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car2go Canada Ltd.
Accessibility for Persons with Disabilities Policy

1.0 Scope

This policy applies to the operations of car2go Canada Ltd. (the “Company”) in Ontario in respect of the provision of goods and services to individuals with disabilities. This policy applies to all persons who are employed by the Company in Ontario, all persons who interact with members of the public or other third parties within the Province of Ontario on behalf of the Company, and all persons who are responsible for developing the Company’s policies.

2.0 Overview

The Company is committed to providing accessible customer service to persons with disabilities. In accordance with the Accessibility for Ontarians with Disabilities Act, 2005 (“AODA”), the Company has developed customer service standards (the “Standards”) that will improve accessibility in a manner that respects the dignity and independence of persons with disabilities. For the purpose of this policy, a customer of the Company shall be referred to as a “member”.

This policy is intended to meet the requirements of Ontario Regulation 429/07 under the AODA. It applies to the provision of goods and services to the public, not the goods or services themselves. This policy aims to ensure that persons with disabilities are provided equal opportunity to obtain, use, and benefit from the Company’s member services.

3.0 Definitions

3.1 Disability means:

a) Any degree of physical disability, infirmity, malformation, or disfigurement that is caused by bodily injury, birth defect, or illness and, without limiting the generality of the foregoing, includes diabetes mellitus, epilepsy, a brain injury, any degree of paralysis, amputation, lack of physical coordination, blindness or visual impairment, deafness or hearing impediment, muteness or speech impediment, or physical reliance on a guide dog or other animal or on a wheelchair or other remedial appliance or device;

b) A condition of mental impairment or developmental disability;

c) A learning disability or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language;

d) A mental disorder; or

e) An injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997.

3.2 Barrier means anything that prevents a person with a disability from fully participating in all aspects of society because of their disability, including a physical barrier, an architectural barrier, an informational or communication barrier, an attitudinal barrier, a technological barrier, a policy, or a practice.

3.3 Service Animal refers to any animal that is used by a person with a disability if it is readily apparent that the animal is used by the person for reasons relating to their disability, or if the person provides a letter from a physician or nurse confirming that the person requires the animal for reasons relating to the disability.

3.4 Support Person refers to another person who accompanies a person with a disability in order to help with communication, mobility, personal care or medical needs or with access to goods or services.

3.5 Assistive Device refers to any device that is designed, made, or adapted to assist a person with a disability in performing a particular task, including physical or technical aids, such as communication devices, canes, crutches, hearing aids, and wheelchairs.

4.0 Accessibility of Services

The Company is committed to excellence in serving all members, including persons with disabilities, and will carry out its functions and responsibilities in the following areas:

Communication: Employees of the Company will communicate with persons with disabilities in a way that takes into account their disability. The Company will train its employees who communicate with members on how to interact and communicate with people with various types of disabilities.

Telephone Services: The Company is committed to providing fully accessible telephone support, including via TTY, to its members, and will train employees to communicate with members over the telephone in clear and plain language and to speak clearly and slowly. The Company will offer to communicate with members by e-mail and/or written letter if telephone communication is not suitable to their communication needs or is not available.

Assistive Devices: The Company is committed to serving persons with disabilities who use assistive devices to obtain, use, or benefit from its goods and services. In addition, the Company will ensure that employees are familiar with various assistive devices that may be used by members with disabilities.

Billing: The Company is committed to providing accessible billing documentation to its members. Member billing documents will be provided in alternative formats upon request. These formats m4.0ay include, but are not limited to, large font and hard copies.

5.0 Use of Service Animals and Support Persons

The Company is committed to welcoming persons with disabilities who are accompanied by a service animal on Company premises, if the public has access to such premises, and will ensure that all employees are properly trained on how to interact with service animals and their owners. It is the responsibility of a person using a service animal to ensure that the service animal is kept in control at all times while on Company premises.

The Company is committed to welcoming persons with disabilities who are accompanied by a support person. Any person with a disability who is accompanied by a support person will be allowed to enter any Company premises to which the public is generally admitted with their support person. At no time will a person with a disability who is accompanied by a support person be prevented from having access to their support person while on Company premises.

6.0 Notice of Temporary Disruption

The Company will notify members in the event of a planned or unexpected disruption in its accessible facilities or member services via the Company website, www.car2go.com. To the extent possible, this notice will include information about the reason for the disruption and the anticipated duration. Employees will be available to assist with locating alternative facilities or services, if available. The notice of temporary disruption will also be placed on the Company’s official mobile application, at all public entrances, or by such other method as is reasonable in the circumstances. Refer to Appendix A for the Notice of Temporary Disruption template.

7.0 Notice of Availability and Format of Documents

The Company’s policies, practices, and procedures related to the Standards will be made available to members and the public upon request. Notification of the availability of documents will be posted on the Company’s website. Members seeking an alternative format of these documents may be advised to complete and submit the request form attached hereto as Appendix B.

8.0 Training for Employees

The Company will provide initial and annual training to all employees within Ontario, regardless of their role within the organization. Initial training for new employees will be provided within thirty (30) days of their start date.

Training will also be provided to individuals who are responsible for developing Company policies, and all other persons who provide services or facilities on behalf of the Company.

Training will cover and include the following:

8.1 The purposes of the AODA and the requirements of the Standards;

8.2 How to interact and communicate with members with various types of disabilities;

8.3 How to interact with members with disabilities who use an assistive device or require the assistance of a service animal or a support person;

8.4 What to do if a member with a disability is having difficulty accessing Company premises and/or services;

8.5 Review of policies, practices, and procedures relating to the Standards.

Employees will also be notified when changes are made to these policies, practices, and procedures. Records of training will be kept with the Human Resources Department and shall be maintained in accordance with the requirements of the AODA.

9.0 Feedback Process

The Company welcomes feedback on its policies, practices, and procedures regarding serving members with disabilities. All feedback can be submitted in the following ways:

9.1 By mail or hand delivery of the written Member Services Feedback Form to any car2go location office;

9.2 By calling Member Services at 1-855-454-1002; or

9.3 By e-mailing Member Services at memberservicesCAN@car2go.com.

The Managers of Member Services will respond to all feedback received in the method and format requested by the member, by e-mail, by phone, or by mail. The response will contain an acknowledgement of the receipt of the member’s feedback, and outline any further action(s) to be taken. All feedback will be targeted for follow up within 2 business days. A record of all such feedback will be maintained by each Manager of the various Member Services departments.

10.0 Related Processes and Procedures

Human Resources and the Managers of Member Services will be responsible for the administration and maintenance of the following processes and procedures:

  • Provide new hires with the training described in Section 8 of this policy within the first thirty (30) business days of their employment in Ontario;
  • Provide the training described in Section 8 of this policy, as needed, to employees working outside of Ontario but who may interact with members from Ontario;
  • Provide annual refresher training to all employees who may interact with members from Ontario;
  • Annually review and update the Accessibility for Persons with Disabilities Policy and Standards;
  • Develop, maintain, and provide to employees a current “Quick Reference Guide” on this policy;
  • Maintain process guidelines related to this policy and the related practices and procedures, including:
    • How members are notified of service disruptions;
    • Member Services Feedback Form;
    • Member Services Feedback Record Tracking; and
    • Availability of the policy and Standards to members and the public.

11.0 Policy Administration

The Director of Human Resources, the Human Resources team as a whole, the Director of Member Services, and the Company’s management team are responsible for ensuring compliance with this policy. If you have any questions regarding this subject, we encourage you to contact Human Resources.