Canada Employment Accessibility Policy

Updated: August 10, 2026.

Purpose

Envoy Air Inc. is committed to identifying, removing, and preventing accessibility barriers in employment so that employees and applicants with disabilities can participate fully, equally, and with dignity in the workplace. This policy supports Envoy’s obligations under the Accessible Canada Act, the Accessible Canada Regulations, and other related laws and regulations.

Scope

This policy applies to all Canadian employment-related activities at Envoy, including recruitment, hiring, onboarding, training, work assignments, scheduling, accommodation, performance management, promotion, transfer, return to work, modified or transitional duty, discipline, termination, and workplace communications. It applies to all full-time, part-time, and temporary employees, applicants for employment, interns, contractors where applicable, and managers involved in employment decisions.

Guiding Principles

• Employees and applicants with disabilities must be treated with dignity and respect.
• Employees and applicants with disabilities must have equal opportunity to participate in employment and career development.
• Accessibility must be considered proactively when Envoy designs, reviews, or changes employment policies, systems, programs, tools, workspaces, and practices.
• Persons with disabilities must be meaningfully consulted in identifying employment barriers and developing measures to remove and prevent those barriers.
• Accommodation will be individualized, collaborative, timely, confidential, and provided to the point of undue hardship.
• Accessibility is a shared responsibility among Envoy, managers, Human Resources, employees, applicants, and other workplace participants.

Identification and Removal of Employment Barriers

Envoy will review its employment policies, practices, programs, workplace tools, and physical work environments to identify barriers that may affect employees and applicants with disabilities. Barriers may be physical, technological, attitudinal, communication-related, procedural, policy-based, or systemic. Envoy will take reasonable steps to remove identified barriers and prevent new barriers from being created.

Recruitment, Selection, and Hiring

Envoy will provide an accessible recruitment and hiring process. Job postings, application procedures, interviews, assessments, background checks, and candidate communications will be reviewed for accessibility barriers. Candidates will be informed that accommodation is available during the hiring process.

Envoy will avoid asking candidates about disability-related accommodation needs required to perform the work until after a conditional offer is made. Selection criteria will be based on bona fide job requirements and essential duties, and not on accommodation needs or requests.

Workplace Accommodation

Envoy will accommodate employees and applicants with disabilities to the point of undue hardship. Accommodation may include changes to job duties, work schedules, workstations, equipment, uniforms or appearance requirements, communication methods, training formats, workplace technology, return-to-work arrangements, leave management, or other measures appropriate to the individual’s needs and the essential duties of the role.

Accommodation requests may be made verbally or in writing to a supervisor, manager, Human Resources, or another designated Envoy contact. Managers who become aware that an employee may need assistance because of a disability-related limitation must consult Human Resources before taking employment action that may affect the employee.

Accommodation Process

1. The employee may request accommodation through their direct supervisor. If the accommodation request is denied, the reasons should be clearly communicated to the employee.
2. The employee may request a second opinion by submitting a request for reconsideration through the General Manager.
3. If, following the review of the original decision, the employee is still not satisfied, he or she may ask that the matter be referred to Human Resources.
4. Envoy may request reasonable supporting information necessary to understand restrictions, limitations, prognosis, or accommodation needs.
5. The accommodation will be documented where appropriate and reviewed periodically to confirm that it remains effective.

Confidentiality

Accommodation information will be treated as confidential and shared only with those who need the information to assess, implement, monitor, or administer the accommodation. These conversations will be handled in as confidential and respectful a manner as possible due to the sensitive and personal nature of the topics being discussed.

Undue Hardship

Envoy will assess undue hardship on an individual, case-by-case basis. Undue hardship means more than inconvenience or preference. Relevant factors may include significant cost, substantial operational disruption, health and safety considerations, and the effect on applicable legal or collective agreement obligations.

The Supreme Court of Canada has accepted that some considerable measure of hardship must be anticipated in ensuring accommodation. When a request for accommodation involves a cost, in order for the accommodation to be considered as undue hardship, that cost would have to substantially affect the viability of the organization. If the cost of an accommodation is exceptionally high or complex, it may be possible to phase in the accommodation.

Onboarding, Training, and Career Development

Envoy will provide onboarding, training, meetings, workshops, career development, and promotional opportunities in accessible formats where required. Training materials and communications will be provided in formats that support participation by employees with disabilities. Managers will consider accessibility needs when scheduling training, assigning mentors, evaluating readiness for advancement, and identifying development opportunities.

Performance Management, Discipline, and Promotion

Envoy will administer performance management, coaching, discipline, promotion, transfer, and termination processes in a manner that is sensitive to and does not discriminate against employees with disabilities. Before taking employment action related to attendance, productivity, conduct, or performance, managers must consider whether a known or reasonably apparent disability-related need may be relevant and consult Human Resources as appropriate.

Workplace Technology, Tools, and Communications

Envoy will consider accessibility when selecting, implementing, or changing workplace technology, scheduling platforms, communication tools, training systems, forms, and employment-related documents. Employees may request accessible formats, communication supports, assistive technology, or other adjustments needed to use workplace systems and information.

Physical Workplace Accessibility and Emergency Procedures

Envoy will consider accessibility in employee workspaces, including offices, airport work areas, crew rooms, training facilities, washrooms, parking areas, and other areas used by employees where Envoy controls or can influence the work environment. Where employees require disability-related support in emergency procedures, Envoy will develop individualized workplace emergency response information where appropriate and required by law.

Modified Duty, Transitional Duty, and Return to Work

Envoy may provide modified duties and/or return-to-work supports, or other temporary measures for employees who are unable to perform all regular duties due to disability, injury, illness, or medical restrictions. These measures will be assessed based on the employee’s restrictions, essential job duties, operational requirements, workplace location, and applicable legal obligations.

Workplace Culture, Respect, and Non-Retaliation

Envoy is committed to a workplace culture that is safe, respectful, inclusive, and free from discrimination, harassment, hate-related behaviour, threats, workplace violence, bullying, and ableism. Envoy will not tolerate retaliation against any person who requests accommodation, identifies an accessibility barrier, participates in consultation, provides accessibility feedback, or raises a concern in good faith.

Accessibility Feedback and Consultation

Envoy will maintain a process for receiving accessibility feedback, including feedback about barriers in employment and the implementation of accessibility measures. Envoy will consult persons with disabilities when preparing and updating its accessibility plan and progress reports. Consultation may include employees with disabilities, applicants, employee representatives, accessibility advisors, disability organizations, and other persons with relevant lived experience or expertise.

Roles and Responsibilities

Envoy is responsible for maintaining accessible employment policies and practices, providing training and resources, funding approved accommodations, maintaining a feedback process, and reviewing employment barriers as part of its accessibility planning cycle.

Human Resources is responsible for supporting managers and employees through the accommodation process, maintaining confidentiality, documenting decisions where appropriate, helping identify barriers, and escalating complex matters for legal or operational review.

Managers and supervisors are responsible for responding promptly to accommodation requests, identifying potential accessibility barriers, consulting Human Resources before taking action that may affect an employee with a known or apparent disability-related need, and supporting approved accommodations.

Employees and applicants are responsible for communicating accommodation needs where possible, participating in the accommodation process, providing reasonable supporting information when requested, and advising Envoy if an accommodation is not working or needs to be reviewed.

Review, Monitoring, and Recordkeeping

Envoy will review this policy periodically and as required to reflect legal developments, operational changes, consultation feedback, and accessibility plan commitments. Envoy will maintain appropriate records of accommodation requests, decisions, accessibility feedback, barrier reviews, consultation activities, and measures taken to remove or prevent employment barriers, subject to applicable privacy and confidentiality requirements.

Related Policies and Resources

• Canada Culture of Respect Policy
• Canada Accommodation Policy
• Canada Workplace Harassment and Violence Policy
• Work Schedule Policy
• Modified Duty, Transitional Duty, and return-to-work procedures