Last updated 1.22.25

The following policy has been established by the Cumming Management Group, Inc. (“Cumming Group”) to govern the company’s programs, services and facilities in accordance with the World Wide Web Consortium Web Content Accessibility Guidelines.

These standards are developed to break down barriers and increase accessibility for persons with disabilities in the areas of information and communications and employment.

Commitment

Cumming Group 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 persons with disabilities with respect to the company’s programs, services and facilities in a timely manner, and will do so by preventing and removing barriers to accessibility and meeting accessibility requirements under applicable laws.

Accessibility Plan

Cumming Group will develop, maintain and document an Accessibility Plan outlining the company’s strategy to prevent and remove barriers from its workplace and to improve opportunities for persons with disabilities.

The Accessibility Plan will be reviewed and updated at least once every five years and once completed will be posted on the company’s website.

Training Employees and Volunteers

Cumming Group will create a program to ensure that training is provided on the requirements under applicable laws and will continue to provide training as it pertains to persons with disabilities, to:

• all its employees and volunteers;
• all persons who participate in developing Cumming Group’s policies; and,
• all other persons who provide goods, services or facilities on behalf of the company.

The training will be appropriate to the duties of the employees, volunteers and other persons.

Employees will be trained when changes are made to the accessibility policy. New employees will be trained upon being hired as part of their orientation.

Cumming Group will keep a record of the training it provides.

Information and Communications Standards

FeedbackCumming Group will continue to ensure that its process for receiving and responding to feedback is accessible to persons with disabilities by providing, or arranging for the provision of, accessible formats and communications supports, upon request.

Accessible Formats and Communication SupportsUpon request, Cumming Group will provide, or will arrange for the provision of accessible formats and communication supports for persons with disabilities in a timely manner that takes into account the person’s accessibility needs due to disability.

Cumming Group will consult with the person making the request in determining the suitability of an accessible format or communication support.

Cumming Group will also notify the public about the availability of accessible formats and communication supports.

Accessible Websites and Web Content

Cumming Group’s ongoing accessibility effort works towards conforming its Internet websites, including web content, and undertaking an assessment to comply with the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.1, at Level AA criteria. These guidelines will not only help to make web content accessible to users with sensory, cognitive and mobility disabilities, but ultimately to all users, regardless of ability. If you would like to request accessibility-related assistance or report any accessibility problems, please contact us using the contact information listed below.

Employment Standards

Recruitment

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

Recruitment, Assessment or Selection Process

Cumming Group 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, Cumming Group 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 ApplicantsWhen making offers of employment, Cumming Group will notify the successful applicant of its policies for accommodating employees with disabilities.

Informing Employees of Supports

Cumming Group will continue to inform its employees of its policies (and any updates to those policies) used to support employees with disabilities, including policies on the provision of job accommodations that take into account an employee’s accessibility needs due to disability. This information will be provided to new employees as soon as practicable after commencing employment.

Accessible Formats and Communication Supports for EmployeesUpon the request of an employee with a disability, Cumming Group 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 his/her job, and information that is generally available to other employees.

In determining the suitability of an accessible format or communication support, Cumming Group will consult with the employee making the request. However, the company reserves the flexibility to decide on the most appropriate accessible formats or communication supports for employees (based on the needs of the specific employee and the capacity of the company to provide the support).

Workplace Emergency Response Information

Cumming Group 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 Cumming Group is aware of the need for accommodation due to the employee’s disability. Cumming Group will provide this information as soon as practicable after becoming aware of the need for accommodation.

Where the employee requires assistance, Cumming Group will, with the consent of the employee, provide the workplace emergency response information to the person designated by Cumming Group to provide assistance to the employee.

Cumming Group will review the individualized workplace emergency response information when the employee moves to a different location in the organization, when the employee’s overall accommodations needs or when plans are reviewed.

Documented Individual Accommodation Plans

Cumming Group will develop and maintain a written process for the development of documented individual accommodation plans for employees with disabilities.

If requested, information regarding accessible formats and communications supports provided will also be included in individual accommodation plans.

In addition, the plans will include individualized workplace emergency response information (where required) and will identify any other accommodation that is to be provided.

Return to Work Process

Cumming Group will maintain a documented return to work process for its employees who have been absent from work due to a disability and who require disability-related accommodations in order to return to work.

The return-to-work process will outline the steps Cumming Group will take to facilitate the return to work and will include documented individual accommodation plans as part of the process.

This return-to-work process will not replace or override any other return to work process created by or under any other statute.

Performance Management, Career Development and Advancement & RedeploymentCumming Group will take into account the accessibility needs of employees with disabilities, as well as individual accommodation plans, when conducting performance management, providing career development and advancement to employees, or when redeploying employees.

Questions about this policy

This policy has been developed to break down barriers and increase accessibility for persons with disabilities in the areas of information and communications and employment. If anyone has a question about the policy, or if the purpose of a policy is not understood, an explanation will be provided by:

The Cumming Management Group, Inc.
Human Resources[hr@cumming-group.com]
[951-252-8555]