AODA Policy and Multi-Year Accessibility Plan

This Policy outlines the policies and actions that Rakuten Kobo Inc. (“Kobo”) will put in place to improve opportunities for people with disabilities and comply with the requirements of the Accessibility for Ontarians with Disabilities Act (“AODA”) and its Integrated Accessibility Standards Regulation (“IASR”).

Statement of Commitment:

Kobo is committed to treating all people in a way that allows them to maintain their dignity and independence. We are committed to meeting the needs of people with disabilities in a timely manner and will do so by attempting to identify, prevent, and remove barriers to accessibility and meeting accessibility requirements under the AODA, allowing for integration and equal opportunity.

Accessible Emergency Information:

Kobo is committed to providing customers with publicly available emergency information in an accessible way upon request. We will also provide employees with disabilities with individualized emergency response information when necessary.

Training:

Kobo will provide training to employees on Ontario’s accessibility laws and on the Human Rights Code as it relates to people with disabilities. Training will be provided in a way that best suits the duties of employees. Kobo will:

• Determine the extent (if any) to which each employee’s duties are affected by the Ontario’s accessibility laws and Human Rights Code;

• Provide training on how to comply with the relevant aspects of such laws as they apply to an employee’s responsibilities;

• Maintain a record of which employees have received training and the details of such training, including the date that such training was received;

• Continue to provide such training to new employees and retrain existing employees as required by changing laws and policies.

Information and Communication Standard:

Kobo is committed to meeting the communication needs of people with disabilities. If requested, we will consult with people with disabilities to determine their information and communication needs.

Website and Web Content:

Kobo will take steps to ensure all websites and content conform with the WCAG 2.0. level AA standard by January 1, 2021.

Feedback Process:

Kobo has multiple alternate feedback processes available to employees and customers. In the event additional feedback processes are requested and determined to be required in order to be accessible to people with disabilities, these will be introduced by Kobo.

Accessible Format:

By no later than January 1, 2016, Kobo will take steps to ensure that it complies with the requirements of Ontario accessibility laws with respect to the provision of publicly available information in an accessible format. This may include:

• Notifying members of the public and employees, that Kobo will accommodate accessibility requests regarding the provision of information in an accessible format on request;

• Consulting with any person requesting such information in order to determine that person’s specific needs;

• Providing the requested information in an accessible format, having regard to the needs of the person requesting such information.

Employment Standard:

Kobo is committed to fair and accessible employment practices.

1.) Recruitment Practices:

By January 1, 2016, Kobo will take steps to notify the public and employees that, when requested, Kobo will accommodate people with disabilities during the recruitment and assessment processes, and when people are hired. This may include:

• Placing such notifications in job postings and instructing any recruiting agencies used by Kobo to follow a similar practice;

• Specifically notifying candidates selected for interviews about Kobo’s policy to accommodate people with disabilities in the

If a candidate requests accommodation, Kobo will consult with the candidate to determine what sort of accommodation is appropriate and will attempt to provide such accommodation.

2.) Notification of Disability Policies (new and existing employees):

By January 1, 2016, Kobo will ensure reasonable steps have been taken to notify new and current employees about Kobo’s existing disability support programs and policies and will provide similar notifications if such programs and policies change. Such notifications will be provided having regard to the specific needs of any employees that have requested specific accommodation.

3.) Individual Accommodation Plans and Return to Work Policies:

By January 1, 2016 Kobo will ensure that there is a written process for developing individual accommodation plans and return-to-work policies for employees that have been absent due to a disability.

4.) Performance Management, Career Development, and Redeployment:

By January 1, 2016, Kobo will take steps to ensure the accessibility needs of employees with disabilities are taken into account in any performance management, career development, or redeployment processes. Steps may include:

• Ensuring that any performance management or career development programs/initiatives also include a review of any accommodation plans to determine whether any adjustments are warranted;

• Ensuring that coaching, feedback, and any documents related to performance management or career development programs/initiatives are provided in an accessible format, having regard to the needs of employees requesting accommodation.

Additional Information:

For more information on this Policy, or to obtain an accessible format of this document, please contact:

Legal or HR Department

Rakuten Kobo Inc.
150 John St., 5th Floor
Toronto, Ontario
M5V 3E3