In Ontario, the Accessibility for Ontarians with Disabilities Act, 2005 (the “AODA”) aims to create a more accessible Ontario by identifying and, to the extent possible, eliminating barriers experienced by people with disabilities.

The Integrated Accessibility Standards regulation (the “IASR”), enacted under the AODA, sets out obligations with respect to five accessibility standards in the areas of Information and Communications, Employment, Transportation, Design of Public Spaces, and Customer Service, in addition to certain general requirements. Robinhood Canada Ltd. (the “Company”) is committed to meeting its obligations under the IASR.

The Company is further committed to ensuring that every employee receives equitable treatment with respect to employment, without discrimination, and receives accommodation in a timely manner where required, in accordance with the provisions of the Ontario Human Rights Code and the AODA and its regulations.

Policy Statement

The Company is committed to treating all people in a way that allows them to maintain their dignity and independence. The Company believes in integration and equal opportunity. The Company is committed to meeting the needs of persons with disabilities in a timely manner, and will do so by identifying, removing and preventing barriers to accessibility and meeting accessibility standards in accordance with the AODA.

To Whom Does this Policy Apply?

This policy applies to the Company’s operations in Ontario and to all of the Company’s personnel, as defined below, who perform services for the Company in the Province of Ontario.

Defined Terms

The following terms as used in this policy have the following meanings:

Training Personnel and Other Persons

The Company will ensure that training is provided on the requirements of the accessibility standards referred to in the IASR and on the Human Rights Code as it pertains to persons with disabilities to:

all of the Company’s personnel (including paid and unpaid, full-time and part-time, and contract positions);
all persons who participate in developing the Company’s policies; and,
all other persons who provide goods, services or facilities on the Company’s behalf.

The training will be appropriate to the duties of the personnel and such other persons.

Personnel and such other persons will be trained when changes are made to the Company’s Integrated Accessibility Standards Policy. New personnel and such other persons will be trained as soon as practicable.

Feedback

The Company will ensure that the Company’s process for receiving and responding to feedback are accessible to persons with disabilities by providing, or arranging for the provision of, accessible formats and communications supports, upon request. The Company will notify the public about the availability of accessible formats and communication supports.

Accessible Formats and Communication Supports

Upon request, the Company will provide, or will arrange to provide, accessible formats and communication supports for persons with disabilities in connection with their communications with the Company or when accessing publicly available information or documents from the Company. The Company will do so in a timely manner that takes into account the person’s accessibility needs due to disability and at a cost that is no more than the regular cost charged to other persons. The Company will consult with the person making the request in determining the suitability of an accessible format or communication support.

Workplace Emergency Response Information

The Company will provide individualized workplace emergency response information to employees who have a disability, if the disability is such that the individualized information is necessary, and if the Company is aware of the need for accommodation due to the employee’s disability. The Company will provide this information as soon as practicable after becoming aware of the need for accommodation.

Where the employee requires assistance, the Company will, with the employee’s consent, provide the workplace emergency response information to the person the Company has designated to provide assistance to the employee.

The Company will review the individualized workplace emergency response information when the employee moves to a different location in the organization, when the employee’s overall accommodation needs or plans are reviewed and when the Company reviews its general emergency response policies.

Recruitment, Assessment or Selection Process

The Company will notify its employees and the public about the availability of accommodation for applicants with disabilities in its recruitment process.

The Company will notify job applicants when they are individually selected to participate further in an assessment or selection process that accommodations are available upon request in relation to the materials or processes to be used.

If a selected applicant requests an accommodation, the Company will consult with the applicant and provide, or arrange for the provision of, a suitable accommodation in a manner that takes into account the applicant’s accessibility needs due to disability.

Notice to Successful Applicants

When making offers of employment, the Company will notify the successful applicant of its policies for accommodating employees with disabilities.

Informing Employees of Supports

The Company will inform its employees of its policies (and any changes to those policies) used to support employees with disabilities. The Company will provide these polices to new employees as soon as practicable after commencing employment.

Accessible Formats and Communication Supports for Employees

Upon the request of an employee with a disability, the Company will consult with the employee to provide, or arrange for the provision of, accessible formats and communication supports for information that is needed to perform the employee’s job, and information that is generally available to other employees. In determining the suitability of an accessible format or communication support, the Company will consult with the employee making the request.

Performance Management, Career Development and Advancement & Redeployment

The Company will take into account the accessibility needs of employees with disabilities when conducting performance management, providing career development and advancement to employees, or when redeploying employees.

Individual Accommodation Plan

The Company is committed to providing accommodations for people with disabilities. The Company has set out a process for when an employee ‎with a disability requests an accommodation. The Company will notify all new and existing employees of the process for requesting accommodation related to a disability.

Return to Work Process

The Company is committed to supporting employees who have been absent from work due to a non-work-related disability and who require an accommodation in order to return to work (“RTW”). As a result, the Company has implemented a RTW process to facilitate an employee’s safe and timely return to work. The Company will notify all new and existing employees of the RTW process.

Accessibility of Services

The Company strives to communicate with customers with a disability in a manner that takes into account both the customer’s disability and the customer’s preferred method of communication. To the extent possible, upon request, the Company will provide all published information or communications for its customers in accessible formats or electronic/digital formats that facilitate conversion of the information or communication into an accessible format.

The Company will allow customers with a disability, where possible, to use their own assistive devices. Where a barrier prevents the use of an assistive device, the Company will endeavor to remove the barrier or make best efforts to accommodate the customer by an alternative means.

The Company will allow customers with a disability to be accompanied by a service animal and to keep the service animal with them on the Company’s premises, unless excluded by law.

The Company will allow customers with a disability to be accompanied by a support person and will ensure the customers have access to their support person while on the Company’s premises.

Notice of Temporary Service Disruptions

The Company will notify customers if there is a planned or unexpected disruption of a facility or service that customers with a disability usually use to access their services.

Training and Records

The Company will provide training, and ongoing training as required under the AODA, to all of the Company’s personnel to whom the Customer Service Standard Policy applies as well as to those persons charged with developing the Customer Service Standard Policy and related procedures and practices.

Training will be provided to all of the Company’s personnel to whom the Customer Service Standard Policy applies after their start date with the Company.

Feedback

The Company will provide, or arrange to provide, a feedback process in accessible formats and communication supports, on request.

The Company will maintain a number of channels through which customers can provide their feedback, including electronically, in writing and in person.

The Company will strive to respond to all feedback received as soon as practicable.

Notice of Availability of Documents

The Company will make its Customer Service Standards Policy available to the public and its customers upon request. The Company will notify the public and its customers on its website that the Customer Service Standards Policy is available upon request.

This Integrated Accessibility Standards Policy exists to ensure accessible service excellence to customers and employees with disabilities. Inquiries, questions or complaints in regards to this Integrated Accessibility Standards Policy should be referred to: by email to hr-compliance@robinhood.com.

means,(a) 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 coordination, 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;

(b) a condition of mental impairment or a developmental disability;
(c) a learning disability, or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language;
(d) a mental disorder; or
(e) an injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997.

“barrier”

“disability”

means an employee of the Company in Ontario, whether engaged on a full-time, part-time, temporary or casual basis.

“employee”

“personnel”

means all of the Company’s employees, contractors and volunteers in Ontario.

GENERAL STANDARDS

INFORMATION AND COMMUNICATIONS STANDARDs

EMPLOYMENT STANDARDs

CUSTOMER SERVICE STANDARDs

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