Accessibility Policy

Purpose

This accessibility policy and plan outline the actions that Xanadu Quantum Technologies Inc. (the “Company”) has and will put in place to improve opportunities for people with disabilities in accordance with the Integrated Accessibility Standards under the Accessibility for Ontarians with Disabilities Act, 2005 (the “Act” or “AODA”). In addition to this policy and plan, the Company also has a separate policy regarding accessible customer service.

COMMITMENT TO ACCESSIBILITY: The Company is committed to treating all people in a way that allows them to maintain their dignity and independence. We believe in integration and equal opportunity. We are committed to meeting the needs of people with disabilities in a timely manner, and will do so by preventing and removing barriers to accessibility and meeting accessibility requirements under the AODA and the Integrated Accessibility Standards.

Scope

This policy applies to the Company’s operations in the province of Ontario.

Policy

Emergency Information and Procedures

The Company is committed to providing customers and clients with publicly available emergency information in an accessible way upon request. We will also provide individualized workplace emergency response information to employees with disabilities if we are made aware of the need for accommodation.

Training

The Company has provided, and will continue to provide, training to employees, volunteers, and other staff members who provide goods, services or facilities on behalf of the Company, as well as any persons who participate in developing Company policies, on the requirements set out in the Integrated Accessibility Standards and on the Ontario Human Rights Code as it relates to people with disabilities. Training will be provided in a way that best suits the duties of the applicable staff, within 4 weeks after staff commence their duties or as soon as practicable, and on an ongoing basis when changes are made to policies pursuant to the Integrated Accessibility Standards. A record of this training will be kept, including the dates on which training is provided and the number of individuals to whom it is provided.

Feedback Processes

Comments on our services to customers with disabilities are welcome and appreciated. Feedback regarding the way the Company provides goods and services to people with disabilities, and about the accessibility of the feedback process itself, can be made by e-mail and verbally. All feedback, including complaints, will be directed to the Human Resources Department. Customers can expect to hear back within 5 business days. Accessible formats and communication supports are available on request. See contact Information (Section 11) for more information on where to provide feedback.

Accessible Formats

The Company is committed to meeting the communication needs of people with disabilities in a timely manner that takes into account the person’s accessibility needs and at no additional cost to the person. We will take reasonable steps to ensure that all publicly available information controlled by the Company is provided in an accessible way upon request. The Company will also consult with the person making the request to determine his or her information and communication needs. The Company will notify the public about the availability of accessible formats and communication supports, including with respect to the feedback process, by posting a notice to the website.

Emergency Procedures, Plans, and Public Safety Information

Upon request, any emergency procedures, plans or public safety information the Company prepares and makes available to the public will be provided in an accessible format or with appropriate communication supports as soon as practicable. The Company shall provide individualized workplace emergency response information to employees who have a disability, if the disability is such that the individualized information is necessary and the Company is aware of the need for accommodation due to the employee’s disability. An individual and documented emergency and evacuation plan will be provided to any such employee, as well as to any person designated to assist the employee, with the consent of that employee. The Company shall review the individualized workplace response information upon the following events:

When the employee moves to a new location in the workplace;
When the employee’s overall accommodation needs are reviewed; and
Upon review of the Company’s general emergency response policies.

Websites

The Company will take reasonable steps to ensure that all new websites controlled by the Company, and content on those sites published after January 1, 2012, conform with the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0 in accordance with the schedule in the Act, if meeting such requirements is practicable given (among other things) the availability of commercial software or tools.

Employment

The Company is committed to fair and accessible employment practices. During the recruitment process, the Company will notify job applicants and the public about its commitment to accommodate those with disabilities and will advise those selected for an interview that accommodation is available upon request. Job descriptions will be reviewed on an ongoing basis to ensure that stated requirements are necessary and the Company will take steps to prevent and remove any accessibility barriers it identifies as unnecessary. If a selected applicant requests a disability-related accommodation, the Company will consult with the applicant and arrange for the provision of suitable accommodations in a manner that considers the applicant’s accessibility needs. Advertisements will include a statement that the Company is an inclusive workplace and welcomes all qualified applicants to apply. When making offers of employment, the Company shall notify a successful applicant of its policies regarding disability accommodations. New employees will receive information related to disability accommodations as soon as practicable after they begin their employment. Discussions around performance management, career advancement, and reassignment will address any disability-related accommodation needs. Where accommodation needs are identified, management will work with Human Resources to ensure that employees are provided with accommodation in accordance with their needs. Individual accessibility needs and individual accommodation plans will be taken into account during any performance management, career development and advancement, and reassignment process.

Performance management includes activities related to assessing and improving employee performance, productivity and effectiveness, with the goal of facilitating employee success.
Career development and advancement includes providing additional responsibilities within an employee’s current position and the movement of an employee from one job to another in an organization that may be higher in pay, provide greater responsibility or be at a higher level in the organization or any combination of them and, for both additional responsibilities and employee movement, is usually based on merit or seniority, or a combination of them.
Reassignment includes the reassignment of employees to other departments or jobs within the organization as an alternative to layoff, when a particular job or department has been eliminated by the organization.

Documented Individual Accommodation Plans

In accordance with the process below, the Company shall develop documented individual accommodation plans for employees with disabilities identifying any accommodations to be provided (each such plan, a “Plan”). Upon request, a Plan will include any information regarding accessible formats and communications supports provided. A Plan will also include information regarding individualized workplace emergency response information as required. Plans will be reviewed and updated on an as-required basis. In developing Plans, the Company shall consider:

The manner in which an employee requesting accommodation can participate in the development of the individual accommodation plan.
The means by which the employee is assessed on an individual basis.
The manner in which the employer can request an evaluation by an outside medical or other expert, at the employer’s expense, to assist the employer in determining if accommodation can be achieved and, if so, how accommodation can be achieved.
The manner in which the employee can request the participation of a representative from their bargaining agent, where the employee is represented by a bargaining agent, or other representative from the workplace, where the employee is not represented by a bargaining agent, in the development of the accommodation plan.
The steps taken to protect the privacy of the employee’s personal information.
The frequency with which the individual accommodation plan will be reviewed and updated and the manner in which it will be done.
If an individual accommodation plan is denied, the manner in which the reasons for the denial will be provided to the employee.
The means of providing the individual accommodation plan in a format that takes into account the employee’s accessibility needs due to disability.

Return to Work Process

Employees returning to work after a period of disability will work with Human Resources to develop a suitable return to work plan that addresses barriers and accommodation needs for a successful transition to the workplace. As part of the return to work process, the Company will outline the steps it will take to facilitate the employee’s return to work, and will create a Plan in keeping with the above.

Design of Public Spaces

The Company will meet the Design of Public Spaces Standards when building or making major modifications to public spaces, including ensuring its work spaces have automatic door openers to assist persons with mobility challenges. We will also put reasonable procedures in place to prevent service disruptions to accessible parts of these public spaces and to deal with temporary disruptions when accessible elements required under these Standards are not in working order. In the event of a service disruption, the Company will notify the public of the service disruption and alternatives available.

Contact Information

For more information about this accessibility policy and plan, including if you would like to make a request under this accessibility policy and plan, please contact us via email at hr@xanadu.ai or mail, or in person at:

Xanadu Quantum Technologies Inc.24th fl, 777 Bay Street, Toronto, Ontario, M5G 2C8Attention: Human Resources Department

Accessible formats of this document are also available for free upon request.

Administration

This Policy will be interpreted and applied consistent with the Company’s obligations under applicable legislation. Subject to compliance with applicable legislation, the Company shall have full discretionary authority to administer, interpret and apply this policy. The Company reserves the right to modify, amend, suspend or terminate this policy at any time, in its sole discretion, with or without notice.