LTRT is committed to creating a work environment where team members are valued, understood, and supported to work to their full potential and be their whole selves. 

A top priority at LTRT is ensuring that employees have the resources and support they need to participate equitably and fairly in our workforce and to the best of their abilities. We strive to take a “yes-by-default” approach. This means that we start from the perspective that an accommodation request can be met. We only change this perspective if concerns arise that it will be difficult to meet or that it might cause LTRT Undue Hardship to do so. 

This policy outlines our commitment to providing accommodations and describes the accommodation process at LTRT. This policy was drafted with input from employees with disabilities, as well as through consultation with current best practices and standards related to accommodation in the workplace. 

This policy applies to all employees, both part- and full-time, regardless of position within the organization. It also applies to temporary and contract workers as well as students and affiliates. This policy applies to all potential employees of LTRT, including job seekers and candidates. 

Accommodations are modifications to LTRT’s facilities, practices, or systems, for an individual, to account for a barrier that the employee experiences due to their membership in a prescribed group. These groups are outlined by the Ontario Human Rights Code and their equivalents in other Canadian provinces and territories.

These prescribed groups include race, ancestry, place of origin, colour, ethnic origin, citizenship, creed, sex, sexual orientation, gender identity, gender expression, age, marital status, family status, or disability. 

Accommodation requests are most common in relation to an employee’s disability or medical condition. Accommodations are also often requested to account for sex, family status, or religion. For example, accommodations may account for parenting duties, pregnancy, or time off for religious observance or holidays.  LTRT will consider requests for accommodation for any prescribed group.

Principals will:

· Monitor compliance with this policy.

· Make sure all managers are aware of this policy and train them on its application. 

· Make final decisions to approve an accommodation plan or to deny an accommodation request, through consultation with the requesting employee, their manager, the Accommodations Advisor (if needed), and considering applicable laws. 

· Make reasonable funds available to meet requests for accommodation.  

· Establish mechanisms for the documentation of all formal accommodation requests and related material (including medical documentation, notes from accommodation meetings, final accommodation decisions, and accommodation plans). 

· Maintain the confidentiality and privacy of all employees who make accommodation requests. 

· Provide organizational leadership that emphasizes LTRT’s commitment to this accommodation policy and to fair and equitable employment for all employees, contractors, and candidates. 

Employees with “People Management Responsibilities” includes Principals, Leads, and, in some cases, Project Managers. They will:

· Inform (i.e. before their first day; and in their first week), and regularly remind (at least annually), the employees they manage about this policy and about the accommodation process at LTRT. 

· Accept requests for accommodation in good faith and limit the amount of personal information they request or require from employees throughout the accommodation process. 

· Collaborate with their direct report, their supervising Principal, and (if needed) the Accommodations Advisor to determine the most appropriate accommodation plan to address the barriers the employee is experiencing. 

· Document all steps of the formal accommodation process, including the initial request, resulting outcome, and any accommodations put in place. This documentation will be stored in the employee’s human resources file, only accessible by the manager and supervising Principal. Documentation related to the decision-making process and outcome will be provided to the employee upon request. 

· Make sure that accommodation information (including the accommodation plan, or short form version of it) is shared with other employees at the organization who require the information to meet the accommodation (for example project managers). Only information that is determined to be necessary to meet the accommodation will be shared and it will only be shared with other employees who require the information (for example, project managers). 

Employees, candidates, and contractors will:

· Engage in the accommodations process in good faith when requesting an accommodation. 

· When requesting an accommodation, work with their manager, Principal, and (if necessary) the Accommodation Advisor to determine the most appropriate accommodation plan. Employees who request accommodations understand that their preferred accommodation may not be the accommodation that is ultimately offered. 

· Participate in creating a culture that promotes accessibility and inclusion. 

· Take steps to understand this accommodation policy and follow the accommodation plans when they are made known of their colleagues (which may include managers and principals). 

· Strive to meet the accommodations laid out in accommodations plans that they are made aware of and retain the confidentiality of accommodation plans. 

The Accommodations Advisor will be a management level employee who has an advanced understanding of the accommodations process both legally and in practice. The Accommodations Advisor is appointed by the Principals. 

The Accommodations Advisor:

· Will act as an advisor (when needed) to both employees making requests for accommodations and managers receiving requests for accommodations. 

· Will provide advice and guidance (where needed) during the accommodation process to help determine: 

o The differences between informal and formal accommodation requests 

o Appropriate accommodation strategies that will address the barrier the employee is experiencing 

o Where further documentation is needed 

o How to maintain confidentiality of accommodations and accommodation plans 

o When a particular accommodation request may or may not amount to Undue Hardship. 

· Can act as a neutral third party for discussions between employees and their managers (when needed), so long as the Advisor is not either the requesting employee or manager. 

· Can support managers to understand how to inquire whether accommodations are needed when performance issues arise.

In cases where the Accommodations Advisor is either the requesting employee, or the manager to whom the request is being made, another designate at LTRT can be appointed to act as this third party. 

This policy is provided to all employees when they begin their employment at LTRT and is always available for review by employees. All job postings clearly outline that accommodations can be provided during the recruitment process and while employed with LTRT, along with instructions for how candidates can request accommodations. 

Managers are encouraged to have regular (at least annually) conversations about accommodations, this policy, and how accommodations can be requested. Managers will remind employees about this policy and the accommodation process during annual reviews with the employees they manage. 

Managers will ask employees if they have any need for accommodations if they believe the employee may benefit from such accommodations. When employees are experiencing performance management issues, their manager will ask if they have any need for accommodations, or if there are barriers they are experiencing which may be contributing to the performance issue. This is called the duty to inquire. 

Employees may have informal accommodations, formal accommodations, or a combination of the two.

Informal accommodations do not go through the formal accommodation process. Informal accommodations are those that do not require significant modifications to LTRT’s facilities, practices, or systems and therefore do not require a formal accommodation plan. In some cases, informal accommodation requests may be met through a change in practice that is adopted by the entire organization, and therefore also do not require a formal accommodation plan tied to an individual employee.  

Some examples may include: 

· An employee asks to start most workdays at 10am Eastern Time instead of 9am Eastern Time but is willing to occasionally start earlier to account for a meeting or deadline. 

· An employee asks their colleagues to provide specific step-by-step instructions (over and above what is typically provided) for a new task because it’s easier for them to learn that way. 

· An employee requests access to a particular kind of software, and LTRT decides to adopt that software across the organization and make it available to all employees. 

LTRT will strive to meet informal accommodation requests to the best of our ability. Many of the organization-wide practices at LTRT are set up to account for people with a wide range of disabilities, learning styles, and working styles. These practices help to reduce the need for formal accommodations and include but are not limited to: 

· Flexible work schedules, including start and finish times.

· Employees being able to set their own schedules for the most part. This can help to account for good/bad days, doctors’ appointments, etc. 

· Using Asana to communicate instructions and keep track of tasks.

· Allowing employees to work from home or in the location of their choosing. 

While we strive to meet all informal accommodation requests, this is not always guaranteed. For example, employees who prefer to start at 10am Eastern Time may still be asked to work earlier to account for a specific meeting or deadline. 

Employees who require an accommodation request to be followed in a more formal and absolute way should submit a formal accommodation request (see next section). 

Formal accommodations are accompanied by a written accommodation plan that is agreed upon by the employee, their manager, and their supervising Principal. Formal accommodations plans must be followed by all LTRT employees (if they are made aware of them). 

Every request for accommodation is considered on an individual basis. LTRT will accept and consider many different types of accommodation requests, however some accommodations are more common (see Appendix 1). 

1. Initiating the process: A request for accommodation is initiated by the employee who requires it. The employee can initiate the request with any of the following people: 

· Their manager 

· Their manager’s supervising Principal

· The Accommodation Advisor 

If a manager or supervising Principal identifies a potential need for accommodation, they should speak to the employee about whether accommodations would be beneficial and encourage the employee to initiate the process. 

The manager receiving the request will determine whether the request can be met through the informal process (described above) or if a formal accommodation process is needed. The manager can seek guidance from their supervising Principal, or the Accommodation Advisor to help them determine which process is most appropriate. 

2. Discussing the accommodation: The employee requesting the accommodation and the person that received the request will have a conversation that outlines: 

· Why the accommodation is being requested. The employee does not need to provide the specific reason (e.g. diagnosis) but must explain what barriers they are experiencing in the workplace. 

· What barriers are being experienced by the employee and what accommodation they are requesting to remove that barrier. 

· If the employee does not know what accommodation they need or what might be helpful: 

o The manager may make recommendations for a particular type of accommodation. 

o The employee or manager may speak to the Accommodation Advisor who may be able to recommend a certain type of accommodation. 

o LTRT may request documentation from the employee that outlines recommended accommodations (e.g. from the employee’s personal health care provider, see section below related to Documentation). 

An employee’s preferred accommodation may not always be the accommodation that is granted. During the discussion phase, alternative accommodations may be discussed which would address the barriers that the employee is experiencing. Employees making a formal request for accommodations should engage in these discussions in good faith and consider whether alternative suggested accommodations could meet their needs. Employees who are not willing to consider alternative accommodations may find that their request for accommodation is denied.

3. Making a decision: Once the accommodation has been identified (if not sooner), the manager will speak to their supervising Principal about the accommodation request. The Principal will be responsible for helping identify any potential Undue Hardship that LTRT could experience if the accommodation is implemented (see section below on Undue Hardship). 

· The principal will identify if documentation is needed on behalf of the employee to demonstrate the need for accommodation or to help identify potential accommodations (see section on Documentation). 

· If the accommodation requested could result in Undue Hardship on behalf of LTRT, or if it would be impractical or difficult to implement, the Manager, Principal and Accommodation Advisor may engage in a process of identifying alternative accommodations that would still meet the needs of the employee in removing their barriers. 

· The ultimate decision to accept or deny a request for accommodation lies with the supervising Principal. 

· A request for accommodation may be denied for one of the following reasons:

o If it is not apparent, or there is no evidence, that the employee is a member of a prescribed group.

o If the requested accommodation would cause undue hardship (see section below on Undue Hardship). 

4. If denied: In the case where an accommodation request is denied, the following steps will take place: 

· The employee will be informed of the denial in writing, with an explanation as to why the request is being denied. This letter will be documented and stored in the employee’s confidential human resources file. 

· The manager and employee will engage in a conversation to discover if other supports can be put in place to assist the employee with the barriers they are facing. This could result in informal accommodations being implemented or resolving the request with an alternative accommodation. 

5. Accommodation Plan: If an accommodation plan is agreed upon by the employee, their Manager, and the supervising Principal, a formal accommodation plan will be written and implemented. The written accommodation plan will include: 

· An exact description of the accommodation and how it is meant to be followed.

· A list of people (by position title and/or project role) who will need to be informed about the accommodation to ensure its successful implementation. 

· The duration of time for which the accommodation is being put in place. 

· A plan for how the accommodation will be monitored to ensure its continued success. 

· A timeline for the review of the plan. Accommodation plans should be revisited and discussed between the employee and their manager no less than once per year. If no issues have arisen from the accommodation plan, then typically, this will occur at or near the time of the employee’s annual performance review. Accommodation plans may need to be revisited more frequently or at different points of time if a new barrier becomes apparent, if the plan is not addressing the employees’ barriers, or if the accommodation(s) are causing difficulty for other employees or the organization. 

· Formal written accommodation plans will be documented and stored in the employee’s confidential human resource file. The employee will receive a copy of the initial accommodation plan and any subsequent updates to that plan. 

· Accommodation plans are considered confidential and shared only with the employees at LTRT who would need the information to implement the accommodation. Note that the accommodation plan does not include information about the employee’s reason for accommodation (e.g. disability or diagnosis). 

o In some cases, there may need to be multiple versions of the accommodation plan created to maximize confidentiality and privacy of the employee. For example, the full accommodation plan may include a mix of information that only the employee’s Manager needs to know, and other information that needs to be shared with all project managers directly supervising the employee on projects. In this case a second version of the accommodation plan should be created specifically to share with project managers, with additional confidential information deleted in that version.  

In some cases, LTRT may request documentation from the employee to demonstrate the need for accommodation (e.g. the presence of a disability or medical condition) or to help identify potential accommodations. 

LTRT will do its best to reduce the need for documentation as we recognize that this request puts strain on the employee making the request for accommodation. 

Documentation will only be requested in one of the following circumstances: 

· If the need for accommodation is not clear or apparent and the requested accommodation will put financial or logistical strain on LTRT or its employees. 

· If it is unclear what accommodation would be appropriate. 

· If the employees’ stated barriers and the requested accommodation do not seem congruent with each other. 

LTRT will cover the costs and expenses related to documentation that we request from an employee. 

LTRT has a duty to accommodate employees up to the point of Undue Hardship. We strive to accommodate all employees but, in some cases, the requested accommodation may be denied if it constitutes Undue Hardship. Undue Hardship is when the requested accommodation either:

· Would be so costly that it would affect the business operations of LTRT significantly. Cost includes additional expenditures (e.g. purchasing specialized equipment), replacement of staff time (e.g. reduced productivity that requires additional staffing), and/or loss of income (e.g. not fulfilling a client contract). 

· Would create a health and/or safety risk for employees, candidates, contractors, or clients. 

· Is impossible, significantly implausible or excessive, and thus not a “reasonable accommodation”. 

Some examples of accommodation requests that could amount to Undue Hardship are listed in Appendix 1. 

LTRT strives to ensure that our hiring and recruitment process is as accessible and free of barriers as possible, thus reducing the need for individualized accommodations. Some of the practices we use to ensure an accessible hiring process include: 

· Stating that accommodations are available upon request in all our job postings and public information about positions at LTRT. 

· Providing information in our job postings about how candidates can request accommodations. 

· Screening candidates and managing our recruitment process manually, not by artificial intelligence. 

· Providing all candidates with detailed information about how the recruitment and interview process will look and what they will be expected to do. 

· During interviews, we always utilize automatic captions and provide each question that we are asking both verbally and in written format to the candidate. 

LTRT will provide reasonable accommodations to employment candidates upon request. The principles of accommodation are the same for both candidates and employees, however the process and types of accommodations available will differ. 

Accommodation requests from candidates will be considered in relation to fairness and objectivity of the interview and hiring process. LTRT may choose to make changes to the process for all candidates to address the accommodation needs of one candidate to ensure fairness. 

Accommodation requests from candidates typically do not amount to Undue Hardship or require documentation, however the information related to Undue Hardship and documentation found in the previous sections of this policy still apply as necessary. 

A list of common accommodations is included in Appendix 1.

Candidates can request accommodations at any time during the hiring process. The initial request gets submitted to the Team Supporter that is supporting that hiring. 

Candidates do not need to disclose the reason for their request (e.g. diagnosis or type of disability) but rather should describe the barriers they experience.

The Team Supporter will share the request with the Principal in charge of the hiring process. The Principal may choose to discuss the request with the hiring manager or Accommodations Advisor. 

In rare cases where the accommodation request cannot be granted, the candidate will be informed in writing and LTRT will discuss alternative measures for meeting the candidate’s needs. 

The Principal or hiring manager will implement the accommodation for the hiring process.

Information related to individual employee’s accommodations and requests for accommodation are considered confidential and are not to be shared with any other employee or person outside of those who require the information. 

An employee’s Manager and their supervising Principal will participate in the accommodation process and therefore will have access to confidential information. The Accommodations Advisor may also be involved in this process. These 2 or 3 individuals will be responsible for maintaining the confidentiality of the process and will not share this information with any other person. This information includes (but may not be limited to): 

· The request for accommodation 

· The barrier(s) the employee is experiencing 

· Membership in a prescribed group

· Supporting documentation 

· Discussions about alternative accommodations or implementation 

· Denial of accommodation requests 

Employees requesting accommodation on the grounds of disability are not required to reveal a specific diagnosis to their manager and/or supervising principal, however if that information is revealed by the employee through the accommodation process, the information will be considered confidential and not shared with anyone else. 

Formal accommodation plans may in some cases be kept confidential, and in other cases may need to be shared with employees beyond the requesting employee, their manager and their supervising principal. Decisions on when to share formal accommodation plans, and with whom will be made in relationship to the specific accommodation itself and what is required to fulfill the accommodation plan. Some examples are included below: 

· Accommodations that involve the purchasing of specific hardware (e.g. specific keyboard and mouse) that will be solely used and/or operated by the requested employee do not need to be shared beyond the Manager and supervising Principal.

· Accommodations that involve installing software will likely need to be shared with LTRT’s Privacy and Security Officer and information technology provider to ensure the software complies with contracts on privacy and security.

· Accommodations that require a change in behavior or practice when interacting with the requesting employee (for example, communicating with a Deaf employee in writing rather than MS Teams meeting) may need to be shared with all employees. 

· Accommodations that require a change to standard practice for projects (for example, limitations on work travel) may need to be shared with all Project Managers under whom the employee is working. 

Accommodation plans will only be shared with employees/contractors who require the information to fulfill or assess the accommodation request. In the case where a formal accommodation plan covers multiple accommodations, and different audiences require different levels of access to this information, then multiple versions of the accommodation plan may be created. 

· For example, a formal accommodation plan may include access to a particular type of software, and a restriction on work travel. In this case a short-form version of the accommodation plan will be created outlining only the restriction of work-related travel. This short form version will be the one shared with project managers, as they do not require information related to the software component of the accommodations plan. 

Accommodation plans, or any information related to a confidential accommodation process, will never be shared with clients and anyone currently on contract with LTRT without the employee’s explicit consent. This consent may be needed if those individuals require this information to fulfil an accommodation (e.g. meeting accessibility features). In the case where a need to share this information is identified, the supervising Manager should seek advice from the Accommodations Advisor on if or how this should be done while maintaining confidentiality. 

This policy will be reviewed and revised (as needed) at a minimum every 3 years. This review will include consultation with employees. During each period of review, employees are reminded to re-visit the policy and make suggestions for any changes, additions or improvements to it. 

The policy may be reviewed or updated on a more frequent basis, or within the 3-year period, if a particular need for that review or revision is identified. This could be, for example, in response to an identified challenge with this policy or resulting procedures, or if best practices in accommodation more generally are identified and should be reflected through LTRT’s policies. 

The Accommodations Advisor is responsible for both regularly scheduled reviews and is also responsible for identifying needs to update this policy outside of the regularly scheduled review period. 

Questions about this policy can be directed to your immediate supervisor, the supervising Principal, or the Accommodations Advisor.  

Cara Wilkie, CFO March 19, 2025
 

The following is a list of common accommodations that may be offered to employees; however, this list is not exhaustive: 

· Modified work schedule that includes a standard start and/or end time (within reason and so long as the employee is still available to schedule and attend client and internal meetings within their modified schedule). 

· Adaptive technology equipment to meet the needs of an employee with a disability (for example an employee who is blind or has reduced hand function). 

· Restrictions or limitations on the type or frequency of work-related travel. 

· Automatic captions for meetings.

· Documents provided in accessible alternative formats.

· Practices that support employee learning or workstyle (for example, asking that all tasks are documented in writing, breaking down larger tasks into smaller steps, etc.). 

· Accessible meeting practices (for example, using auto-captions as standard practice, or refraining from holding last-minute meetings). 

The following is a list of common accommodations that may be offered to LTRT candidates; however, this list is not exhaustive: 

· Extra time to complete assignments that are a component of the LTRT hiring process. 

· Advance information about the nature of assignments.

· Provision of an ASL interpreter for interviews.

· Providing documents in accessible formats.

Some non-exhaustive examples of accommodation requests that could amount to Undue Hardship include:

· A request to work reduced hours without a reduction in salary.

· A request for dedicated office space (given that LTRT does not maintain any dedicated office spaces).

· A request to complete all work hours outside of the typical workday (9:00am -5:00pm Eastern Time) with no exceptions to attend meetings. 

· A request for significantly extended deadlines for client deliverables.

Employee Name: 

Employee’s Manager: 

Supervising Principal: 

Initial Plan Date:  Date of Last Revision: 

Accommodations 

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