Last Updated: October [16], 2023

1. Purpose

Withe is committed to ensuring and facilitating equitable access to its services and software using electronic and information technologies (“EIT”) for persons with disabilities, and we will use reasonable efforts to eliminate barriers experienced by such individuals. This Policy establishes standards for designing, implementing, iterating, and updating all web-based content and services in consideration of persons with disabilities.

2. Definitions

For the purposes of this Policy: "disability" means:

  • any degree of physical disability, infirmity, malformation or disfigurement that is caused by bodily injury, birth defect or illness and, without limiting the generality of the foregoing, includes diabetes mellitus, epilepsy, a brain injury, any degree of paralysis, amputation, lack of physical co‐ordination, blindness or visual impediment, deafness or hearing impediment, muteness or speech impediment, or physical reliance on a guide dog or other animal or on a wheelchair or other remedial appliance or device;
  • a condition of mental impairment or a developmental disability;
  • a learning disability, or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language;
  • a mental disorder; or
  • an injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997.

3. Commitment to Accessibility

Withe is committed to providing equitable access to our EIT content to persons with disabilities. Our goal is to ensure that our content and services is accessible to all individuals in a way that allows them to maintain their dignity and independence, and we will comply with the standards set out under Accessible British Colombia Act, and the Accessibility for Ontarians with Disabilities Act, 2005, to the best of our ability.

4. Scope

This Policy applies to all EIT content designed, developed, produced, or maintained by Withe and that are provided to the public and our staff, who are accountable for providing accessibility to persons with disabilities.

5. Authority

The Accessibility Specialist (the “Accessibility Specialist”) at Withe is responsible for implementing and enforcing this Policy, in coordination with the Chief Officers of Withe (the “Leadership Team”).

6. Procedures and Guidelines

Withe will adopt procedures and guidelines for designing, developing, publishing, and maintaining accessible EIT content. These procedures and guidelines are as follows:

  1. The Leadership Team will provide resources to the Accessibility Specialist to ensure the Company is following the Policy and together with the Accessibility Specialist, will assist staff in designing, implementing, iterating, producing, and maintaining accessible EIT.
  2. The Accessibility Specialist will oversee and coordinate Withe’s efforts to provide training and education to staff and other individuals who provide services to the public on the provision of its services to persons with disabilities, including how to understand and comply with this Policy, how to interact with persons with disabilities, as well as offering continuing education regarding accessible EIT.
  3. The Leadership Team will establish an accessibility review committee to review EIT to determine whether the goals and objectives set out under this Policy are being achieved, as well as to oversee feedback regarding the methods we use to provide services to persons with disabilities.
  4. The Accessibility Specialist will be responsible for answering any questions regarding EIT accessibility and general questions concerning this Policy.
  5. The Accessibility Specialist will conduct accessibility testing and evaluations to determine whether changes need to be made to the Policy and to ensure up-to-date procedures and guidelines. Modifications to this Policy will only be made once the impact of the changes on persons with disabilities have been considered.

7. Communication

If telephone communication is not suitable or is unavailable, we will offer to communicate with customers by email. We will communicate with persons with disabilities in ways that consider their needs.

8. Feedback and Questions

Withe welcomes any feedback to improve this Policy and the methods we use to provide services to persons with disabilities. If there are any questions or concerns regarding this Policy, please contact the Accessibility Specialist at

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