is provided “as is”.  Cidel does not warrant the accuracy, adequacy, timeliness or completeness of this Website or Website information and disclaims liability for any errors or omissions.  No warranty or condition of any kind is given in the Website or Website information.  Cidel does not warrant that the Website will be available and meet your requirements, that access will be uninterrupted, that there will be no delays, difficulties in use, defects, incompatibility, failures, errors, omissions or loss of transmitted information.

Certain names, words, titles, phrases, logos, icons, graphics or designs, or other content on the Website are trademarks or trade names owned by Cidel or its subsidiaries.   Nothing on this Website shall be construed as conferring any license of any intellectual property rights, whether by estoppel, implication or otherwise.  Except when otherwise stipulated, the information otherwise may not be copied, displayed, distributed, downloaded, licensed, modified, published, reposted, reproduced, reused, sold, transmitted, used to create a derivative work or otherwise used for public or commercial purposes with the express written consent of Cidel or its subsidiaries.  Any unauthorized downloading, re-transmission, or other copying or modification of trademarks and/or the content of the Website may be a violation of federal or other law that may apply to trademarks and/or copyrights, and such actions could subject the copier to legal action.

In compliance with the Bank Act and the Trust and Loans Companies Act, the following offices have been designated by Cidel Bank & Trust Inc., Cidel Bank Canada, Cidel Asset Management Inc., Cidel Trust Company, and Cidel Pty Ltd. for the service of enforcement, including for Canada Revenue Agency and Family Maintenance and Support Orders.

South Africa

Cidel (Pty) Ltd.
32 Impala Rd
Chislehurston
Sandton, 2196
South Africa

Barbados (Cidel Bank & Trust Inc., Cidel Financial Inc., Cidel Trust Services LTD.)

Cidel Bank & Trust Inc.
Cidel Place
Lower Collymore Rock
St. Michael
Barbados

Attention: Legal Department

Canada (Cidel Trust Company)

Cidel Trust Company
Vintage Towers 1
Suite 403, 322-11th Avenue SW
Calgary, Alberta
T2R 0C5
Canada

Attention: Legal Department

Canada (Cidel Bank Canada, Cidel Asset Management Inc.)

Cidel Bank Canada
60 Bloor St. West 9th Floor
Toronto, ON M4W 3B8
Canada
Attention: Legal Department

CIDEL BANK & TRUST INC,
CIDEL FINANCIAL INC.,
CIDEL TRUST SERVICES LTD.

Cidel Bank & Trust Inc. (“CBTI”) is a Foreign Currency Earning Bank that designs and implements customized financial solutions to help clients build, reserve and transfer wealth.  With a strategic network of operations in Canada and internationally, its broad range of investment and structuring capabilities provide clients with solutions that are global and innovative.  Most of these activities are carried out by CBTI’s subsidiaries, Cidel Trust Services Ltd (CTSL) and Cidel Financial Inc. (CFI), herein refer to ‘Cidel’.

CBTI is licensed and regulated by the Central Bank of Barbados and is subject to the Financial Institutions (Amendment) Act 2018-51.  The Board of Directors, Audit Committee, senior management and employees of Cidel are guided by internal policies as well as the Money Laundering and Financing of Terrorism (Prevention and Control) (Amendment) Act 2019, the Anti-Terrorism (Amendment) Act, 2019 and the Anti-Money Laundering (AML) / Combating Financing of Terrorism (CFT) Guidance Note issued by the Central Bank of Barbados in conjunction with the Anti-Money Laundering Authority, issued October 2006 and revised November 2021.

The Barbadian subsidiaries are subject to the same AML legislation and Guidelines as CBTI.  The asset management business is undertaken by CFI as a Securities Company and Investment Advisor.  It is licensed by the Financial Services Commission.  CTSL, the fiduciary arm of the business, is subject to the Corporate Trust and Services Providers Act and is regulated by the International Business Unit.

Cidel is required to take reasonable and appropriate measures to establish the identities of their clients (entity and individual) including all beneficial owners and to open accounts and conduct transactions only after identity is verified to our satisfaction.  These measures are also applicable to Cidel’s relations with custodians, correspondent banks, professional intermediaries, investment advisors and agents.

Money laundering and Financing of Terrorism and Proliferation are criminal offences in Barbados and in many other jurisdictions of which business is undertaken.  Cidel is committed to preventing the use of its business for such purposes, by establishing policies and procedures to ensure that:

  • Business acceptance polices are in place for identification and approval of new business.
  • A senior employee has been designated the Chief Compliance Officer and the Money Laundering Reporting Officer.

The various regulatory agencies issue guidelines periodically and Cidel will update its policies and procedures to ensure compliance with them by considering the nature and scale of its business, complexity, volume and size of activities and the degree of risk associated with each area of its operations.

Independent Review

An independent AML review is conducted every two years by an external party and the results are reported to the Board of Directors and the various regulatory agencies.  From time to time, CBTI and its subsidiaries are also subject to regulatory inspections which involve assessing their risk management and AML framework.

December 31, 2023

Cidel Bank & Trust Inc. (hereinafter referred to as “the Bank”)

1. PURPOSE & SCOPE

The Bank will accept funds and securities from time to time from Clients, who may be trusts, corporations or individuals, for the purpose of making investments on behalf of such Client in accordance with instructions received from the Client. All funds and securities received will be accepted by the Bank in trust for the Client in accordance with the terms and conditions set out herein which shall govern the relationship between the Bank and its Clients and seek to facilitate the expeditious handling of Clients’ instructions. In addition, special regulations and conditions may apply to particular kinds of business and service provided by the Bank and, if a copy of the same is not provided at the commencement of such business or service,those special regulations and conditions shall nevertheless apply.

2. FUNDS

Any funds transferred into the Bank’s trust account shall be deemed to be funds entrusted for safekeeping by the Bank. Such funds will be held in a bank account at a correspondent bank or custodian in the Bank’s name designated as a client account. At all times this account will be segregated from the Bank’s own funds.The funds may be held with other client money in a pooled arrangement at the correspondent bank or custodian. Where funds held on a Client’s behalf are placed on deposit at another financial institution, all interest earned on such funds will be credited to the Client’s account.
The Bank does not ensure the tax consequences of any transaction.

3. AUTHORIZED SIGNATURES

The list of signatures of persons authorized to sign for the Client, which the Client had filed with the Bank, shall be binding upon the Client until written notice of changes shall have been received by the Bank. The Bank will require each authorized signatory to provide its standard due diligence information as set out in its application form. Each new signatory to an account will also be required to provide the Bank’s standard due diligence information for consideration before being accepted as a signatory to an account.The Bank reserves the right to reject any signatory to an account where such signatory fails to satisfy or maintain the Bank’s established standards. Each authorized signatory will be required to provide updated due diligence information from time to time. Failure to provide updated information upon request may lead to the suspension of the relationship.

4. JOINT ACCOUNTS

All funds, property or other assets held by the bank for the credit of two or more Clients jointly or in joint names shall be the property of the joint account holders as joint tenants, and the Bank may rely upon and act in accordance with the instructions of and deal with instructions purporting to be made, drawn, accepted, endorsed or given by either or all of them or otherwise as indicated on the Account Opening Form.The liability of joint account holders to the Bank shall be joint and several. Unless expressly indicated to the contrary,the Bank may act upon the instructions of a survivor and deal with instruments signed by the survivor alone. Such survivors shall notify the Bank immediately upon the death of one of their number and the Bank shall be entitled to call for and rely upon evidence (if any) of death. If a joint account is opened, remittances received by one account holder only shall automatically be credited to the joint account unless a separate account exists in the exclusive favour of the named Client or unless the Bank is in possession of instructions to the contrary.

5. CORPORATE CLIENTS

A corporate Client shall notify the Bank in writing of any amendments to its Memorandum, Articles of Association or corresponding documents or any change in its name, directors, officers, authorized signatories or mandate as contained in the Account Opening Form or the then-current mandate. The Bank may rely upon, or decline any notice of amendment, or revocation of any mandate, or instructions given to it, until such time as evidence to its satisfaction has been received confirming the authority and validity of such notice. Until such time, the Bank may rely and act upon instructions given to it by an authorized signatory designated as such in the then-current mandate without liability on its part.

6. STATEMENT OF CLIENT ACCOUNT

The Bank at the close of each accounting period, for the particular client account shall forward to the Client unless otherwise directed, a statement pertaining to that particular account for the preceding accounting period. Objections to such statement or to other communications from the Bank must be made immediately. In the case of delay in making such objection, any loss resulting therefrom shall be borne by the Client. Further notice must be given immediately to the Bank when an expected notice is not received by the Client in due time. If notice is not given within thirty (30) days, the statement of account shall be deemed to be approved. All communication by the Bank shall be deemed to have been transmitted when sent to or held at the disposal of the Client in accordance with his instructions, or for his protection in a manner which deviates therefrom. The date of the copies or mailing lists in the possession of the Bank shall be deemed to be at the time of dispatch.

7. CLIENT ACCOUNT IN FOREIGN CURRENCY

The funds held on behalf of Clients corresponding to Clients’ credit balances in foreign currencies are held in the same currency in or outside of the country whose currency is involved.The Client bears proportionately to his account balance all economic and legal consequences resulting from measures taken by the country of the currency or by the country where the Client’s funds are invested and affecting all the Bank’s trust assets held in either country.Obligations of the Bank arising from foreign currency client accounts shall be discharged exclusively at the place of business of the Bank. Remittances received in a currency for which there is no corresponding account of the Client shall be credited at the Bank’s discretion to an already-existing account of the Client and shall be maintained in the currency of the said existing account of the Client.

8. DRAFT, CHEQUES & OTHER INSTRUCTIONS

If drafts, cheques and other instruments received by the Bank for collection or discount are not paid, or if the proceeds thereof cannot be freely disposed of, the Bank shall be entitled to cancel any credit given and charge the Client’s account for the same, and shall retain its rights in connection with such instruments until the payment of all indebtedness including all costs and expenses of the collection. The Bank will give value for cheques and drafts only after the lapse of the number of business days indicated in its Schedule of Minimum Amounts, Fees and Conditions, calculated from the business day following the day of receipt.

9. ERRORS IN TRANSMISSION/FORGERIES/ IDENTIFICATION

Damage resulting from delays, losses or mistakes in transmission of any advice, instructions in whatever format shall be borne by the Client. Likewise, the Client shall bear all losses resulting from failure by the Bank to discover forgeries or other defects, particularly with respect to identification or capacity to act. Neither the Bank or any related person shall be liable for any costs, expenses, losses or damages whatsoever excluding only the consequences of actual fraud on the part of the Bank or any employee of the Bank. Moreover, the Bank shall be entitled without liability on its part to refuse to act if in its opinion,there is any doubt as to the validity or authenticity of any instructions given.

10. PAYMENT INSTRUCTIONS

The Bank will execute payment instructions provided they do not include conditional clauses, timing requirements or approval of documents. Where payments are executed through a correspondent bank, that Bank’s charges, if any, will be borne by the beneficiary, unless otherwise stipulated by the Client. In case of delay in carrying out payment instructions, the Bank shall in no event be liable for more than the payment of interest for the period involved, except where its attention has been specifically directed to the risk of additional damage.

11. CUSTODIAN ACCOUNTS

  • Duties of the Bank -Securities and other valuables shall be kept in custody accounts with the same care as the Bank’s own property..The Bank may keep the property in custody abroad in its name for the account and risk of the Client. Unless the Client specifies separate custody and agrees to assume expenses thereof, the Bank is expressly authorized to effect the safekeeping of securities in nominee format pooled with other Client securities. Any additional amounts that may be paid to the Bank as a result of pooled investments will be for the Bank’s account and not that of the Client. The safe custody charges set out in the Bank’s Schedule of Services and Fees will apply.
  • Duties of the Client -Unless otherwise agreed, the Client must take all other steps necessary to protect his rights in connection with the property deposited, in particular, the giving of instructions for the exercise or sale of subscription rights or conversion rights for the payment of calls on partly paid shares, and for effecting exchanges of securities. If no instructions are received from the Client, the Bank shall be entitled to act in its discretion.

12. NO TRUSTS

Where a Client is acting as Trustee or in any other fiduciary capacity or where the rights of the Client against the Bank are subject to any encumbrance, equity or third-party interest, then, notwithstanding any notice of the same, the Bank shall be entitled to disregard the same and to treat the Client as absolute beneficial and unencumbered owner subject to any written directions from the Client to the Bank properly made in accordance with these conditions and the then-current mandate.This provision and all other provisions contained in these conditions and the current mandate shall be binding on all third parties claiming an interest in the account.

13. ADJUSTMENT OF CREDITS, RATES AND COMMISSIONS, SET-OFF & LIEN

Except where otherwise agreed by the Bank in writing, the Bank shall be entitled to adjust interest credits, exchange rates and commissions, effective immediately, to the prevailing conditions, and at any time to terminate business relationships. The Bank shall be entitled at any time to set-off against each other the balances of all accounts of the Client (irrespective of the currency of the account), or to enforce the same individually. The Bank shall have a lien on all assets which are held for the Client for all claims, whether or not such claims shall be due, and whether or not in the case of extensions of credit such claims shall be unsecured by specific collateral. In the event of default by the Client, the Bank shall be entitled to realize such assets, which assets are hereby transferred to the Bank for such purpose.

14. LIABILITY & INDEMNITY

The Bank shall not be liable for decisions left to its discretion or otherwise in the absence of its fraud and dishonesty. The Client shall indemnify the Bank against all loss, damage, liability and expense as it may suffer or incur as a result of the relationship otherwise than as a result of its fraud or dishonesty, and the Bank shall be entitled to debit any account of the Client for the purpose of satisfying such indemnity.

15. SETTLEMENT OF CLAIMS

Place of Performance -The place of business of the Bank shall be the place of performance of the obligations of the Bank and the Client, as well as the place for the instituting of proceedings for the collection of debts owed by Clients domiciled abroad.
Governing Law -The legal relationship between the Bank and the Client shall be governed by the laws of Barbados.The Client shall submit to this jurisdiction in the case of any legal proceedings brought by the Bank against him, but the Bank shall be entitled to bring proceedings against the Client at his country of domicile or in any other competent jurisdiction, in which event, the laws of Barbados will nevertheless apply. The service of process out of any court in any proceedings instituted against the Client may be effected by air-mailing of copies with postage prepaid to such address as shall have been notified to the Bank or known to the Bank and in any other manner permitted by law.
Conflicting Claims -In the event of conflicting claims in respect of any Client account or any part of the monies or other assets held by the Bank, the Bank may in its absolute discretion take such steps as it may deem necessary to safeguard its interest and shall not in any event be liable for complying with any order of any court in Barbados or elsewhere.The Bank shall be entitled without liability to the Client, pending determination of any such claim, to refuse to pay or deliver to the Client any monies or other assets in its possession or control which are the subject of such conflicting claims
Probate Laws -In the event of death of a single signatory to an account, the probate laws of Barbados in force shall apply.

16. MINIMUM AMOUNTS, FEES & CONDITIONS

The Bank’s Schedule of Minimum Amounts, Fees and Conditions from time to time in force is an integral part of these General Conditions, and special regulations and conditions applying to particular kinds of business and service shall become a part of these General Conditions in the event the particular kinds of business and service are provided by the Bank.

17. DISCLOSURE OF INFORMATION

The preservation of secrecy for banking establishments carrying on business within Barbados provided for under Section 46 of the International Financial Services Act, Chapter 325 of the Laws of Barbados, or any amendments thereto, is subject to qualifications. The Bank, its officers and directors, employees and mandatories are obliged to furnish certain information when lawfully required to do so by any Court of competent jurisdiction within Barbados under the provisions of any law of Barbados.Further,they may disclose information relating to the identity, assets, liabilities, transactions and accounts of the Client with the express or implied consent of the Client. The establishment of client accounts and securities deposits maintained under numbers or passwords is an internal measure by the Bank, affecting in no way its obligation vis-à-vis authorities to give evidence or information. The Bank shall at all times be subject to the direction of the Client. Unless otherwise advised by the Client, the Bank may act on oral instructions from any person authorized to give written directions pending delivery to the Bank of such written directions.The Bank shall not be obliged or required to determine whether any instructions issued to it by the Client are in compliance with any law or regulation.
Nothing herein shall restrict, limit or negate any rights of the Bank by law expressed or implied.

CIDEL BANK CANADA,
CIDEL ASSET MANAGEMENT INC.,
CIDEL TRUST COMPANY

The following policy has been established by Cidel Bank Canada, Cidel Asset Management Inc. and Cidel Trust Company (each, the“Company”) to govern the provision of services with Regulation 191/11, “Integrated Accessibility Standards” (“Regulation”) under the Accessibility for Ontarians with Disabilities Act, 2005.

These standards are developed to break down barriers and increase accessibility for persons with disabilities in the areas of information and communications and employment.

Statement of Commitment

The Company is committed to ensuring equal access and participation for people with disabilities. The Company is committed to treating all people in a way that allows them to maintain their dignity and independence. We believe in integration and equal opportunity. We are committed to meeting the needs of people with disabilities in a timely manner, and will do so by preventing and removing barriers to accessibility and meeting accessibility requirements under the Accessibility for Ontarians with Disabilities Act, 2005 and its regulations.

Accessibility Plan

The Company will develop, maintain and document an Accessibility Plan outlining the company’s strategy to prevent and remove barriers from its workplace and to improve opportunities for persons with disabilities.

The Company’s Accessibility Plan will be posted on the company website and will be reviewed and updated at least once every five years. Upon request, we will provide a copy of the Accessibility Plan in an accessible format.

See below for most recent plan.

Training

The Company will ensure that training is provided on the requirements of the Regulation which includes training on the Ontario Human Rights Code as it pertains to persons with disabilities

This training applies to:

  • all employees and volunteers;
  • all persons who participate in developing the Company’s policies; and,
  • all other persons who provide goods, services or facilities on behalf of the company

The training will be appropriate to the duties of the employees, volunteers and other persons.

Employees will be trained when changes are made to the Accessibility Policy. New employees will be trained as part of the onboarding process, as soon as practicable.

The Company will keep a record of the training it provides.

Information and Communications

Feedback

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

Accessible Format and Communication

Upon request, The Company will provide, or will arrange for the provision of accessible formats and communication supports for persons with disabilities in a timely manner that takes into account the person’s accessibility needs due to disability. The Company will consult with the person making the request in determining the suitability of an accessible format or communication support.

Accessible Website and Web Content

The Company will ensure that all The Company websites, including web content, conform to the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0, at Level A by January 1, 2014, except where this is impracticable.

The Company will ensure that all The Company websites, including web content, conform to the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0, at Level AA by January 1, 2010, except where this is impracticable.

Employment

The Company is committed to fair and accessible employment practices.

Recruitment

The Company will notify its employees and the public about the availability of accommodation for applicants with disabilities in its recruitment process.

The Company will notify job applicants when they are individually selected to participate further in an assessment or selection process that accommodations are available upon request in relation to the materials or processes to be used.

If a selected applicant requests an accommodation, The Company 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 accessibility needs due to disability.

When making offers of employment, The Company will notify the successful applicant of its policies for accommodating employees with disabilities.

Informing Employees of Supports

The Company will continue to inform its employees of its policies (and any updates to those policies) used to support employees with disabilities, including policies on the provision of job accommodations that take into account an employee’s accessibility needs due to disability. This information will be provided to new employees as soon as practicable after commencing employment.

Accessible Formats and Communication Supports for Employees

Upon the request of an employee with a disability, The Company 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 his or her job, and information that is generally available to other employees. In determining the suitability of an accessible format or communication support, The Company will consult with the employee making the request.

Workplace Emergency Response

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

Where the employee requires assistance, The Company will, with the consent of the employee, provide the workplace emergency response information to any persons designated by The Company to provide assistance to the employee.

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

Individual Accommodation Plans

The Company will develop and have in place a written process for the development of documented individual accommodation plans for employees with disabilities in accordance with the requirements set out in the Regulation.

Where requested, an employee’s individual accommodation plan will include any information regarding the provision of Accessible Formats and Communications Supports.

Where required, an employee’s individual accommodation plan will include individualized workplace emergency response information.

 

Return to Work Process

The Company will develop will have in place a documented process  for the return to work of an employee returning from any disability related leave and/ or require disability-related accommodations in order to return to work

The return to work process will outline the steps the Company will take to facilitate the employee’s return to work and will include documented individual accommodation plans as part of the process

Performance Management, Career Development and Advancement & Redeployment

The Company will take into account the accessibility needs of employees with disabilities, as well as individual accommodation plans, when conducting performance management, providing career development and advancement to employees, or when redeploying employees.

Questions about this policy

If anyone has questions about this policy, please contact hr@cidel.com.

 

Five Year Accessibility Plan

Section Initiative Description Action Status
3 Establishment of Accessibility Policies 3.(1) 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. Develop Policy and post on website
4 Accessibility Plans 4.(1) 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
Compliance and HR Department will review and update the
accessibility plan at least once every five years
Complete
Review every
5 years
7 Training 7.(1) 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.
Develop mandatory
firm wide training program

 

 

 

Part 2 – Information and Communications Standards

Section Initiative Description Action Status
11 Feedback 11.(1) 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. Develop feedback mechanisms
12 Accessible Formats & Communication Supports 12.(1) 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.12.(2) The obligated organization shall consult with the person making the request in determining the suitability of an accessible format or communication support.12.(3) Every obligated organization shall notify the public about the availability of accessible formats and communication supports.
Integrated into Individual Workplace
Accommodation Plan
As required
13 Emergency Procedures, Plans or Public Safety Info 13.(1) In addition to its obligations under section
12, 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.
Develop process and policy Complete
14 Accessible Websites & Web Content 14.(2) Designated public sector organizations and 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. Developed web site as per requirement and will continue to leverage current guidelines for future changes. January 1, 2014
New internet websites and web content on those sites must conform with WCAG 2.0 Level
A. January 1, 2010
All internet websites and web content must conform with WCAG 2.0 LevelAA, other than,
• success criteria 1.2.4 Captions (Live)
• success criteria 1.2.5 Audio Descriptions (Pre-recorded).

 

 

 

Part 3 – Employment Standard

Section Initiative Description Action Status
22 Recruitment – General 22. Every employer shall notify its employees and the public about the availability of accommodation for applicants with disabilities in its recruitment processes. Develop process Complete
23 Recruitment, Assessment or Selection Process 23.(1) 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.
(2) 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 in a
manner that takes into account the applicant‘s accessibility needs due to disability
Develop process Complete
24 Notice to Successful Applicants 24. Every employer shall, when making offers of employment, notify the successful applicant of its policies for accommodating employees with disabilities. Develop process Complete
25 Informing Employees of Supports 25.(1) Every employer shall inform its employees of its policies used to support its 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.

25.(2) Employers shall provide the information required under this section to new employees as soon as practicable after they begin their employment.

25.(3)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

Develop process Complete
26 Accessible Formats & Communication Supports for
Employees
26.1 In addition to its obligations under section 12, 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.26.2. The employer shall consult with the employee making the request in determining the suitability of an accessible format or communication support.
Integrated into Individual Workplace Accommodation Plan As required
27 Accessible Formats & Communication Supports for Employees 27.(1) Every employer shall provide individualized workplace emergency response
information to employees who have a disability, if the disability is such that the individualized information is necessary and the employer is aware of the need for accommodation due to the employee’s disability.(2) 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.(3) 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.(4) 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.
Develop process and policy Complete
28 Documented Individual Accommodation Plans 28.(1) 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.28 (2) The process for the development of documented individual accommodation plans
shall include the following elements:
1.The manner in which an employee requesting accommodation can participate in the development of the individual accommodation plan.
2. The means by which the employee is assessed on an individual basis.
3. 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 and how accommodation can be achieved.
4. The manner in which the employee can request the participation of a representative
from their bargaining agent, where the employee is represented by a bargaining
agent, or other representative from the workplace, where the employee is not represented by a bargaining agent, in the development of the accommodation plan.
5. The steps taken to protect the privacy of the employee’s personal.
6. The frequency with which the individual accommodation plan will be reviewed and updated and the manner in which it will be done.
7.If an individual accommodation plan is denied, the manner in which the reasons for the denial will be provided to the employee.
8. The means of providing the individual accommodation plan in a format that takes into account the employee’s accessibility needs due to disability.
Develop process and policy
29 Return to Work Process 29.(1) 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.29. (2) 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 individual documented accommodation
plans, as described in section 28, as part of the process29. (3) 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.
Develop process and policy
30 Performance Management 30.(1) 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. Integrated into Individual Workplace
Accommodation Plan
31 & 32 Career Development & Advancement 31.(1) 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.32. (1) 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.
Integrated into Individual Workplace Accommodation Plan

Each Cidel entity (“Cidel”) is committed to ensuring that its internal policies, practices, and systems are free of barriers, emphasize the value of diversity, and promote full participation to ensure dignity, respect, and equal access for all employees.

Through our processes and practices, we are working to eliminate barriers to employment for people who are usually underrepresented in Canada’s workforce – Aboriginal people, people with disabilities, racialized persons, and women.

Consistent with human rights legislation, employment equity recognizes the value and dignity of each individual and ensures everyone has genuine, open and unhindered access to employment opportunities, free from any barriers, systemic or otherwise.

Cidel’s established employment equity statement reflects this:

Cidel is committed to equity in its policies, practices, and programs, supports diversity in employment, learning and work environments, and ensures that applications from members of underrepresented groups are seriously considered under its employment equity policy. All qualified individuals who would contribute to the further diversification of Cidel are encouraged to apply.