Accessibility Policy



Consistent with our belief for Brilliant Service and Doing the Right Thing, Royal & Sun Alliance Company of Canada (“RSA”) is committed to treating our customers, employees, suppliers, business partners, and visitors with fairness, dignity, respect and courtesy, in a way that respects all international, provincial and territorial law.

RSA also complies with all applicable national and provincial laws pertaining to non-discrimination and equal opportunity.




This policy applies to all RSA employees, including affiliates and subsidiaries’ employees, who work in Canada as well as contingent workers (agency contractors, independent contractors, third party contractors etc.) who work in Ontario; and those who provide service in Ontario regardless of where they are located, such as volunteers and third parties who interact with the public on behalf of RSA in Ontario.




This policy is intended to provide the overarching framework, to guide the review and development of RSA policies, standards, and procedures governing how RSA achieves or will achieve accessibility, to ensure compliance with the standards developed under the Accessibility for Ontarians with Disabilities Act, 2005, S.O. 2005, c. 11 (AODA).   




Accessible Formats - may include, but are not limited to, large print, recorded audio and electronic formats, Braille and other formats usable by persons with disabilities.


Communication Supports - may include, but are not limited to, captioning, alternative and augmentative communication supports, plain language, sign language and other supports that facilitate effective communications.


Disability - is defined, per Section 2 of the Accessibility for Ontarians with Disabilities Act, 2005, S.O. 2005, c. 11 and the Human Rights Code, R.S.O. 1990, c. H.19, as follows: 

(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 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 [in] a wheelchair or other remedial appliance or device, 

(b) a condition of mental impairment or a 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.” 


Service Animals – are defined, per Section 4(9) of the Accessibility Standards for Customer Service, O. Reg. 429/07, as follows: 

     “an animal is a service animal for a person with a disability: 

(a) if it is readily apparent that the animal is used by the person for reasons relating to his or her disability; or 
(b) if the person provides a letter from a physician or nurse confirming that the person requires the animal for reasons relating to the disability.” 


Support Person – is defined, per Section 4(8) Accessibility Standards for Customer Service, O. Reg. 429/07, as follows: 

 “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 or medical needs or with access to goods or services.” 


Unconvertible - information or communications are unconvertible if it is not technically feasible to convert the information or communications or, the technology to convert the information or communications is not readily available. 



General Accessibility Requirements


Establishment of Accessibility Plans and Policies 

RSA will maintain a Multi-Year Accessibility Plan. The plan will be posted on the Company’s website and shall be made available in an accessible format, upon request. The Accessibility Plan will be reviewed and updated at least once every five (5) years. See Appendix A

RSA maintains policies governing how the Company shall meet its requirements under the AODA, and we will provide policies in an accessible format, upon request.   


Customer Service Standards 

1.0 Assistive Devices

RSA is committed to serving persons with disabilities who use assistive devices to obtain, use or benefit from our services. If a person with a disability is hindered or prevented from accessing our services using their assistive device, we will consult with the person and accommodate them by providing an alternative wherever possible.

We will also ensure that employees, volunteers and third party contractors know how to use assistive devices to provide our services and inform individuals wishing to access RSA’s services.

2.0 Service Animals

Service animals, such as, but not limited to guide dogs, hearing dogs, seizure response dogs, and other certified service animals shall be permitted entry to all RSA’s facilities and meeting rooms that are open to the public, unless otherwise excluded by law.

RSA will ensure that all employees and third parties dealing with the public are trained in how to interact with persons with disabilities who are accompanied by a service animal.

3.0 Support Persons

A Support Person accompanying a customer or prospective customer shall be permitted entry to all RSA facilities and meeting rooms that are open to the public, or as otherwise approved by the appropriate authority.

If there is a charge to attend an event and fees are payable to a third party, a Support Person is permitted to attend the event at their own cost unless otherwise outlined by the third party. If fees are payable to RSA, a Support Person is permitted to attend at reduced or no cost, depending on the event.

Customers are required to provide their own Support Person(s).

4.0 Notice of Temporary Service Disruptions

RSA will give notice of temporary disruptions to services or facilities used by persons with disabilities, including the reason(s) for the disruption and expected duration. The notice shall be posted appropriately at the applicable facility and on the RSA web site when appropriate. In the event of a planned disruption, advance notice will be provided.  


Information and Communication Standards 



When communicating with a person with a disability, RSA employees, volunteers and third party contractors shall do so in a manner that takes into account the person’s disability. 

Accessible Websites and Web Content 

Internet websites and web content controlled directly by RSA, or through a contractual relationship that allows for modification of the product, shall be made accessible in accordance with the requirements of the AODA Integrated Accessibility Standards Regulation (O. Reg. 191/11). 

Emergency Procedures, Plans and Information 

RSA shall provide all existing public emergency procedures, plans and public safety information, upon request in an accessible format or with appropriate communication support in a timely manner.    


Employment Standards    



RSA will post information about the availability of accommodations for applicants with disabilities in its recruitment process. Job applicants who are individually selected for an interview and/or testing shall be notified that accommodations for material to be used in the process are available, upon request. RSA shall consult with any applicant who requests an accommodation in a manner that takes into account the applicant’s disability. Successful applicants shall be notified about our policies for accommodating employees with disabilities as part of their offer of employment.        


Workplace Emergency Response Information 

If an employee’s disability is such that workplace emergency response information is necessary and RSA is aware of the need for accommodation, this information shall be provided to employees. In addition, this information shall be provided, with the employee’s consent, to the person designated to provide assistance. The information shall undergo review when the employee moves to a different location, when the employee’s overall accommodation needs or plans are reviewed and when RSA reviews its general emergency response plan. 


Availability of Documents

This policy and other documents deemed as critical to the delivery of services and the compliance under the AODA Accessibility Standards will be made available upon making a request to RSA Complaint Liaison Officer or Rsa Manager, Customer Care. Documents will also be available in an alternative format on request. To make such a request, the individual is asked to contact RSA Complaint Liaison Officer or Rsa Manager, Customer Care via mail or e-mail.


Ontario Customer/Public Feedback Process

A simple to use, accessible process for individuals to provide feedback or complaints is in place and will be posted on the RSA website. Feedback may be provided by a person with a disability directly to the service provider or by completing the Feedback Form and submitting to RSA Complaint Liaison Officer or Rsa Manager, Customer Care via mail or e-mail. Feedback will be used to improve customer service where applicable.


Contact Information


Any questions about this policy, the feedback process or availability of documents can be directed to:

Phone - Toll Free: 1 888 877 1710

E-mail: [email protected]


18 York Street, Suite 800

Toronto, Ontario

M5J 2T8


APPENDIX A - AODA, Multi Year Plan Summary




Accessibility Standards
Customer Service Standard 

s. 3 (4) 
• Must communicate with a person with a disability in a manner that takes into account their disability. 

s. 4 Use of service animals and support persons 
• Establish policies, practices and procedures around a person with a disability being accompanied by a service animal or support person. 
• Create document describing policies, practices and procedures; provide upon request. 

s. 5 Notice of temporary disruptions 
• Provide public notice of disruption in facilities or services by posting on premises or on website. 
• Include in notice the reason for disruption, anticipated duration, and description of alternatives, if available. 
• Create a document describing steps to be taken for temporary disruptions; provide upon request. 

s. 6 Training for staff
• Provide training to all employees who deal with the public or others on behalf of Company. 
• Provide training on ongoing basis to reflect any changes to policies, practices and procedures. 
• Create document describing training policy, summary of content and details of when the training is provided. 
• Keep records of training provided, including dates and number trained. 

s. 7 Feedback process 
• Establish process for receiving and responding to feedback; make information about process publicly available. 
• Create document describing process; make available on request. 

s. 8 Notice of availability of documents 
• Notify employees and customers that the documents covered by this regulation are available upon request by posting on company's website or other reasonable method. 

s. 9 Format of documents 
• Alternate format of documents covered by this regulation must take into account person's disability.









Information & Communication Standards

s. 13 Emergency and public safety information 
• Make information available to public in an accessible format or with appropriate communication supports, upon request. 
s. 14 New Internet websites and new web content 
• Conform to WCAG 2.0, initially Level A. (Applies to websites, web content and web-based applications that Company controls directly or through contractual relationship)    









Employment Standards

s. 27 Workplace emergency response information 
Provide individualized workplace emergency response information to employees who have a disability who may require an individualized plan
s. 22, 23, 24 Recruitment 
• Notify applicants about the availability of accommodation. 
• Notify job applicants selected in hiring process that accommodations are available upon request in relation to material or processes to be used. 
• Consult with the applicant, or arrange to provide the accommodation.










Design of Public Space

Part IV.1 Design of Public Spaces
• Follow technical and other requirements imposed under IASR for large organizations that intend to develop new, or redevelop existing, public spaces
• Obligations include but are not limited to outdoor public use eating areas, exterior paths of travel, accessible parking, improvements relating to service (newly constructed service counters, fixed queuing guides, waiting areas) and maintenance of accessible elements.