Introduction

Reinhart Foods Ltd. (“Reinhart”) has a practice of protecting the privacy and security of customer, supplier and employee records. We are committed to meeting our obligations under Canadian data privacy laws, including the Personal Information Protection and Electronic Documents Act, S.C. 2000, c. 5, and applicable provincial laws. We adhere to the privacy principles set out below, which govern the way we collect, use, store and disclose personal information that is obtained in the course of development, sales, promotion and distribution of our products or in the course of employment.

“Personal information”, as used in this policy, means any information about an identifiable person, including employee records, and customer and supplier information, but does not include the name, title, business address, business telephone number, business fax number or business e-mail address of an employee of an organization.

Policy for the Protection of Personal Information:

We will collect, use, store and disclose personal information in accordance with the following privacy principles:

1. Accountability. The overall responsibility for ensuring our compliance with data privacy laws and this privacy policy rests with the Director, Human Resources, who is our Privacy Officer, although other individuals within Reinhart have responsibility for the day-to-day collection and processing of personal information and may be delegated to act on behalf of the Privacy Officer.

   We are responsible for personal information in our possession or custody, including personal information that we may transfer to third parties for processing. We will require our service providers to agree to contractual requirements that are consistent with our privacy and security policies. We will require that our service providers are prohibited from using personal information, except for the specific purpose for which we supply it to them.

2. Identifying Purposes. Either before or at the time of collection, we will identify the purposes for which we plan to use the personal information. Depending upon the way in which the personal information is collected, this can be done orally or in writing. Reinhart may use the information we collect for the following purposes:

   (a)    to ship products or provide services to our customers;

   (b)    to provide customers access to Reinhart products;

   (c)    to respond to customer inquiries about accounts and other services;

   (d)    to understand our customers and prospective customers’ needs and to offer products and services to meet those needs;

   (e)    to conduct credit checks on customers or prospective customers; and

   (f)    to meet legal requirements.

   Unless required by law, we will not use personal information for a new purpose without the knowledge and consent of the individual to whom the information relates.

3. Consent. Personal information will only be collected, used or disclosed with the consent of the individual, except in certain circumstances permitted or required by law. The way in which we seek consent may vary depending upon the sensitivity of the information. We will obtain consent in all cases where the personal information involved is considered sensitive, such as income or health information.

   Typically, we will seek consent for the use or disclosure of personal information at the time of collection. However, additional consent will be sought after the personal information has been collected if it is required for a new purpose.

   In certain circumstances, obtaining consent would be inappropriate. The federal Personal Information Protection and Electronic Documents Act and provincial privacy laws provide for exceptions where it is impossible or impractical to obtain consent.

4. Limiting Collection.  We will collect personal information by fair and lawful means and will limit the amount and type of personal information we collect to that which is necessary for our identified purposes.

   Personal information will be retained for 3 years and will be stored in a locked storage facility on Reinhart premises. Only the Human Resources department and Privacy Officer have access to the locked storage facility in which the personal information records are being retained. After 3 years, the personal information will be destroyed in a secure manner and in accordance with applicable privacy legislation.

   Upon an employee’s resignation, retirement or termination of employment, the employee’s personal information will be destroyed in a secure manner and in accordance with applicable privacy legislation.

5. Limiting Use, Disclosure and Retention.  We will not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Reinhart may sell and/or trade customer lists to selected third-party companies and organizations that meet our requirement for security and confidentiality. These lists will not include any personal information and do not include credit or transaction information. Subject to any applicable business, legal, or regulatory requirements, we will ensure that the data is destroyed in a secure manner, erased or made anonymous.
6. Accuracy. We will use our best efforts to ensure that personal information that is used on an ongoing basis and information that is used to make a decision about an individual is as accurate, complete and up-to-date as necessary for the purpose for which it is to be used.
7. Safeguards. We will protect personal information with safeguards appropriate to the level of sensitivity of the information. Our safeguards protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, regardless of the format in which the information is held. We will exercise care in the disposal or destruction of personal information to prevent unauthorized parties from gaining access to the information. Our methods of protection include physical measures (e.g., locked file storage and restricted access to offices), organizational measures (e.g., security clearances and limiting access on a need-to-know basis) and technological measures (e.g., the use of passwords and encryption). We also require our outside service providers to provide a comparable level of protection to personal information that we may supply to them.
8. Individual Access. Upon written request, we will inform an individual of the existence, use and disclose of his/her personal information and give him/her reasonable access to that information. We may deny access for legally permissible reasons, such as situations where the information is prohibitively costly to provide, if it contains references to other individuals, or where it cannot be disclosed for legal, security or commercial proprietary reasons. We will advise the individual of any reason for denying an access request.
   When an individual successfully demonstrates the inaccuracy or incompleteness of personal information held by us, we will correct or update the information as required.
9. Individual Access. We will investigate all written complaints and respond to all written inquiries. If we find a complaint to be justified, we will take appropriate measures to resolve it.

To file an opt-out request, request access to your information, report incorrect information or file a complaint, please write to:

Director, Human Resources
Reinhart Foods Ltd.
7449 Hwy 26,
Stayner, ON
LOM 1S0

2. Accessibility Policy

CUSTOMER SERVICE STANDARDS FOR ACCESSIBILITY POLICY

Reinhart Foods is committed to excellence in serving all people in a way that allows them to include their dignity and independence. All goods and services provided by Reinhart Foods shall follow the principles of dignity, independence, integration, and equal opportunity. This policy is intended to meet the requirements of Accessibility Standards for Customer Service, Ontario Regulation 429/07 under the Accessibility for Ontarians with Disabilities Act, 2005, and applies to the provision of goods and services to the public or other third parties, not to the goods themselves.

SCOPE:

1. This policy applies to the provision of goods and services at premises owned and operated by Reinhart Foods.
2. This policy applies to employees, volunteers, agents and/or contractors who deal with the public or other third parties that act on behalf of Reinhart Foods, including when the provision of goods and services occurs off the premises of Reinhart Foods such as in: delivery services, vendors, drivers, and third-party agencies.
3. The section of this policy that addresses the use of service animals only applies to the provision of goods and services that take place at premises owned and operated by Reinhart Foods.
4. This policy shall also apply to all persons who participate in the development of the Reinhart Foods policies, practices and procedures governing the provision of goods and services to members of the public or third parties.
5. Reinhart Foods will strive to ensure that its policies, practices, and procedures are consistent with the following core principles as outlined in the AODA:
   • Dignity – ensure persons with disabilities are provided with services in a manner that will allow them to maintain self-respect and the respect of others.
   • Independence – ensure persons with disabilities have the right to work on their own and are able to do things in their own way.
   • Integration – ensure persons with disabilities fully benefit from the same goods and services, in the same place and in the same or similar manner as others. This may require alternative formats and flexible approaches. It means complete and full participation.
   • Equal Opportunity – ensure persons with disabilities have the same chances, options, benefits, and results as others.

DEFINITIONS:

Disability – the term disability as defined by the Accessibility for Ontarians with Disabilities Act, 2005, and the Ontario Human Rights Code, refers to:

• 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 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.

Service Animal – as reflected in Ontario Regulation 429/07, an animal is a service animal for a person with a disability if:

• it is readily apparent that the animal is used by the person for reasons relating to his or her disability; or
• if the person provides a letter from a physician or nurse confirming that the person requires the animal for reasons relating to the disability.

Support Person – as reflected in Ontario Regulation 429/07, a support person means, in relation to a person with a disability, another person who accompanies him or her in order to help with communication, mobility, personal care, medical needs or access to goods and services.

GENERAL PRINCIPLES:

Assistive Devices

Persons with disabilities may use their own assistive devices as required when accessing goods or services provided by Reinhart Foods.

In cases where the assistive device presents a safety concern or where accessibility might be an issue, other reasonable measures will be used to ensure the access of goods and services. Where an individual requires assistive devices for the purposes of mobility, and are not able to access our front lobby, we will accommodate their needs by asking that they contact us in advance in order to make arrangements to meet their service needs in an alternate.

Service Animals

We welcome people with disabilities and their service animals. Due to strict food manufacturing guidelines, service animals are allowed in public spaces.

If a service animal is excluded by law, Reinhart Foods will offer alternative methods to enable the person with a disability to access goods and services, when possible (for example, securing the animal in a safe location and offering the guidance of an employee).

If it is not readily apparent that the animal is being used for reasons relating to his or her disability, Reinhart Foods may request verification.

Verification may include:

• a letter from a physician or nurse confirming that the person requires the animal for reasons related to the disability;
• a valid identification card signed by the Attorney General of Canada; or,
• a certificate of training from a recognized guide dog or service animal training school.

The customer that is accompanied by a service animal is responsible for maintaining care and control of the animal at all times.

If a health and safety concern presents itself, for example, an individual, has a severe allergy to the service animal, Reinhart Foods will make all reasonable efforts to meet the needs of all individuals

Support Persons

If a customer with a disability is accompanied by a support person, Reinhart Foods will ensure that both persons are allowed to enter the premises together and that the customer is not prevented from having access to the support person.

In situations where confidential information might be discussed, consent will be obtained from the customer, prior to any conversation where confidential information might be discussed.

Notice of Disruptions in Service

Service disruptions may occur due to reasons that may or may not be within the control or knowledge of Reinhart Foods. In the event of any temporary disruption to facilities or services that customer’s with disabilities rely on to access or use Reinhart Foods goods or services, reasonable efforts will be made to provide advance notice. In some circumstances, advance notice may not be possible.

In the event that a notification needs to be posted the following information will be included unless it is not readily available or known:

• goods or services that are disrupted or unavailable
• reason for the disruption
• anticipated duration
• a description of alternative services or options

When disruptions occur Reinhart Foods will provide notice by:

• posting notices in conspicuous places including at the point of disruption, at the main entrance and the nearest accessible entrance to the service disruption
• verbally notifying customers when they are making an appointment; or
• Any other method that may be reasonable under the circumstances.

Recruitment and Employment

Reinhart Foods is committed to fair and accessible employment practices. We will take the required steps to notify public and staff, when requested; we will accommodate people with disability during the recruitment and assessment processes and when people are hired.

• When placing job ads and/or notices (internal/external) Reinhart Foods will notify its employees, public and external employment agencies of the availability of accommodations for
  applicants with disabilities.
• Once an applicant has been chosen to participate further in the selection process, they be notified that accommodations are available upon request, pertaining to the materials and
  methods used in the selection process and job assessment.
• As part of the job offer letter and the new employee orientation process, Reinhart Foods will notify the successful applicant of its policies for accommodating employees with disabilities. Offer letter and orientation check list will be reviewed and revised based on required accommodation.
• If an employee with a disability makes a request for arrangement of accessible formats and communication supports, Reinhart Foods will consult with the employee and provide what is needed for the employee to perform his/her job function.
• Provided assistance is required, and Reinhart Foods is made aware of the need for accommodation by an employee, an individualized emergency response plan will be developed
  for an employee with a disability. Reinhart Foods Emergency Evacuation Policy will be reviewed to include individual emergency response plans. Existing and new employees will be
  asked if they require assistance due to a disability, in the event there is an emergency.
• Reinhart Foods will maintain a written process for the development of documented individual accommodation plans for employees with disabilities. If requested by the employee and necessary, the plan will include accessible formats, communication supports and emergency response information and assistance.
• Reinhart Foods 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. Current processes will be reviewed and updated.
• Reinhart Foods will take into account the accessibility needs of employees with disabilities when conducting performance management, providing career development and advancement opportunities to employees. Current processes will be reviewed and updated.

Training for Staff

Training will be provided to:

1. all employees, volunteers, agents and/or contractors who deal with the public or other third parties that act on behalf of Reinhart Foods.
2. those who are involved in the development and approval of customer service policies, practices and procedures.
3. Reinhart Foods policies, procedures and practices pertaining to providing accessible customer service to customers with disabilities.
4. Training may include:
   • How to interact and communicate with people with various types of disabilities.
   • Guidance on how to interact with people with disabilities who:
     • use assistive devices;
     • require the assistance of a service animal
     • require the use of a support person
     • how to assist a person with a disability who is having difficulty accessing our services
   • Instructions on what to do if a person with a disability is having difficulty accessing your services.

Design of Public Spaces

Reinhart Foods will ensure that we meet the Accessibility Standards for the Design of Public Spaces when building or making major modifications to public spaces as identified in the regulation.

Communication and Feedback Process

Reinhart Foods is committed to providing their employees, customers, and clients with public available information in an accessible way upon request. Included in this information we will also provide employees, customers and clients with disabilities with individualized emergency response information when necessary.

Upon request, Reinhart Foods 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.

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

Reinhart Foods shall provide customers with the opportunity to provide feedback on the service provided to customers with disabilities (TR-F-046). Information about the feedback process will be readily available to all customers and notice of the process will be made available by phone, fax, email, or website.

Customers can submit feedback to:

Sharon Syrota, Director, Human Resources

1 705 428 2422 X133

7449 Highway 26, PO Box 30,
Stayner ON L0M 1S0

ssyrota@reinhartfoods.com

Fax: 1 705 428 2335
www.reinhartfoods.com

Customers that provide formal feedback will receive acknowledgement of their feedback, along with any resulting actions based on concerns or complaints that were submitted.

For more information on this accessibility plan it can be viewed on our website at www.reinhartfoods.com or by contacting Human Resources at 705-428-2422.

If you have any questions or concerns about this policy or its related procedures, please contact the above. This policy and its related procedures will be reviewed and updated once at least every 5 years.