The following policy has been established by Starlight Investments Capital LP (“Starlight Capital”) to govern the provision of services with Regulation 191/11, “Integrated Accessibility Standards” (“Regulation”) under the Accessibility for Ontarians with Disabilities Act, 2005.

These standards have been developed to ensure accessibility for persons with disabilities in the areas of information, communications and employment.

Starlight Capital is governed by this policy as well as by the Accessibility Standards for Customer Service Policy and the Accessibility for Ontarians with Disabilities Act, 2005 in meeting the accessibility needs of persons with disabilities.

Commitment

Starlight Capital 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 in a timely manner and will do so by preventing and removing barriers to accessibility and meeting accessibility requirements under the Accessibility for Ontarians with Disabilities Act.

This policy will be implemented in accordance with the timeframes established by the Regulation.

Accessibility plan

Starlight Capital will develop, maintain and document an Accessibility Plan outlining the company’s strategy for preventing and removing barriers from its workplace, and for meeting its requirements under the Regulation.

The Accessibility Plan will be reviewed and updated at least once every five years and will be posted on the company’s website. Upon request, Starlight Capital will provide a copy of the Accessibility Plan in an accessible format.

Procuring or acquiring goods, services or facilities

Starlight Capital will have regard for accessibility criteria and features when it procures or acquires goods, services or facilities, except where it is not practicable to do so.

Training employees and volunteers

Starlight Capital will ensure that training is provided on the requirements of the accessibility standards referred to in the Regulation and continue to provide training on the Human Rights Code as it pertains to persons with disabilities, to:

• all its employees and volunteers,
• all persons who participate in developing Starlight Capital'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.

Staff will be trained when changes are made to the accessibility policy. New staff will be trained in a timely manner.

Starlight Capital will keep a record of the training it provides.

Feedback

Starlight Capital 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 supports

Upon request, Starlight Capital 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.

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

Starlight Capital will also notify the public about the availability of accessible formats and communication supports.

Accessible websites and web content

Starlight Capital will ensure that its Internet and Intranet websites, including web content, conform to the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0, at Level AA except where this is impracticable.

Recruitment

Starlight Capital 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

Starlight Capital 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, Starlight Capital 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, Starlight Capital will notify the successful applicant of its policies for accommodating employees with disabilities.

Informing employees of supports
Starlight Capital 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 in a timely manner after commencing employment.

Accessible formats and communication supports for employees

Upon the request of an employee with a disability, Starlight Capital 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, Starlight Capital will consult with the employee making the request.

Workplace emergency response information

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

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

Starlight Capital will review the individualized workplace emergency response information when the employee moves to a different location in the organization, and the employee’s overall accommodations needs or plans may need to be altered.

Documented individual accommodation plans

Starlight Capital will maintain a written process for the development of documented individual accommodation plans for employees with disabilities.

If requested, information regarding accessible formats and communications support that has been 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

Starlight Capital maintains a documented return to work process for its employees who have been absent from work due to a disability and require disability-related accommodations in order to return to work.

The return-to-work process outlines the steps Starlight Capital 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 (e.g., the Workplace Safety Insurance Act, 1997).

Performance management, career development, and advancement and redeployment

Starlight Capital 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 remove barriers and increase accessibility for persons with disabilities in the areas of information, communications and employment. If anyone has a question about the policy, or if the purpose of a policy is not understood, please contact Starlight Capital's Director, Advisor and Investor Experience as follows:

Mail:

Starlight Investments Capital LP 
3280 Bloor Street West, Suite 1400
Toronto, Ontario, Canada
M8X 2X3

Attention: Director, Advisor and Investor Experience

Email: info@starlightcapital.ca

Telephone: 416 234 8444 / 1 866 782 7536