Accessibility

4.0 Key Areas in Section 5

4.1 Employment

Identified Barriers:

• We can find practical means for further promoting a culture which values diversity, equity and inclusion with respect to persons with disabilities.
• Support and engagement for better accessibility within the workplace culture could be improved throughout the employment lifecycle from recruiting, hiring and onboarding to ongoing employment, performance management and career development.
• Managers and employees may be unaware of the resources and reasonable accommodations available, along with the process for requesting and implementing such reasonable accommodations.
• The objectives and goals of our Diversity, Equity and Inclusion Charter could be articulated in more details with respect to the impacts on persons with disabilities.

Action Plan:

• Evaluate how our existing processes and Human Resources Information System (HRIS) are performing on a periodic basis and update as needed.
• Ensure the onboarding materials, Employee Handbook and intranet page include sufficient information about the availability of resources and reasonable accommodations throughout the employment lifecycle, the simple and dignified process for submitting such requests, and the available options for providing feedback to the company.
• Publish the accessibility policy with the corporate policies on the intranet page for easy reference by our employees.
• Highlight the availability of resources and reasonable accommodations for persons with disabilities during the annual employee training on the Employee Handbook.
• Conduct management training on the hiring process in line with our Diversity, Equity and Inclusion Charter, the availability of resources and reasonable accommodations throughout the employment lifecycle, the proper process for requesting either, mechanisms for applying the performance management process in an equitable manner across the organization for all workers, including workers with disabilities, and the importance of regularly reiterating each with their team members.
• Encourage feedback from employees with disabilities either directly to Human Resources or via the IntelePeer Trustline to improve inclusion, awareness, and acceptance within our corporate culture.
• Include all bona fide occupational requirements in selection criteria expressly in the job listing.
• Review all pre-employment tests and selection criteria to ensure none inadvertently exclude persons with disabilities, and ask candidates to inform us if additional time is needed as an reasonable accommodation for a disability.
• Review current standards periodically for leading accessibility standards for hiring and workplace practices.

4.2 Built Environment

Identified Barriers:

• IntelePeer does not have any office or retail space or other facilities in Canada. Our employees in Canada, and most of our employees in the U.S., work entirely on a remote basis.
• Less than 25% of our U.S. employees regularly work in one of our two offices in the U.S. once or twice each week. These two offices were built out within the past few years to current accessibility standards in the U.S., so the controls should not need to be updated during the period of this Plan.
• Our communications network is housed in leased space, which is only accessed on an intermittent basis for purposes of inspection, installation and maintenance.

Action Plan:

• None needed for this Plan period at this time.

4.3 Information and Communication Technologies

Identified Barriers:

• Language used may be too difficult or complicated to understand on our Information and Communication Technologies, including without limitation our website, chatbot, online forms, webinars, vlogs, customer portals, training platform, company intranet page, and social media (“Tools”).
• All the video tools we use may not have Closed Captioning (CC) and Described Video (DV) available or enabled.
• Our two customer portals and public website are compliant with Level AA of the Web Content Accessibility Guidelines (WCAG) 2.0, but we need to remain up to date with subsequent guideline releases.
• It has been an extended period of time since our customer portals have been tested due to focus on testing new service and development releases.

Action Plan:

• Simplify language used in these Tools to make more clear and concise
• Investigate options for alternate methods of communication for transactions in these Tools we might add in the future.
• Improve communications to users about the availability of alternate methods to meet their accessibility needs.
• Enable CC and/or DV to any of our video content more consistently when available, and seek Tools with CC and DV capabilities for more of our video content.
• Ensure there is sufficient time, or an opportunity allowing users to extend time, needed to complete any online forms or transactions.
• Set up testing for our customer portals with our third-party consultant in the coming six months, and schedule for subsequent testing on a regular basis.
• Develop guidelines for our teams that create, implement and procure vendors for these Tools that foster greater accessibility.
• Training on accessibility for employees creating, implementing or finding vendors for these Tools.
• Seek opportunities to collect more feedback from regular users for suggestions on areas we can improve the accessibility of these Tools.

4.4 Transportation

Identified Barriers:

• Transportation does not currently apply to any operations of IntelePeer.

Action Plan:

• None needed for this Plan period.

4.5 Procurement of Goods, Services and Facilities

Identified Barriers:

• Our internal teams may not be considering new and existing vendors’ adherence to industry standards and legal requirements for accessibility.
• Our third party management policies and processes could be bolstered to encourage our vendor managers to emphasize these attributes in their selection process.

Action Plan:

• Update the third party management policies and processes to expand on the criteria considered during selection.
• Train all of our vendor managers on our accessibility expectations, including fundamentals and best practices for confirming that vendors they are considering identify and remove barriers to accessibility.
• Conduct surveys with existing key vendors to identify their accessibility practices and policies.
• Create accessibility contract language for all third-party goods, services, and facilities procured to include in the IntelePeer Supplier Code of Conduct.

4.6 Design and Delivery of Products and Services

Identified Barriers:

• Our multi-channel services can help our enterprise customers further the accessibility of their communications and products for their customers or other third parties, like our speech-to-text, natural language processing, and speech recognition functionalities, but other opportunities exist especially with generative artificial intelligence to further enhance the functionalities of our services and platforms.
• We may not specifically promote those functionalities with our enterprise customers to date.
• Our users, salespeople, account managers and customer support teams may not always be fully aware of the accessibility features of our services and platform.
• Our design practices around accessibility should reflect current industry standards and guidelines as practical.
• Not all of our product and development managers may have knowledge and awareness about barriers experienced by persons with disabilities.

Action Plan:

• Add information to our reference materials (training, wiki, etc.) for internal teams which regularly work with our customers about the accessibility of our services and platform.
• Continue working with our third-party consultant to test all new services, features or functionality during the design phase of product and software development lifecycles, but also consider retesting legacy services and features based on current technologies and standards, including reviewing new standards in WCAG 2.1.
• Seek feedback on accessibility from internal teams using our services for their job function.
• Include more frequent inquiries in our standard customer surveys, and query our Customer Advisory Board, for feedback on accessibility associated with our services and platform.

5.0 Definitions

Accessible: Any space, feature, element, site, environment or facility that can be used (e.g., located, approached, entered, exited or operated) by people with varying disabilities, with or without the use of mobility aids or assistive devices. Can also refer to services, practices and programs.

Accessibility: To enable persons with disabilities to live independently and participate fully in all aspects of life.

Accommodation: Making adjustments to facilities, rules, policies, workplace cultures, and physical environments to ensure that they are readily accessible and usable by a person with a disability within the employment life cycle, such as job restructuring, modified work schedules, reassignment to a vacant position, acquisition or modification of equipment or devices, appropriate adjustment or modifications of training materials or policies, the provision of qualified readers or interpreters, and other similar accommodations for individuals with disabilities.

Barrier: Anything the hinders the full and equal participation in society of persons with an impairment, including those with a physical, mental, intellectual, cognitive, learning, communication or sensory impairment or a functional limitation, and includes:

• a physical barrier
• an architectural barrier
• an information or communications barrier
• an attitudinal behavioral barrier
• a technological barrier

Communication: Languages, display of text, Braille, tactile communication, large print, accessible multimedia as well as written, audio, plain-language, human-reader and augmentative and alternative modes, means and formats of communication, including accessible information and communication technology.

Disability: Any impairment, including a physical, mental, intellectual, cognitive, learning, communication or sensory impairment, or a functional limitation, whether permanent, temporary or episodic in nature, or evident or not, that, in interaction with a barrier, substantially hinders a person’s full and equal participation in society.

2024 Progress Report