This accessibility policy outlines the activities that Triple M Metal LP, Giampaolo Group Inc. and its affiliates (collectively, “TMM”) will follow to achieve accessibility and meet the needs of persons with disabilities, as required under the Accessibility for Ontarians with Disabilities Act, 2005 (the “AODA”) and the Ontario Human Rights Code (the “Code” together with the AODA the “Accessibility Legislation”).

As an organization, TMM understands the importance of identifying and removing, in a timely fashion, both existing and new barriers to accessibility for its employees, workers, suppliers and customers. Accordingly, TMM is committed to providing equal access to TMM’s products and services including providing information in an accessible format. We are committed to providing our employees and contract workers reasonable accommodation and equal access to all opportunities. This is accomplished in several ways:

1. Training

TMM has and will continue to develop and implement an accessibility training program for its employees, management, and temporary workers. TMM has and will continue to provide training to its current and new employees and temporary contract workers on the requirements of the Accessibility Legislation as it relates to persons with disabilities and on the accommodations available to persons with disabilities. TMM maintains a record of who was trained and when.

2. Communication

TMM’s published content meets and shall continue to meet the requirements of the AODA thereby ensuring that our published content is accessible to persons with disabilities. TMM has a process to receive and respond to feedback from persons with disabilities.

TMM has and will continue to take appropriate steps to make sure that our websites and web content conform, where practicable, with the World Wide Web Consortium Web Content Accessibility Guidelines (“WCAG”). TMM is committed to ensuring that all of its web content, including websites, will conform with WCAG 2.0 Level AA by January 1, 2021. Until such date, TMM confirms that any new web content will be WCAG 2.0 Level A.

3. Employment

TMM is committed to being an employer of choice in Ontario and in Canada by creating a workplace that prevents and removes barriers to accessibility. To achieve this commitment and to comply with the requirements of the AODA, the Organization took the following steps prior to January 1, 2016:

  • advise applicants during the recruitment process of the availability, upon request, of accommodation for persons with disabilities;
  • provide or arrange for the provision of suitable accommodations during the recruitment process, upon request, for persons with disabilities who have been selected to participate in an assessment or selection process;
  • advise applicants when making offers of employment of the Organization’s policies for accommodating persons with disabilities;
  • inform current and new employees, as soon as practicable, of the Accessibility Policy;
  • provide or arrange for the provision of accessible formats and communication supports, upon request, necessary for persons with disabilities to perform their job;
  • provide individualized workplace emergency response information to persons with disabilities;
  • develop a written process to assess persons with disabilities and to develop and document individual accommodation plans, provided that the Organization is aware of the need for such accommodation;
  • develop and document a return to work process for employees who have been absent from work due to a disability;
  • develop a process to factor the accessibility needs of an employee, including any applicable individual accommodation plans, when conducting performance reviews; and
  • factor in an employee’s accessibility needs, including any applicable individual accommodation plans, when redeploying employees with disabilities.

4. Contact Information

Please contact Humanresources@triplemmetal.com with any questions on the foregoing or TMM’s accessibility policy.

5. Intellectual Property Notice

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Last Updated: April 1, 2019