Action Needed for AODA & Bill 132 Compliance -

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We want to take this opportunity to highlight some urgent compliance deadlines associated with AODA (Accessibility for Ontarians with Disabilities Act, 2005) and its associated compliance standards to all of our current and former clients. While there is a phased in approach for AODA – several standards required compliance by January 1, 2017.

Additionally, Bill 132, Sexual Violence and Harassment Action Plan Act, which identifies specific processes and measures to protect employees from sexual violence, required employers to comply by September 8, 2016.

We have learned of recent impromptu compliance audits taking place in organizations within the Ottawa region targeting smaller businesses in particular. A recent example is an IT company of 30 employees where a Compliance Analyst came on-site unannounced to perform an audit, which resulted in a notice to provide evidence of compliance within 10 days. Non-compliance can result in significant fines. These audits have been a pattern we have seen over the past couple of years with the introduction of AODA. Causes of non-compliance range from not having a policy to having a policy that is no longer appropriate for the size of the organization following a period of growth.

If you have a BSG HR Associate working with you, he or she can review this with you and ensure the work is done to address these requirements. If you do not have an HR Associate actively working with you, we would be happy to have someone come in and do a review of your AODA program and identify any gaps and the steps to be taken.

Secondly, one of the requirements of Bill 132, Sexual Violence and Harassment Action Plan Act, is the need to have an independent third party as a point of contact for all employees for a situation where the alleged harasser is the most senior officer of the company (i.e. the CEO). In this case, we are able to operate as that identified independent third party for employees to contact who can then address and conduct any of the necessary follow up and investigation. The legislation requires that you have the name and contact details of the independent third party included in your policy.

If you would like to have this arrangement in place please contact us so that we can provide contact information. Related fees will only be applied if there is an actual incident that requires follow up and investigation.

For assistance with either of these topics, please contact Kim Gurtler at