The Canadian Bankers Association’s commitment to accessibility

The Canadian Bankers Association (CBA) recognizes the importance of equitable opportunities and strives to improve the accessibility of its operations. Our goal is to proactively identify and eliminate barriers, ensuring that everyone, regardless of ability, can engage fully with our organization.

Through ongoing evaluation of our accessbility journey, the CBA is dedicated to finding and addressing barriers to accessibility. The CBA’s Accessibility Plan 2024‑2027 below serves as a roadmap, outlining the key priorities and actions the CBA will undertake to improve on our commitment to provide a respectful and inclusive workplace that serves employees, our members and Canadians who access our services.

Providing feedback on the CBA’s Accessibility Plan

The CBA welcomes feedback on our Accessibility Plan. The Feedback Process section of the Plan outlines how you can contact the CBA to provide feedback to help us improve.
 

The Canadian Bankers Association Accessibility Plan 2024-2027

The Canadian Bankers Association (CBA) is the voice of more than 60 domestic and foreign banks operating in Canada and their 280,000 employees and it continues to provide governments and others with a centralized contact to all banks on matters relating to banking in Canada. The CBA advocates for public policies that contribute to a sound, thriving banking system to ensure Canadians can succeed in their financial goals.

The Association promotes financial literacy to help Canadians make informed financial decisions and sponsors two financial literacy seminar programs: Your Money Students and Your Money Seniors.

The Association also works with banks and law enforcement to help protect customers against financial crime and promote fraud awareness.

The CBA provides its members with information, research, and operational support, and contributes to the development of public policy on issues that affect financial institutions. The Association is continually involved in financial data collection and analysis, consumer protection efforts, fighting bank fraud, and developing industry consensus on issues impacting banks in Canada.

Requirements of the Accessible Canada Act

The Accessible Canada Act (the Act) is a federal law that aims to find, remove, and prevent barriers facing people with disabilities. The Act defines disabilities as impairments or functional limitations that, when combined with barriers, prevent people from fully and equally participating in society.

The Act applies to the CBA as a federal organization with less than 99 employees and is considered a small business. The CBA’s deadline to prepare an Accessibility Plan is June 1, 2024.

Executive Summary

The CBA is happy to share its first Accessibility Plan. This Plan presents the CBA’s new and ongoing efforts to realize the vision set out by the Act, which aims to create a barrier-free Canada by 2040. By working toward a barrier-free Canada, the CBA will identify, remove, and prevent barriers in the CBA’s workplaces and in our delivery of our work for our members and to Canadians.

The CBA’s Plan includes:

1. plans over a three-year period setting out how the Association will identify, remove, and prevent barriers to accessibility in its programs and services.
2. the intent to publish annual Progress Reports that describe how the Association is delivering upon its Accessibility Plan.
3. a process to collect, manage, and respond to feedback on accessibility, including on its Accessibility Plan and Progress Reports.

The CBA's Accessibility Plan will focus on the seven areas listed in the Act to address accessibility barriers over the next three years:

1. Employment;
2. The built environment (buildings and public spaces);
3. Information and communication technologies;
4. Communication, other than information and communication technologies;
5. The procurement of goods, services, and facilities;
6. The design and delivery of programs and services; and,
7. Transportation.
    

The CBA’s Accessibility Plan to address the seven key Priority Areas

The action plan commitments below are written to target barriers and represent the first steps toward closing these gaps.

1.0. Employment

Current State

The CBA believes strongly in providing equal access to employment and has historically looked for opportunities to reduce barriers in the workplace. Applicants to the CBA are made aware of the commitment to equal employment access through the CBA’s Equal Opportunity Employer statement that is found on the CBA’s Career page located on https://cba.ca/exploring-a-career-at-the-cba.

CBA employees are encouraged to self-identify for promotions and are given equal access to career development and advancement. Furthermore, employees have access to a robust benefits program including a health care spending account, flexible paramedical coverage, and a virtual care option.

There are opportunities for CBA to continue its path towards barrier-free employment including expanding our recruitment sources, improving our accommodation process for employees, and further developing a culture of inclusion and belonging.

Our Goal

Actions under the Employment section will improve recruitment, retention, and promotion of persons with visible and non-visible disabilities. They will identify additional recruitment sources that provide barrier-free ways to apply for open positions at the CBA.

Commitments

1. Enhance the current accommodation process during the hiring process by 2025.
2. Develop an easy and clear accommodation request process during Employee Onboarding that acts to enhance and make fully evident the accommodation policy by June 2025. Add an Accessibility Tool Guide to the Employee Onboarding process by June 2025.
3. Establish an Employee Accessibility Resource Group to create a support network for employees with disabilities and further a culture of inclusion by June 2025.
4. Research and create a plan to provide training for employees about accessibility, removal of barriers, and overall inclusion for all by June 2026.

2.0 Built Environment

Current state

The built environment at the CBA provides an accessible and largely barrier-free environment for both employees and guests. The main barrier in the built environment is the office’s doors. The doors are not automatic and require key card access. Signage throughout the built environment is high contrast but does not include braille for the visually impaired. Upon request, the CBA provides employees with an ergonomic assessment and ergonomic equipment to ensure a comfortable work environment. Employees have access to a recharge/relaxation room. There is a well-established protocol for assisting people with physical disabilities in exiting the building during an emergency situation, led by the building management and CBA floor wardens.

The CBA leases its office space. The building offers accessible parking, wheelchair-accessible entrances, security checkpoints, and elevators with braille and auditory cues.

Our Goal

Actions under the Built Environment will ensure that everyone can move freely around our offices.

1. Research and create a plan to provide training for staff volunteer floor wardens and assistant floor wardens that informs on how to assist people with disabilities other that physical disabilities in the event of an emergency by June 2025.
2. Establish an accessibility standard for the consideration of all future CBA office spaces by June 2025.
3. Obtain quotes for the removal of barriers in our head office (Toronto) and two satellite offices (Montreal and Ottawa) including installing automatic doors, upgrading lights to fully adjustable LEDs, and replacing signage to include braille by June 2026.
4. Determine the budget, feasibility, and timeline for the removal of barriers for each of our offices by June 2026.
5. The CBA will research the Toronto real estate market to consider other spaces that meet accessibility standards and consider if there are any opportunities by June 2027.
   

3.0 Information and Communication Technology (ICT)

Current State

The CBA uses a variety of technologies and digital tools. While the CBA’s main public website (cba.ca) is not fully compliant with WCAG standards, the Association is currently working toward compliance with WGAG 2.2 AA standards.

Our Goal

Actions under the ICT area will ensure accessible digital content and technologies and ensure effective communication of information to persons with disabilities.

1. Complete an audit and plan for updating the CBA’s web content to meet WCAG 2.2 AA standards by June 2025.
2. Complete an audit of our internal social media standards to identify areas for improved accessibility by June 2025.
3. Roll out new standards for posting graphics through social media to improve accessibility within the limits of each platform by June 2026.
4. Research and understand the implications and resources required for providing captioning on all pre-recorded video content in both English and French by June 2025.

4.0 Communication, other than ICT

Current State

The CBA aims for barrier-free branding and simple language and is working towards plain language for the majority of its communications products in print and on digital platforms.

Our Goal

Actions under the Communications area will ensure barrier-free services and spaces for persons with disabilities. This includes the use of plain language and alternate service options.

1. Establish best practices and develop Communication Guidelines that highlight the use of plain language and accessible design within the CBA by June 2025.
2. Provide plain language training for all employees responsible for communications with members and members of the public by June 2026.
3. Source options for vendors that provide audio recordings, braille printing, and sign language interpretations to be made available upon request for members and employees by June 2026.

5.0 Procurement of goods, services, and facilities

Current State

The CBA does not currently have a formal procurement policy or process.

Our Goal

Actions under the Procurement of goods, services, and facilities area will ensure the purchasing of goods, services and facilities is accessible by all.

1. Develop and publish a new Procurement Policy that prioritizes accessible goods and services, and facilities that offer barrier-free options or promote accessibility by June 2025.
2. Provide all employees responsible for procurement with training on the new policy and how to identify accessible design by December 2025.

6.0 Design and delivery of programs and services

Current State

The CBA does not currently have any official standards of accessibility in the design and delivery of programs and services. Members of the CBA are actively asked for and provide feedback on the programs and services provided to them; however, the process does not specifically ask about barriers to access. The CBA’s website for its members, the Member Portal, was designed with the Accessibility for Ontarians with Disabilities Act in mind including meeting WCAG standards.

Our Goal

Actions under the Design of delivery of programs and services will ensure that CBA members and the public receive services and facilities that are accessible to all.

1. Establish a best practices guide for CBA employees to inform the development and dissemination of programs and services that address common barriers that the public and members experience by June 2025.
2. Integrate a "Request for Accommodation" process for members when attending virtual or in-person events by December 2025.
3. Identify opportunities to integrate accessibility into the member feedback process by December 2025.
4. Research and create a plan to provide training for employees and managers that informs on accessibility, removal of barriers, and overall inclusion for all by June 2026.

7.0 Transportation

Current State

The CBA is not responsible for the transportation of members of the public.

Our Goal

The CBA recognizes that there are barriers as they relate to the transportation for persons with disabilities. While the CBA is not responsible for the transportation of the public or its members, it will create a goal to assist in removing transportation barriers.

1. Establish a guide to inform the level of accessibility when planning events for members and employees and ensure there are accessible transportation options to and from the event space by June 2025.

Consultations

The Executive Leadership Team of the CBA has engaged throughout the development of its first Accessible Plan and has approved and endorsed its Plan.

The CBA is committed to fostering accessibility and inclusivity. Importantly, the CBA established a volunteer Employee Accessibility Group. This group's purpose is to understand the experiences of employees within the CBA, gather their input, and assess the state of accessibility across seven priority areas outlined in the Act. The aim is to ensure that CBA workplaces are accessible to all, including employees, members, and the public.

The Employee Accessibility Group represents more than 20% of the overall CBA headcount and includes employees with diverse abilities willing to share their lived experiences. Additionally, the group consists of CBA employees representing functional expertise from areas who will be responsible for projects in this Plan and from each functional division within the CBA.

Summary

The Employee Accessibility Group will work to identify opportunities to make improvements through:

• Advocacy and Awareness: raising awareness about accessibility issues and advocating for the needs of persons with disabilities.
• Policy Implementation: supporting the implementation of policies and procedures to ensure compliance with the Accessible Canada Act.
• Accessibility Initiatives: developing and implementing initiatives to improve accessibility at the CBA, such as providing training, conducting accessibility audits, and making necessary accommodations.
• Feedback and Support: serving as a resource for employees with questions or concerns related to accessibility and providing support in navigating accessibility challenges.
• Feedback Mechanisms: encourage open communication and welcome feedback from all employees regarding accessibility issues or suggestions for improvement.
• Compliance: work diligently to ensure that the CBA complies with the requirements set forth by the Accessible Canada Act, as well as any additional accessibility regulations at the federal, provincial, or municipal levels.

Consultation Methodology

The Employee Accessibility Group provided consultation on the Accessibility Plan in two ways in a meeting to review the accessibility audit and goal recommendations, and in a review of the completed Accessibility Plan.

Goal Facilitation & Review Meeting

The Employee Accessibility Group met on March 25, 2024, via Teams. All members of the Employee Accessibility Group were provided with a copy of the Insight & Recommendations Report to review ahead of the first meeting. The agenda for the first meeting included:

1. Provide an overview of the Act.
2. Review the current state of accessibility at the CBA and gather their input.
3. Discuss the recommended goals for each of the 7 key areas:
   • Employment
   • Built environment (physical spaces)
   • Information and Communication Technologies (ICT)
   • Communication, other than ICT
   • Procurement (buying and renting things and places)
   • Programs and services
   • Transportation
4. Establish next steps which include collecting ongoing suggestions for accessibility, the Group’s review of the draft Plan prior to the Plan’s public publication date, and additional future meetings.
    

Contacting the CBA and providing feedback

Feedback Process

The CBA receives feedback from its employees, members, and the public, including feedback on accessibility, through various channels. Feedback about accessibility can be made by telephone, mail, and email. Feedback can be in the form of a complaint, a compliment, or a suggestion. Feedback can be sent in a way that identifies the sender for follow‑up or can be sent anonymously.

We commit to acknowledging and addressing the feedback we receive on accessibility unless the feedback is submitted anonymously. Internal processes are also in place to ensure that we monitor, report on, and incorporate the feedback that relates to accessibility barriers and the Accessibility Plan into our future accessibility plans and progress reports.

The CBA’s designated individual to receive feedback about accessibility is the Vice President, Talent Management. To send feedback by email about accessibility barriers you are experiencing or about the CBA’s Accessibility Plan, you can send an email to the Vice President, Talent Management at AccessibilityFeedback@cba.ca.

Please note: If you prefer to submit your feedback anonymously, please remember that we are unable to acknowledge or reply to feedback.

Accessibility feedback can be submitted anonymously or by identifying yourself in the following ways:

By phone: 416‑362‑6092 from 9:00 am – 5:00 pm EST.
By email: to AccessibilityFeedback@cba.ca
By Mail:
Vice President, Talent Management
c/o Accessibility Feedback
Box 348
Commerce Court West
199 Bay Street, 30th Floor
Toronto, Ontario M5L 1G2

Alternative Formats Available

The CBA’s Accessibility Plan is available in the following formats:

• Print
• Large Print
• Electronic
• Audio
• Braille

Alternative formals of the CBA’s Accessibility Plan may be requested by phone at 416‑362‑6092.
 

Conclusion

Inclusion of people with disabilities in all aspects of the CBA’s operations and work is a top priority. The CBA is committed to improving accessibility by implementing this Accessibility Plan over the next three years. The CBA is also dedicated to continuing to examine its practices and operations to find and address barriers to accessibility. The CBA understands that accessibility is an ongoing process and is committed to continuing its consultation efforts.