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Accessibility

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EBC’s Accessibility Plan

Last updated May 2024

Our Commitment To Accessibility

EBC is committed to meeting the accessibility needs of persons with disabilities in a timely manner, consistent with the principles of dignity, independence, integration and equal opportunity. The purpose of this Accessibility Plan (this “Plan”) is to outline Exchange Bank of Canada’s (EBC) strategy to prevent and remove barriers to accessibility. This Plan includes but is not limited to the commitments of EBC to applicable legislation.

General
VP, HR and CCO are designated to receive feedback on barriers and EBC’s accessibility plans. These designated individuals can be contacted by any of the following means:

This Plan is publicly available on our website at https://www.ebcfx.com/en. This Plan is also available in an alternate accessible format upon request by contacting us through any of the methods set out on EBC’s Contact Us page.

Executive Summary
EBC is committed to meeting the accessibility needs of persons with disabilities in a timely manner, consistent with the principles of dignity, independence, integration and equal opportunity. The purpose of this document is to outline EBC’s strategy to prevent and remove barriers to accessibility in the areas of employment, the built environment, information and communication technologies (ICT), communication, other than ICT, the procurement of goods, services, and facilities, the design and delivery of programs and services, and transportation. This document also describes how EBC consulted persons with disabilities in the preparation of this plan, and how EBC will provide training, budget and resource allocation, and maintenance and review of this Plan.

EBC has identified the following barriers and actions to remove them in each area:

  • Employment: EBC will provide accommodation in recruitment, during employment, and in return to work processes. EBC will require written information from the employee regarding their disability-related needs then determine the most appropriate form of accommodation.
  • The Built Environment: EBC operates in leased office spaces that are maintained by the property management. EBC will request the property management to provide the building’s accessibility plan and to ensure that the building meets the accessibility standards. EBC will also ensure that its own office space is accessible to employees and clients (if applicable).
  • Information and Communication Technologies (ICT): EBC will provide or arrange for accessible formats and communication supports for documents and feedback processes upon request. EBC will also ensure that its website and online services are compatible with support for screen readers and meet or exceed WCAG 2.0 Level AA standards.
  • Communication, other than ICT: EBC will provide or arrange for accessible communication formats and communication supports for persons with disabilities who interact with EBC through telephone, e-mail, mail, or in-person.
  • The Procurement of Goods, Services, and Facilities: EBC will incorporate accessibility criteria and features when procuring or acquiring goods, services, or facilities, except where it is not practicable to do so. EBC will also provide an explanation upon request when it is not practicable to incorporate accessibility criteria and features.
  • The Design and Delivery of Programs and Services: EBC will ensure that its programs and services are accessible to persons with disabilities. EBC will also consider the needs of persons with disabilities when designing, reviewing, or modifying its programs and services.
  • Transportation: EBC does not provide transportation services to its employees or clients. However, EBC will ensure that any transportation services that it contracts or arranges for its employees or clients are accessible to persons with disabilities.


EBC consulted persons with disabilities in the preparation of this Plan by conducting surveys with its employees, clients, and external stakeholders. EBC received feedback on the current and potential barriers to accessibility in each area, as well as suggestions for improvement and best practices. EBC will continue to consult persons with disabilities in the implementation and review of this Plan.

EBC will provide training to its employees and other persons on accessibility in employment as they pertain to persons with disabilities. EBC will also provide training on the specific accessibility policies, programs, practices, and services that are relevant to each person’s role and responsibilities. EBC will ensure that the training is appropriate to the person’s needs and is delivered in an accessible format and communication support upon request.

EBC will allocate sufficient budget and resources to implement and maintain this Plan.

EBC will also monitor and evaluate the effectiveness and outcomes of this Plan. EBC will also review and update this Plan at least every five years, or as required by applicable legislation. The next scheduled review is 2029, unless an earlier review is required.

Accessibility statement

EBC is a leading provider of foreign exchange and international payment services to businesses and financial institutions across Canada. We operate as a business-to-business model, serving our clients through our online platform, phone, and email.

EBC is committed to meeting the accessibility needs of persons with disabilities in a timely manner, consistent with the principles of dignity, independence, integration and equal opportunity. We comply with the Accessible Canada Act (ACA) and other applicable legislation, and we strive to identify, remove and prevent barriers to accessibility in our policies, programs, practices and services.

As part of this Plan, we have consulted with persons with disabilities, including our employees, clients, and experts, to identify the potential barriers and the best practices to address them. We have also established a process to receive and respond to feedback on accessibility issues, and to provide or arrange for accessible formats and communication supports upon request.

Some of the actions we have taken or will take to promote accessibility include:

  • Providing fair and accessible employment practices and opportunities, from recruitment to retention, and ensuring reasonable accommodations are made available to employees with disabilities throughout the employment relationship.
  • Ensuring that our physical premises are accessible to persons with disabilities, and that any changes to the built environment are done in consultation with the property management and accessibility experts.
  • Ensuring that our online platform, website, and other information and communication technologies (ICT) are compatible with various assistive devices and software, and that they meet or exceed the Web Content Accessibility Guidelines (WCAG) 2.0 Level AA standards.
  • Ensuring that our communication with clients and other stakeholders, other than ICT, is done in a manner that takes into account their accessibility needs and preferences, and that we offer alternative methods of communication, such as phone, email, or mail.
  • Ensuring that our procurement of goods, services, and facilities considers accessibility criteria and features, and that we work with our suppliers and partners to promote accessibility in our supply chain.
  • Ensuring that our design and delivery of programs and services are inclusive and accessible to persons with disabilities, and that we consult with them to understand their needs and expectations.
  • Providing training to our employees and other persons on accessibility in employment and human rights as they pertain to persons with disabilities, and on the requirements and best practices of the ACA and other relevant legislation.

We will review and update this Plan at least every five years, or as required by applicable legislation. The next scheduled review is 2029. We will monitor and evaluate our progress and outcomes, and report on them publicly on our website.

We welcome your feedback and suggestions on how we can improve our accessibility. You can contact us through any of the methods set out on our Contact Us page, or by emailing [email protected]. We will respond to your feedback as soon as possible and provide or arrange for accessible formats and communication supports if needed.

We are proud of our commitment to accessibility, and we look forward to serving you in a way that respects your dignity and independence.

Definitions

Accessibility: The degree to which a product, device, service, environment, or facility is usable by as many people as possible, including persons with disabilities. Accessibility also refers to the ability of persons with disabilities to access and benefit from the same opportunities, services, and information as others, without barriers or discrimination.

Accessible Canada Act (ACA): The federal legislation that aims to make Canada barrier-free by 2040 in the areas of employment, the built environment, information and communication technologies, communication other than information and communication technologies, the procurement of goods, services and facilities, the design and delivery of programs and services, and transportation.

Barrier: means anything—including anything physical, architectural, technological or attitudinal, anything that is based on information or communications or anything that is the result of a policy or a practice—that hinders the full and equal participation in society of persons with an impairment, including a physical, mental, intellectual, cognitive, learning, communication or sensory impairment or a functional limitation.

Disability: means any impairment, including a physical, mental, intellectual, cognitive, learning, communication or sensory impairment—or a functional limitation—whether permanent, temporary or episodic in nature, or evident or not, that, in interaction with a barrier, hinders a person’s full and equal participation in society.

Regulatory

The ACA forms the basis of this Plan. It also serves to recognize the existing human rights framework that supports equality for people with disabilities. The ACA builds of these framework to identify, remove and prevent barriers to accessibility. The purpose of the ACA is to make Canada barrier-free by January 1, 2040 in the areas described below. EBC is committed to identify any barriers for persons with disabilities and provide any accommodations and treat such persons with fairness and equality.

Employment

EBC has identified potential barriers for job applicants with disabilities in the hiring and recruitment process and employees who require accommodations during employment. EBC describes below the steps it will take the remove these barriers.

Accommodation in Recruitment

EBC is committed to fair and accessible employment practices and opportunities, beginning with the recruitment process. Job applicants will be notified by way of the job posting that accommodations are available upon request for persons with disabilities.

Candidates chosen to attend an interview in the recruitment process for any vacant position or opening with EBC will be informed that accommodations are available upon request for the interview process. Should the candidate require an accommodation or communication support, a Human Resource representative will consult with the candidate to determine the most appropriate form of accommodation.

Further, any letter of employment subsequently issued will note that accommodation will be available for employees with a disability and will also inform the prospective employee of EBC’s policies on accommodating employees with disabilities.

Accommodation during Employment

EBC is committed to ensuring that reasonable accommodations are made available to employees with disabilities throughout the employment relationship.

EBC and the employee have an obligation to recognize and identify the need for accommodation. EBC will work with employees to accommodate individual disability needs. The need for accommodation can be identified and/or requested by:

  1. the employee,
  2. EBC, or
  3. any third-party disability management, STD or LTD

Once the need for accommodation is identified, the Workplace Parties will be responsible for working together to gather relevant information and assess the specific accommodation needs.

Gathering Relevant Information to Assess Accommodation Needs

The following standards is applied during the information gathering process:

If an employee requests accommodation of a disability, EBC will require written information from the employee regarding their disability-related needs, including medical documentation regarding any restrictions or limitations an employee may have. Only information about the employee’s functional abilities and restrictions will be required and may be requested from the employee or the employee’s medical professional. The specific nature of the employee’s disability or illness and/or any diagnosis is not relevant to the accommodation assessment.

The Built Environment

EBC operates in a leased office space located in a building with other offices. Accessibility to the building is maintained by the building manager, who is responsible for ensuring that the building complies with the applicable accessibility standards and regulations. EBC outsources its building and does not have direct control over the building structure or maintenance.

EBC is not a retail bank or branch, and its facilities are only limited to employees and on a limited basis to business clients. EBC does not provide any services to individual clients or the general public. Therefore, the accessibility needs of EBC’s clients and vendors are minimal.

Once inside the office, EBC’s office location is on one floor. The office has accessible features such as marked doors, elevators, ramps, and accessible washrooms. EBC also provides reasonable accommodations to its employees with disabilities, such as ergonomic furniture, assistive devices, or flexible work arrangements.

However, EBC recognizes that there may be some barriers in the built environment that could hinder the full and equal participation of persons with disabilities. Some of these barriers are:

  • The clean space by the elevators, where sometimes there are bags or boxes thrown out there, which could pose a tripping hazard or obstruct the access for people using wheelchairs or other mobility aids.
  • The lack of signage or wayfinding in the building, which could make it difficult for people with visual impairments or cognitive disabilities to navigate the premises.
  • The noise level in the office, which could affect the concentration or communication of people with hearing impairments or sensory sensitivities.

EBC is committed to identifying, removing, and preventing these barriers in the built environment, in collaboration with the building manager and the property management. EBC has requested from the property management the building’s accessibility plan, and will review it to ensure that it aligns with EBC’s accessibility goals and obligations. EBC will also consult with its employees and clients with disabilities to gather feedback on the accessibility of the built environment, and to determine the most appropriate and effective solutions to remove any barriers.

Information and Communication Technologies (ICT)

EBC is committed to ensuring that its information and communication technologies (ICT) are accessible, usable, and compatible for persons with disabilities. ICT includes any equipment, system, or service that is used to create, store, process, transmit, receive, or exchange information, such as computers, mobile devices, software applications, websites, online platforms, digital documents, telephones, and email.

EBC recognizes that barriers may exist in the way it provides or communicates information through ICT, such as in the design, functionality, or compatibility of its ICT systems or services. EBC aims to identify and remove these barriers and prevent new ones from arising, in consultation with its employees, clients, and other stakeholders.

Some of the barriers we have identified in this area are:

  • Lack of compliance with the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA standards for some of our website and online platform features, such as forms, buttons, or images
  • Lack of alternative formats or communication supports for some of our digital documents, such as PDFs, spreadsheets, or presentations

Some of the actions we have taken or will take to remove these barriers are:

  • Update our website to meet or exceed WCAG 2.1 Level AA standards for new or significantly refreshed applications delivered through the web or accessed on mobile devices wherever possible
  • Providing or arranging for accessible formats or communication supports for our digital documents upon request, such as large print, braille, audio, or plain language
  • Ensuring that our ICT devices and software are compatible with various assistive devices and software, such as screen readers, magnifiers, or speech recognition, and offering alternative devices or software upon request

Communication, other than ICT

EBC recognizes that communication is a vital part of its business and that some persons with disabilities may require accessible communication formats and communication supports to interact with EBC. Communication, other than ICT, refers to any form of communication that is not based on information and communication technologies, such as computers, mobile devices, software applications, websites, online platforms, digital documents, telephones, and email. Examples of communication, other than ICT, include face-to-face communication, written communication, and oral communication.

EBC is committed to providing or arranging for accessible communication formats and communication supports for persons with disabilities who communicate with EBC through any of these methods. EBC will consult with the person with a disability to determine the most appropriate and effective form of communication or support, based on their individual needs and preferences. EBC will also ensure that its staff and service providers are trained and equipped to communicate with persons with disabilities in a respectful and inclusive manner.

Some of the barriers that may exist in communication, other than ICT, are:

  • Lack of alternative formats for written communication, such as large print, braille, or audio formats
  • Lack of communication supports for oral communication, such as sign language interpreters, captioning, or assistive listening devices

Some of the actions that EBC has taken or will take to remove these barriers are:

  • Providing or arranging for alternative formats for written communication upon request, such as large print, braille, or audio formats
  • Providing or arranging for communication supports for oral communication upon request (if feasible), such as sign language interpreters, captioning, or assistive listening devices
  • Establishing a dedicated email address and phone number for receiving feedback on communication accessibility, and responding to any concerns or complaints in a timely and respectful manner

The Procurement of Goods, Services and Facilities

EBC did not receive any feedback on the accessibility of its procurement of goods, services, and facilities from the consultations. This may indicate that the participants did not encounter any barriers or issues in this area, or that they were not aware of or interested in this topic. EBC will continue to seek feedback and input from persons with disabilities on its procurement practices and will make improvements as needed.

To remove any potential barriers in its procurement of goods, services, and facilities, EBC will incorporate accessibility criteria and features when procuring or acquiring goods, services, or facilities, except where it is not practicable to do so. EBC will also provide an explanation upon request when it is not practicable to incorporate accessibility criteria and features. EBC will also ensure that its staff and service providers are trained and aware of the accessibility requirements and best practices in procurement.

The Design and Delivery of Programs and Services

EBC is committed to designing and delivering programs and services that are accessible, inclusive, and responsive to the needs and preferences of persons with disabilities. We recognize that barriers may exist in the way we provide our services, such as in our policies, procedures, practices, or physical environment. We aim to identify and remove these barriers and prevent new ones from arising, in consultation with our employees, clients, and other stakeholders.

Some of the barriers we have identified in this area are:

  • Lack of awareness or understanding of accessibility issues and best practices among our staff and service providers
  • Lack of accessible communication formats and supports for our clients who require them
  • Lack of feedback mechanisms to monitor and evaluate the accessibility and quality of our services

Some of the actions we have taken or will take to remove these barriers are:

  • Providing mandatory accessibility training to all our staff and service providers on an annual basis, covering topics such as the ACA, human rights, disability etiquette, and inclusive communication
  • Ensuring that our website, online platforms, and digital documents are compliant with WCAG 2.1 Level AA standards, and offering alternative formats and communication supports upon request
  • Establishing a dedicated email address and phone number for receiving feedback on our accessibility performance, and responding to any concerns or complaints in a timely and respectful manner

Transportation

EBC does not provide transportation services to its employees or clients. However, EBC will ensure that any transportation services that it contracts or arranges for its employees or clients are accessible to persons with disabilities.

Consultations

EBC used a mixed-methods approach to consult persons with disabilities, including employees, clients, and external stakeholders. The methods included:

  • An anonymous online survey that was distributed to all EBC employees and clients via email. The survey asked about the respondents’ experiences and satisfaction with EBC’s accessibility, as well as their suggestions for improvement. The survey was available in English and French and was compatible with screen readers and other assistive technologies. The survey was open from March 1, 2024 to April 30, 2024, and received 42 responses, of which 6 identified as persons with disabilities.

The consultations revealed that EBC is generally perceived as an accessible and inclusive organization by persons with disabilities, but that there are still some areas that need improvement or attention. The main findings from the consultations are summarized below:

  • The majority of the survey respondents (97%) rated EBC’s accessibility as good and expressed satisfaction with EBC’s commitment to accessibility and its accommodation of individual needs.
  • The most common barriers that were identified by the survey respondents a were related to the built environment, such as ramps, or automatic doors at EBC’s offices, and the limited space for wheelchair users or persons with mobility impairments.

EBC appreciates the feedback and input from the persons with disabilities who participated in the consultations, and will use the findings to inform the development and implementation of its accessibility plan. EBC will also continue to engage and consult persons with disabilities on an ongoing basis to monitor and evaluate the progress and effectiveness of its accessibility plan, and to identify and address any emerging or evolving accessibility needs or issues.

Training

EBC is committed to ensuring that training is provided to employees, as may be required, on accessibility in employment as they pertain to persons with disabilities. In particular, EBC currently provides training to all employees regarding respect in the workplace, including anti-discrimination and anti-harassment.

EBC will also provide training on the ACA and its Regulations, as well as on the policies, programs, practices and services related to the identification and removal of barriers, and the prevention of new barriers, in the areas covered by the ACA. The training will be updated as necessary to reflect any changes to the legislation or EBC’s policies and practices.

EBC will ensure that the training is accessible to all employees, regardless of their disability. For employees who are blind or have low vision, EBC will provide training materials in accessible formats. EBC will keep records of the training provided, including the dates, the names of the participants, and the feedback received. EBC will monitor and evaluate the effectiveness of the training and make improvements as needed.

EBC will provide the training to all existing employees by February 2025, and to all new employees within six months of their hire date. EBC will also provide refresher training to all employees every two years, or as required by any changes to the legislation or EBC’s policies and practices.

Additional information

For additional information on this Plan, you may contact [email protected].

Maintenance and review

This Plan was developed in May 2024 and will be reviewed at least every five years. The next scheduled review is 2029, unless an earlier review is required by applicable legislation.

Feedback Process Description

We welcome your feedback and suggestions on how we can improve our accessibility. You can contact us through any of the methods set out on our Contact Us page, or

  • Mailing address: 390 Bay Street, Suite 700, Toronto ON M5H 2Y2
  • Telephone number: +1 407-536-5500
  • Email: [email protected]

We will respond to your feedback as soon as possible and provide or arrange for accessible formats and communication supports if needed. Where EBC receives a request for an accessible copy of a description of its feedback process, the company provides the description in the accessible format within 45 days in the case of a braille or audio format, or in the case of a request for the plan in any other format, within 20 days.