Accessibility Policy

Sionna Investment Managers is committed to excellence in serving all customers including people with disabilities.

This policy is intended to meet the requirements of Accessibility Standards for Client Service, Ontario Regulation 429/07 under the Accessibility for Ontarians with Disabilities Act, 2005, and applies to the provision of goods and services to the public or other third parties, not to the goods themselves.

All goods and services provided by Sionna Investment Managers Inc. (“Sionna”) shall follow the principles of dignity, independence, integration and equal opportunity.

Scope

a)    This policy applies to the provision of goods and services at premises owned and operated by Sionna.

b)    This policy applies to employees, volunteers, agents and/or contractors who deal with the public or other third parties that act on behalf of Sionna, including when the provision of goods and services occurs off the premises, such as: delivery services, call centers, vendors, drivers, catering and third party marketing agencies.

c)    The section of this policy that addresses the use of guide dogs, service animals and service dogs only applies to the provision of goods and services that take place at premises owned and operated by Sionna Investment Managers Inc.

d)    This policy shall also apply to all persons who participate in the development of the Sionna’s policies, practices and procedures governing the provision of goods and services to members of the public or third parties.

Definitions

Assistive Device – is a technical aid, communication device or other instrument that is used to maintain or improve the functional abilities of people with disabilities. Personal assistive devices are typically devices that clients bring with them such as a wheelchair, walker or a personal oxygen tank that might assist in hearing, seeing, communicating, moving, breathing, remembering and/or reading.

Disability – the term disability as defined by the Accessibility for Ontarians with Disabilities Act, 2005, and the Ontario Human Rights Code, refers to:

• 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      co-ordination, blindness or visual impediment, 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;
• a condition of mental impairment or a developmental disability;
• a learning disability, or dysfunction in one or more of the processes involved in understanding or using symbols or spoken language;
• a mental disorder; or
• an injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997.

Guide Dog – is a highly-trained working dog that has been trained at one of the facilities listed in Ontario Regulation 58 under the Blind Persons’ Rights Act, to provide mobility, safety and increased independence for people who are blind.

Service Animal – as reflected in Ontario Regulation 429/07, an animal is a service animal for a person with a disability if:

• it is readily apparent that the animal is used by the person for reasons relating to his or her 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.

Service Dog – as reflected in Health Protection and Promotion Act, Ontario Regulation 562 a dog other than a guide dog for the blind is a service dog if:

•  it is readily apparent to an average person that the dog functions as a service dog for a person with a medical disability;
• or the person who requires the dog can provide on request a letter from a physician or nurse confirming that the person requires a service dog.

Support Person – as reflected in Ontario Regulation 429/07, a support person means, in relation to a person with a disability, another person who accompanies him or her in order to help with communication, mobility, personal care, medical needs or access to goods and services.

General Principles

In accordance with the Accessibility Standards for Client Service, Ontario Regulation 429/07, this policy addresses the following:

1. The Provision of Goods and Services to Persons with Disabilities;
2. The Use of Assistive Devices
3. The Use of Guide Dogs, Service Animals and Service Dogs
4. The Use of Support Persons
5. Notice of Service Disruptions
6. Client Feedback
7. Training
8. Notice of Availability and Format of Required Documents

1. The Provision of Goods and Services to Persons with Disabilities

Sionna Investment Managers Inc. will make every reasonable effort to ensure that its policies, practices and procedures are consistent with the principles of dignity, independence, integration and equal opportunity by:

• ensuring that all clients receive the same value and quality;
• allowing clients with disabilities to do things in their own ways, at their own pace when accessing goods and services as long as this does not present a safety risk;
• using alternative methods when possible to ensure that clients with disabilities have access to the same services, in the same place and in a similar manner;
• taking into account individual needs when providing goods and services; and
• communicating in a manner that takes into account the client's disability.

2. Assistive Devices

Client’s own assistive device(s):

Persons with disabilities may use their own assistive devices as required when accessing goods or services provided by Sionna.

In cases where the assistive device presents a safety concern or where accessibility might be an issue, other reasonable measures will be used to ensure the access of goods and services.  For example, open flames and oxygen tanks cannot be near one another. Therefore, the accommodation of a client with an oxygen tank may involve ensuring the client is in a location that would be considered safe for both the client and business.  Or, where elevators are not present and where an individual requires assistive devices for the purposes of mobility, service will be provided in a location that meets the needs of the client.

3. Guide Dogs, Service Animals and Service Dogs

A client with a disability that is accompanied by guide dog, service animal or service dog will be allowed access to premises that are open to the public unless otherwise excluded by law. “No pet” policies do not apply to guide dogs, service animals and/or service dogs.

Food Service Areas:

A client with a disability that is accompanied by guide dog or service dog will be allowed access to food service areas that are open to the public unless otherwise excluded by law.

Other types of service animals are not permitted into food service areas due to the Health Protection and Promotion Act, Ontario Regulation 562 Section 60.

Exclusion Guidelines:

If a guide dog, service animal or service dog is excluded by law (see applicable laws below) Sionna will offer alternative methods to enable the person with a disability to access goods and services, when possible (for example, securing the animal in a safe location and offering the guidance of an employee).

Applicable Laws:

Food Safety and Quality Act 2001, Ontario Regulation 31/05: Animals not intended for slaughter or to be euthanized are not allowed in any area or room of a meat plant. It also makes an exception for service dogs to allow them in those areas of a meat plant where food is served, sold or offered for sale to clients and in those areas that do not contain animals or animal parts and are not used for the receiving, processing, packaging, labelling, shipping, handling or storing of animals or parts of animals.

The Health Protection and Promotion Act, Ontario Regulation 562 Section 60, normally does not allow animals in places where food is manufactured, prepared, processed, handled, served, displayed, stored, sold or offered for sale.  It does allow guide dogs and service dogs to go into places where food is served, sold or offered for sale. However, other types of service animals are not included in this exception.

Dog Owners' Liability Act, Ontario: If there is a conflict between a provision of this Act or of a regulation under this or any other Act relating to banned breeds (such as pitbulls) and a provision of a by-law passed by a municipality relating to these breeds, the provision that is more restrictive in relation to controls or bans on these breeds prevails.

Recognizing a Guide Dog, Service Dog and/or Service Animal:

If it is not readily apparent that the animal is being used by the client for reasons relating to his or her disability, Sionna may request verification from the client.

Verification may include:

•  a letter from a physician or nurse confirming that the person requires the animal for reasons related to the disability;
• a valid identification card signed by the Attorney General of Canada; or,
• a certificate of training from a recognized guide dog or service animal training school.

Care and Control of the Animal:

The client that is accompanied by a guide dog, service dog and/or service animal is responsible for maintaining care and control of the animal at all time.

Allergies:

If a health and safety concern presents itself for example in the form of a severe allergy to the animal, Sionna will make all reasonable efforts to meet the needs of all individuals.

4. Support Persons

If a client with a disability is accompanied by a support person, Sionna will ensure that both persons are allowed to enter the premises together and that the client is not prevented from having access to the support person.

There may be times where seating and availability prevent the client and support person from sitting beside each other. In these situations Sionna will make every reasonable attempt to resolve the issue.

In situations where confidential information might be discussed, consent will be obtained from the client, prior to any conversation where confidential information might be discussed.

Admission Fees:

If payment is required by a support person for admission to the premises Sionna will ensure that notice is given in advance by posting notice of admission fees for support persons where fees are posted.

5. Notice of Disruptions in Service

Service disruptions may occur due to reasons that may or may not be within the control or knowledge of Sionna Investment Managers Inc. In the event of any temporary disruptions to facilities or services that client's with disabilities rely on to access or use Sionna's goods or services, reasonable efforts will be made to provide advance notice. In some circumstances such as in the situation of unplanned temporary disruptions, advance notice may not be possible.

Notifications will Include:

In the event that a notification needs to be posted the following information will be included unless it is not readily available or known:

• goods or services that are disrupted or unavailable
• reason for the disruption
• anticipated duration
• a description of alternative services or options

Notifications Options:

When disruptions occur Sionna will provide notice by:

• posting notices in conspicuous places including at the point of disruption, at the main entrance and the nearest accessible entrance to the service disruption and/or on the Sionna Investment Managers Inc. website;
• contacting clients with appointments;
• verbally notifying clients when they are making a reservation or appointment; or
• by any other method that may be reasonable under the circumstances.

6. Feedback Process

Sionna Investment Managers Inc. shall provide clients with the opportunity to provide feedback on the service provided to clients with disabilities. Information about the feedback process will be readily available to all clients and notice of the process will be made available by (insert ways in which the process will be publicized). Feedback forms along with alternate methods of providing feedback such as verbally (in person or by telephone) or written (hand written, delivered, website or email), will be available upon request.

Submitting Feedback:

Clients can submit feedback to:

•  Paul Spagnolo, Chief Operating Officer, Chief Compliance Officer
• (416) 203-8803
• 8 King Street East, Suite 1600 Toronto ON M5C 1B5
• www.sionna.ca

Clients who wish to provide feedback by completing an onsite client feedback form can do so by submitting it to the reception desk at Sionna.

Clients that provide formal feedback will receive acknowledgement of their feedback, along with any resulting actions based on concerns or complaints that were submitted.

7. Training

Training will be provided to:

a)    all employees, volunteers, agents and/or contractors who deal with the public or other third parties that act on behalf of Sionna Investment Managers Inc.; for example: salespersons, drivers, vendors, event operators, call centers and third party marketing agents; and,

b)    those who are involved in the development and approval of client service policies, practices and procedures.

Training Provisions:

As reflected in Ontario Regulation 429/07, regardless of the format, training will cover the following:

• A review of the purpose of the Accessibility for Ontarians      with Disabilities Act, 2005.
• A review of the requirements of the Accessibility Standards for Client Service, Ontario Regulation 429/07.
• Instructions on how to interact and communicate with people with various types of disabilities.
• Instructions on how to interact with people with disabilities who:
  • use assistive devices;
  • require the assistance of a guide dog, service dog or other service animal; or
  • require the use of a support person (including the handling of admission fees).

• Instructions on how to use equipment or devices that are available at our premises or that we provide that may help people with disabilities.
• Instructions on what to do if a person with a disability is having difficulty accessing your services.
• Sionna Investment Managers Inc.'s policies, procedures and practices pertaining to providing accessible client service to clients with disabilities.

Training Schedule:

Sionna Investment Managers Inc. will provide training as soon as practicable. Training will be provided to new employees, volunteers, agents and/or contractor who deal with the public or act on our behalf during their orientation session. Revised training will be provided in the event of changes to legislation, procedures and/or practices.

Record of Training:

Sionna Investment Managers Inc. will keep a record of training that includes the dates training was provided and the number of employees who attended the training.

8. Notice of Availability and Format of Documents

Sionna Investment Managers Inc. shall notify clients that the documents related to the Accessibility Standard for Client Service are available upon request and in a format that takes into account the client's disability. Notification will be given by posting the information in a conspicuous place owned and operated by Sionna Investment Managers Inc., the Sionna Investment Managers Inc.'s website and/or any other reasonable method.

Administration

If you have any questions or concerns about this policy or its related procedures please contact:

•  Paul Spagnolo, Chief Operating Officer, Chief Compliance Officer
• (416) 203-8803
• 8 King Street East, Suite 1600 Toronto ON M5C 1B5
• www.sionna.ca

This policy and its related procedures will be reviewed as required in the event of legislative changes.