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RBC Insurance’s Multi-Year Accessibility Plan

Introduction and Statement of Commitment

In 2005, the Ontario government passed the Accessibility for Ontarians with Disabilities Act (AODA). The goal of the Ontario Government is to ensure accessibility in Ontario by 2025. The Integrated Accessibility Standards Regulations (IASR) under the AODA require that effective January 1, 2014 RBC Insurance establish, implement and maintain a multi-year accessibility plan which summarizes our commitment to accessibility.

This accessibility plan outlines the policies and actions that RBC Insurance has and will continue put in place to improve opportunities for people with disabilities and meet accessibility requirements under the Accessibility for Ontarians with Disabilities Act (Integrated Accessibility Standards).

Our Plan

Accessibility Policies

Commitment:

RBC Insurance is committed to:

  • Providing clients with disabilities the same opportunity to access our products and services,
  • allowing clients with disabilities to benefit from the same services, in the same place, and in an equitable way as other customers,
  • providing a professional environment that promotes barrier-free access for all clients as required by applicable legislation,
  • providing employees and job applicants with reasonable accommodation,
  • providing information in ways that are accessible to people with disabilities, and
  • meeting these commitments in a timely manner.

Achievements:

  • Analysis of all current policies and procedures relating to accessibility.
  • Established a committee with representation from key business units to ensure all policies are considered during our review.
  • Leveraged policies already in place along with the IASR and the Ontario Human Rights Code to ensure new policies created are in line with the regulation.
  • Published policies on internal and external sites and ensured its availability in an accessible format.

Actions planned:

  • Review and update the multi-year accessibility plan at least once every five years (Last Published Feb 2023).
  • Our existing policies and procedures relating to accessibility will be reviewed on a regular basis for any updates required to the process, as needed.

Training

Commitment:

RBC Insurance will is committed to provide providing training to employees and contract workers on the requirements of the Accessibility for Ontarians with Disabilities Act (Integrated Accessibility Standards) and on the requirements of the Ontario Human Rights Code as it relates to people with disabilities. Training will be provided in a way that best suits the duties of employees and contract workers.

Achievements:

RBC Insurance has taken the following steps to ensure employees are provided with the training noted above.

  • A training course has been provided and rolled out to all employees and contract workers covered under this legislation.
  • All new employees and contract workers mentioned above will be trained as soon as practicable.
  • We keep records of the training provided under this section.

Actions planned:

  • Whenever an amendment is made or deadline approaching, review and ensure training is re-issued in alignment with the legislation and/or RBC Policies should there be changes.

Information and Communication Standards

Commitment:

RBC Insurance is committed to meeting the communication needs of people with disabilities. We will continue to consult with people with disabilities to determine their information and communication needs.

Feedback, Accessible Formats and Communications Support

Achievements:

  • RBC Insurance has ensured that existing processes for receiving and responding to feedback are accessible to people with disabilities by providing or arranging for the provision of accessible formats and communication supports upon request.
  • RBC Insurance has taken the following steps to provide or arrange for the provision of accessible formats and communication supports, upon request, for persons with disabilities:

    • We provide such accessible formats and communication in a timely manner that takes into account the person’s accessibility needs due to disability.
    • We provide such accessible formats and communication at a cost that is no more than the regular cost charged to other persons.

Actions planned:

Going forward, we will consult with the person making the request to determine the suitability of an accessible format or communication support.

Accessible Websites and Web Content

Achievements:

RBC Insurance has taken the following steps to make all internet websites and web content conform with WCAG 2.0, Level AA, except where meeting such requirements was not practicable, to meet accessibility requirements under the Accessibility for Ontarians with Disabilities Act (Integrated Accessibility Standards):

  • All new internet web sites and web content created, or existing internet web sites have undergone a significant refresh, were made to conform to WCAG 2.0 Level A.
  • All internet web sites and web content on those sites have been updated to conform to WCAG 2.0 Level AA.
  • We have posted resources on our Intranet for employees and contract workers to use in order to meet this requirement.
  • We have ensured that all employees and contract workers involved in the development of our internet web sites and web content are aware of and have access to developer guidelines and best practices for meeting this requirement.
  • We have ensured that all employees and contract workers involved in the testing of our internet web sites and web content are aware of and have access to the testing guidelines and best practices for meeting this requirement.

Actions planned:

  • RBC Insurance will ensure that any new websites and content is accessible to people with disabilities by continually testing and updating to ensure conformance to international standards for website accessibility: World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0.

Self-Service Kiosks

Achievements:

RBC Insurance has taken the following steps to ensure employees have regard to the needs of people with disabilities when procuring or acquiring self-service kiosks:

  • RBC has reviewed all locations and confirmed that Kiosks are not in use at this time.
  • Accessibility questions pertaining to the accommodation of persons with disabilities are available for inclusion in Request For Information (RFI) and Request For Proposal (RFP) procurement templates.

Actions planned:

  • RBC will ensure that, should Kiosks be introduced in the future, any changes since initial review continue to be accessible to customers and employees.

Temporary Disruption

Commitment:

  • In the event of a planned or unexpected disruption in facilities or services, RBC will provide information about the reason for the disruption, how long it is expected to last, and a description of any alternative facilities or services available (where applicable).

Actions planned:

  • Review temporary disruption plan to assess where improvements can be made to ensure an effective application of any temporary disruption process.

Employment Standards

Recruitment

Commitment:

RBC Insurance is committed to fair and accessible employment practices.

Achievements:

RBC has taken the following steps to notify the public and employees that, when requested, we will accommodate people with disabilities during the recruitment, selection, and hiring processes and when people are hired.

  • RBC Insurance will notify all job applicants about the availability of reasonable accommodation for applicants with disabilities in the recruitment, selection and hiring process.
  • RBC Insurance has incorporated this requirement into HR Policies and have advised and made said policies available to all employees and people managers.
  • RBC Insurance will provide accessible documents or information upon request, and when making offers of employment, notify successful job applicants of this policy.

Actions Planned:

  • Our accommodations policies will be reviewed on a regular basis for any updates required to the process, as needed.

Informing Employees of Supports

Commitment:

RBC Insurance will inform all employees of policies that support 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 a disability.

Achievements:

  • RBC Insurance has incorporate the requirement to prevent and remove other accessibility barriers that are identified into HR Policies. These policies have been socialized with and make available to all employees and people managers
  • Informed current employees and new hires of RBC Insurance’s policies on the provision of job accommodations that take into account an employee’s need due to disability;
  • Provide information under this section as soon as practicable after the new employee begins employment, specifically during the onboarding process;
  • Keep employees up to date on changes to existing policies on job accommodations with respect to disability;
  • Where an employee with a disability so requests it, RBC Insurance will provide or arrange for provision of suitable accessible formats and communications supports for:

    • Information that is needed in order to perform the employee’s job;
    • Information that is generally available to employees in the workplace.
  • In meeting the obligations to provide the information that is set out in the paragraph above, RBC Insurance will consult with the requesting employee to determine the suitability of an accessible format or communication support.

Actions Planned:

  • Our accommodations policies will be reviewed on a regular basis for any updates required to the process, as needed.

Documented Individual Accommodation Plans/Return to Work Process

Commitment:

RBC Insurance will incorporate new accessibility requirements to ensure that barriers in accommodation and return to work processes are eliminated and corporate policies surrounding accommodation and return to work are followed, where applicable. RBC Insurance’s existing policies and processes include steps that RBC Insurance will take to accommodate an employee with a disability and to facilitate an employee’s return to work after absenteeism due to disability or injury.

Achievements:

  • Reviewed and assessed the existing policies and processes to ensure that they included steps for the development of a documented individual accommodation plan for employees with a disability, if such plans are required.
  • Ensured that the process for the development of documented individual accommodation plans included the following:

    • How employees requesting accommodations can participate in the development of the individual accommodation plan.
    • How the employee is assessed on an individual basis.
    • How RBC Insurance can request an evaluation by an outside medical or other expert, at the employer’s expense, to assist the employer in determining if accommodation can be achieved, and if so, how accommodations can be achieved.
    • Steps taken to protect the privacy of the employee’s personal information.
    • The frequency with which the individual accommodation plan will be reviewed and updated, and how it will be done.
    • If an individual accommodation plan is denied, how the reasons for the denial will be provided to the employee.
  • Ensured the individual accommodation plan included:

    • Any information regarding accessible formats and communications supports provided by RBC Insurance, if requested.
    • Individualized workplace emergency response information that is required;
    • Any other accommodation that is to be provided.
  • Ensured that the return to work process as set out in existing policies outlines the steps RBC Insurance will take to facilitate the employee’s return to work after a disability-related absence or injury, outlines the development of a written individualized return to work plan for such employees, and if required the use of individual accommodation plans, as discussed above, in the return to work process.

Actions Planned:

  • Our accommodations policies will be reviewed on a regular basis for any updates required to the process, as needed.

Performance Management, Career Development and Redeployment

Commitment:

RBC Insurance will 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.
  • Providing career development and advancement to its employees with disabilities.
  • Redeploying employees with disabilities.

Achievements:

  • Reviewed, assessed, and modified existing policies, procedures, and practices as necessary to ensure the accessibility needs of employees with disabilities are met.
  • Ensure we take the accessibility needs of employees with disabilities and, as applicable, their individualized accommodation plans into account when:

    • Assessing performance,
    • Managing career development and advancement, and
    • Redeployment is required.
  • Reviewed, assessed, and modified if required existing processes to ensure that performance management process and tools take into consideration the accessibility needs of employees with disabilities.
  • Ensured we take into account the accessibility needs of employees with disabilities when providing career development and advancement to its employees with disabilities:

    • Provide people managers with appropriate support to assist in the career development of their employees with disabilities.
  • Develop and document redeployment process for employees with disability in conjunction with the individualized accommodation plans.

Actions Planned:

  • Our accommodations policies will be reviewed on a regular basis for any updates required to the process, as needed.

For More Information

For more information on this accessibility plan, please contact us at:

Email: Insurance Regulatory Governance

Accessible formats of this document are available free upon request from: aodaescalations@rbc.com