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Accessibility for Ontarians with Disabilities

These policies apply to Lake Inc.’ provision of goods and services and meet the requirements of the Accessibility for Ontarians with Disabilities Act, 2005.

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Accessibility for Customers

Lake Inc, operating on Lake.com, is committed to the full inclusion of persons with disabilities in accordance with the Accessibility for Ontarians with Disabilities Act, 2005 including the requirements of the applicable regulations (collectively, the “AODA”).

This Accessible Customer Service Policy outlines Lake’s actions to comply with the AODA and to identify, remove and prevent barriers for people with visible and non-visible disabilities in accessing Lake’s products, services, and facilities.

Amendments to our Policies

Lake will comply with all applicable federal, provincial and municipal legislation with respect to accessibility and will implement the standards specified under the AODA in effect from time to time. Whenever new or revised standards are developed under the AODA, this policy will be reviewed and updated to the extent necessary to ensure consistency with the legislation.

Customer Support

Lake is committed to excellence in serving all customers, including those customers with visible and non-visible disabilities. Lake is committed to providing its goods and services in a way that respects the privacy, dignity, and independence of persons with disabilities and ensures that customers with disabilities receive the same quality as service as others do.

Communication; Assistive Devices; Service Animals and Support Persons

Accessible Communication

Lake recognizes that persons with disabilities may use or require communication supports when accessing Lake’s goods, services, and/or facilities. Lake is committed to ensuring that its employees will communicate with persons with disabilities in a manner that takes into account their disability.

Accessible formats will be provided to persons with disabilities, when applicable, on request, and when such accommodation will not cause undue hardship to Lake.

Assistive Devices

Lake is committed to ensuring that persons with disabilities who use assistive devices receive equal access to its goods, services, and/or facilities. Lake will endeavor to ensure that its employees are trained and/or familiar with various assistive devices that may be used by customers with disabilities when accessing our goods and/or services.

Service Animals and Support Persons

Lake welcomes persons with disabilities and their service animals and permits service animals on parts of Lake’s premises that are open to the public. Lake will ensure that all employees dealing with the public are trained in how to interact with persons with disabilities who are accompanied by service animals.

Lake is also 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 on Lake’s premises with his or her support person. At no time will a person with a disability who is accompanied by a support person be prevented from having access to his or her support person while on our premises.

Notice of Temporary Disruption

Lake will give notice of temporary disruptions to service or facilities used by persons with disabilities, including any reason(s) for the disruption. These notices will be posted on Lake.com’s website Lake and by any other method that may be reasonable under the circumstances. Lake will make reasonable efforts to provide prior notice of planned disruptions, if possible.

Employee Training

Lake is committed to providing training to all employees who deal with the public and all those who are involved in the development and approvals of customer service policies, practices, and procedures.

Training will include, without limitation: • The purpose and requirements of the AODA; • The requirements of the Integrated Accessibility Standards (Ontario Regulation 191/11); and • Information about Lake’s policies and procedures pertaining to the provision of Lake’s services to persons with disabilities

Lake will keep records of the training provided under this section, including the dates on which the training is provided and to whom such training is provided.

Feedback Process

Policies, procedures, and practices with respect to accessibility, including this Accessible Customer Service Policy and those required under the AODA (our “Policies”) shall be made available in hard copy or can be found on Lake.com’s website Lake. Copies of our Policies will also be made available in an accessible format, and with communication supports where necessary, upon request.

Feedback will be accepted in person, by telephone, in writing, or by email. If a feedback method is not suitable, a customer may request another method for communication. Contact details can be found on Lake.com’s website and in this policy. Lake will respect the privacy of all individuals that submit feedback, and feedback will be reviewed for possible action that can be taken to improve Lake’s services.

Glossary

“accessible formats” include, without limitation, large print, recorded audio and electronic formats, braille, and other formats usable by persons with disabilities.

“assistive devices” means a technical aide, communication device or other instrument that is used to maintain or improve the functional abilities of people with disabilities. Assistive devices may include, without limitation, wheelchairs, walkers, a personal oxygen tank, or any other device that might assist in hearing, seeing, communicating, moving, breathing, and/or reading.

“barrier” means anything that prevents a person with a disability from fully participating in all aspects of society because of his or her disability, including a physical barrier, an architectural barrier, an information or communications barrier, an attitudinal barrier, a technological barrier, a policy or a practice.

“communication supports” include, without limitation, captioning, alternative and augmentative communication supports, plain language, sign language, and other supports that facilitate effective communications.

“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 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,

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” for the purpose of this policy means:

a. A guide dog as defined in Section 1 of the Blind Persons Rights Act R.S.O 1990, Chapter B.7;

b. A service animal for a person with a disability. For the purpose of this policy, an animal is a service animal:

i. if it is readily apparent that the animal is used by the person for the reasons relating to his or her disability;

ii. or of the person provides a letter from a physician or nurse confirming that the person requires the animal for reasons relating to the disability.

For certainty, a service animal does not include a therapy animal (i.e. an animal trained to provide affection and comfort, but is not trained to perform specific tasks to help a person who has a disability).

“support person” means another person who accompanies a person with a disability in order to aide him or her with communication, mobility, personal care, or medical needs or with access to goods and/or services.

Multi-Year Accessibility Plan

I. Introduction and Statement of Commitment

Lake is committed to meeting its obligations under the Accessibility for Ontarians with Disabilities Act (the “AODA” or the “Act”) and the related Integrated Accessibility Standards Regulations (the “IASR”). Building on Lake’s Accessibility Policy, Lake is committed to treating all people in a way that allows them to maintain their dignity and independence.  We believe in integration and equal opportunity.  Lake is committed to meeting the accessibility needs of persons with disabilities in a timely manner, and will do so by preventing and removing barriers to accessibility.

As part of Lake’s commitment to meeting its obligations under the Act, Lake has developed a multi-year plan which outlines Lake’s strategy to prevent and remove barriers and meet its requirements under the AODA.

Lake’s Multi-Year Accessibility Plan will be reviewed and updated by management at least once every five (5) years, and as required.

II. Establishment of Accessibility Policies and Plans

Lake will by November 1, 2023:

  • Develop, implement and maintain a corporate policy or policies governing how the organization will achieve accessibility;
  • Establish, implement and maintain a Multi-Year Accessibility Plan;
  • Include within its Multi-Year Accessibility Plan a statement of commitment to meet the accessibility needs of persons  with disabilities in a timely manner; and
  • Make the corporate policy(ies) and Multi-Year Accessibility Plan available to the public on Lake’s website and available in accessible formats upon request.

III. Training

Lake will by January 1, 2024:

  • Provide training on the requirements of the IASR and on disability-related obligations under Ontario Human Rights legislation, as well as similar legislative provisions across the country, to the following individuals: associates, volunteers, and any others who may be acting on Lake’s behalf in dealing with the public or any other third parties.  Training will also be provided to all people who are involved in the development of Lake’s policies; and
  • Maintain records of the dates when training is completed and the individuals who completed the training.

IV. Information and Communications Standards

A. Accessible Websites and Web Content

Lake will by January 1, 2025:

  • Make Lake’s new internet websites and new content on such websites conform with World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0 Level A.

Lake will by January 1, 2021:

  • Make Lake’s internet websites and web content conform with WCAG 2.0 Level AA, except for exclusions set out in the IASR.

B. Feedback, Accessible Formats and Communication Supports

Lake will by January 1, 2026:

  • Put a statement on its websites about the availability of accessible formats and communication supports and, upon request, provide or arrange for the provision of accessible formats in a timely manner; and
  • Ensure that the processes for receiving and responding to feedback are accessible to persons with disabilities by providing or arranging for the provision of accessible formats and communications supports, upon request.

V. Employment Standards

A. Recruitment

Lake will by November 1, 2023:

  • On its job postings, specify that accommodations are available for applicants with disabilities;
  • Inform applicants selected to participate in an assessment or selection process that accommodations are available during the recruitment process, upon request, in relation to materials and processes to be used;
  • Upon request, consult with the applicant and arrange for suitable accommodation; and
  • Notify the successful applicant, when making offers of employment, of its policies for accommodating associates with disabilities.

B. Informing Associates of Supports

Lake will by January 1, 2024:

  • Inform associates and new hires (as soon as practicable) of Lake’s policies to support associates with disabilities and keep associates up to date on changes to these policies; and
  • Upon request from an associate with a disability, and further to consultation with the associate, provide for suitable accessible formats and communication supports for:  information needed by the associate to perform their job, and information that is generally available to associates.

C. Documented Individual Accommodation Plans / Return to Work Process

Lake will by January 1, 2025:

  • Develop a written process for the development of individual accommodation plans; and
  • Develop and document a return to work process for associates who have been absent due to a disability; the process shall outline the steps Lake will take to facilitate the associate’s return to work and use the associate’s individual accommodation plan as part of that process.

D. Performance Management, Career Development and Redeployment

Lake will by January 1, 2026:

  • Take into account the accessibility needs of associates with disabilities and individual accommodation plans when utilizing Lake’s performance management processes, considering career development and advancement opportunities and redeployment of its associates with disabilities.

Further Assistance

Any further questions or feedback relating to this website should be directed to our AODA Compliance Officer:

David Ciccarelli

Chief Executive Officer

Lake Inc.

legal@lake.com

www.lake.com

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