Accessibility Policy

October 16, 2024

Overview and Statement of Organizational Commitment

Cardinal Capital Management, Inc. ("Cardinal") is committed to providing equitable access to its financial services and products for individuals with disabilities in a timely manner, in compliance with the Accessibility for Manitobans Act, 2013 ("AMA") and related legislation. Cardinal aims to foster an inclusive environment, ensuring dignity, independence, and equal opportunity for all customers and employees. This Accessibility Policy outlines how Cardinal will comply with accessibility requirements and what individuals with disabilities may expect when interacting with the company.

Application

This Policy applies to all Cardinal employees, Advisors, Associate Advisors, Assistants, and third-party representatives who interact with the public on behalf of Cardinal, including those at all of Cardinal's locations in Manitoba. All individuals shall be treated with respect and dignity, regardless of the nature of their disability, whether visible or not.

Definitions

For the purposes of this Policy:

Disability includes any physical, mental, intellectual, cognitive, learning, communication, or sensory impairment—or functional limitation—that, in interaction with a barrier, hinders a person's full participation in society.
Barrier means anything that limits or prevents full participation in society, including physical, technological, and attitudinal obstacles.

General Accessibility Principles

Cardinal will make reasonable efforts to ensure that all individuals, including those with disabilities, have the same opportunities to access and benefit from its services. Cardinal will strive to ensure that:

Services are provided in a manner that respects the dignity, independence, and equal opportunity of individuals with disabilities.
Financial products and services are available through an integrated approach unless alternative measures are required to ensure accessibility.
Employment practices are barrier-free, and accommodations are provided for employees and applicants with disabilities.
Cardinal will maintain accessibility features (e.g., ramps, assistive devices) inworking order through regular inspections and repairs.

Assistive Devices

Individuals with disabilities may use their personal assistive devices to access Cardinal's premises and services. If the use of such devices presents a health or safety risk, Cardinal will provide alternative measures where possible.

Support Persons

Individuals with disabilities are welcome to bring support persons when accessing Cardinal’s premises. If confidential information is discussed, consent will be requested before proceeding in the presence of the support person. If a support person is required for health and safety reasons, Cardinal may mandate their presence.

Service Animals

Cardinal welcomes individuals with disabilities accompanied by service animals at its locations, unless restricted by law. If a service animal is excluded by law, Cardinal will make alternative accommodations to ensure access to services.

Accessible Communication

Cardinal will communicate with individuals with disabilities in a manner that accommodates their specific needs. Upon request, documents and information will be provided in accessible formats within 15 business days at no cost. A notice confirming the availability of this policy is prominently displayed on Cardinal’s website and at all physical locations.

Employment Practices

Cardinal is committed to fair and accessible employment practices. Accommodations are available upon request during recruitment, interviews, and throughout employment. Individual accommodation plans will be developed for employees with disabilities as required.

Workplace Emergency Response

Cardinal will provide individualized workplace emergency response information for employees with disabilities, tailored to their needs, as soon as Cardinal becomes aware of the need for such accommodation.

Notice of Service Disruption

Cardinal will provide timely notice of any service disruptions that could affect individuals with disabilities. Notices will be communicated via onsite signage, website alerts, or other reasonable means, including the reason for the disruption, its anticipated duration, and information on alternative methods of service.

Training

All employees, management, and contractors will receive training on the AMA, customer service regulations, and human rights legislation as it pertains to individuals with disabilities. Training includes instruction on:

Using available accessibility equipment.
Assisting individuals facing barriers, including escalation protocols and alternative service methods.
AMA compliance, human rights legislation, and emergency procedures.

Training is provided to new hires during onboarding and to all staff after updates to regulations, policies, or practices. Cardinal utilizes the Manitoba Accessibility Office’s free online training module. Certificates of completion are retained for five years.

Accessibility Plan

Cardinal will establish a multi-year accessibility plan to identify, remove, and prevent barriers to accessibility. The plan will be reviewed and updated every five years, at a minimum, to ensure ongoing compliance with AMA requirements.

Feedback and Concerns

Feedback on Cardinal’s accessibility policies and practices can be provided via email, phone, or in person. Cardinal will document actions taken in response to feedback and make this documentation available in accessible formats upon request.

Review

This Policy will be reviewed annually and updated as necessary to remain consistent with the latest accessibility standards and legislation. Further information on how to provide feedback and the actions the Company will take on receiving notice of a concern is available from the Cardinal Capital Management Contact Page or on request from enquiries@cardinal.ca