Individual Accommodation Plan Policy

Multi-Year Accessibility Plan | Individual Accommodation Plan Policy | Reports

Effective Date: June 23, 2026

Purpose

This policy establishes Brand Momentum’s process for requesting, developing, implementing, documenting, and reviewing Individual Accommodation Plans (IAPs) for employees with disabilities, in accordance with the Accessibility for Ontarians with Disabilities Act, 2005 (AODA) and Ontario Regulation 191/11, the Integrated Accessibility Standards Regulation (IASR).

Brand Momentum is committed to providing an inclusive workplace and accommodating employees with disabilities up to the point of undue hardship, in line with both the AODA and the Ontario Human Rights Code.

Legislative Basis

Section 28(1) of the IASR requires employers, to develop and maintain a written process for the development of documented Individual Accommodation Plans for employees with disabilities. This policy is also informed by the Ontario Human Rights Code, which has primacy and overrides the AODA where there is a conflict, with the law offering the higher level of accessibility taking precedence.

Definitions

• Disability: Has the same meaning as under the Ontario Human Rights Code, and includes both visible and non-visible disabilities, whether permanent, temporary, or episodic.
• Individual Accommodation Plan (IAP): A written document outlining the specific accommodations agreed upon between an employee and Brand Momentum to address disability-related needs in the workplace.
• Undue Hardship: The legal threshold beyond which an employer is not required to provide accommodation, assessed based on cost, and outside sources of funding, if any, and health and safety requirements, if any.

Scope

This policy applies to all employees of Brand Momentum who require workplace accommodation related to a disability. This includes accommodation requests made at any stage of employment, including recruitment, onboarding, active employment, return-to-work following a disability-related absence, and redeployment.

Roles and Responsibilities

• Employee: Initiates accommodation request; participates in good faith in plan development; provides relevant information about functional needs (not required to disclose the specific diagnosis). Cooperate in the accommodation process by providing reasonable information relating to functional limitations and participating in discussions regarding appropriate accommodation.
• Manager: Engages with the employee; escalates to People Operations; supports implementation of approved accommodations
• People Operations: Coordinates the IAP process; maintains documentation; arranges third-party medical or expert input where needed; ensures confidentiality
• Senior Director, People Operations: Reviews accommodation requests involving significant operational or financial impact, approves accommodation measures where required, reviews any proposed denials before they are communicated to the employee, and provides guidance on complex accommodation matters.

The IAP Process

1. Initiating a Request: An employee may request accommodation directly, or Brand Momentum may initiate a conversation if it becomes aware that an employee may need accommodation to perform their job. The worker has the most knowledge about their own needs and what accommodations will best meet those needs.
2. Employee Participation: The employee will be invited to participate fully in the development of their own IAP. The process will address how an employee participates in the development of their individual accommodation plan, how the employee is assessed on an individual basis, how a unionized employee can request a representative from their bargaining agent, and how a non-unionized employee can request a representative from the workplace to participate in the development of the plan.
   • The employee is not required to disclose the specific nature of their disability or diagnosis. The discussion will instead focus on functional limitations and the support needed to perform essential job duties.
3. Individual Assessment: Each accommodation request is assessed on an individual, case-by-case basis. Brand Momentum may request reasonable medical documentation confirming that the employee requires accommodation, outlining the employee’s functional limitations and restrictions, and identifying accommodation-related needs. Brand Momentum will not request information regarding the employee’s diagnosis except where required by law or where it is reasonably necessary to facilitate accommodation.
4. Third-Party Expert Evaluation: Where the information provided is insufficient to determine appropriate accommodation, Brand Momentum may, at its own expense, request an independent medical or other expert assessment. This clarifies that an independent assessment is only requested when necessary.
5. Privacy and Confidentiality: All information collected as part of the IAP process will be kept confidential and stored securely, Accessible only to individuals who require the information for the purpose of administering the accommodation. The steps taken to protect the privacy of the employee’s personal information will be documented as part of this process.
6. Content of the IAP: Where an accommodation is approved, the written IAP will include, where applicable:
   • A description of the accommodation(s) being provided
   • Individualized workplace emergency response information, if required
   • Any other accommodation measures that are to be provided
   • The format in which information will be provided to the employee
   • Timelines for implementation
   • The review schedule for the plan
7. Format of the Plan: The employee’s copy of the IAP, or notice of denial, will be provided in a format that is accessible to that employee.
8. If a Request Is Denied: If an accommodation request is denied, in whole or in part, the denial must be reviewed by the Sr. Director, People Operations before being communicated to the employee. Brand Momentum will provide the employee with written reasons for the decision.
9. Review of the Plan: Reviewed at intervals established in the Individual Accommodation Plan and additionally whenever:
   • The employee’s needs change
   • The employee moves to a different role or physical location
   • Brand Momentum reviews its general accommodation or emergency response policies

While the Integrated Accessibility Standards Regulation (IASR) does not require specific timelines, it is helpful to set expectations for employees. Brand Momentum will make every reasonable effort to respond to accommodation requests promptly and will keep the employee informed throughout the process.

Relationship to Workplace Harassment and Violence Policy

Where a disability is related to, or arises from, an incident of workplace harassment or violence, Brand Momentum will coordinate the Individual Accommodation Plan process with the reporting and investigation procedures set out in the Workplace Harassment and Violence Policy.

This may include accommodations related to safety planning, physical or schedule changes, or support during an ongoing investigation. Nothing in this policy limits an employee’s right to report an incident under the Workplace Harassment and Violence Policy or their protection against reprisal for a good faith complaint, and the two processes will be managed collaboratively by People Operations to ensure the employee’s safety and accommodation needs are addressed without delay.