Accessibility Plan

General

This Accessibility Plan describes the steps CommandLink, LLC (“CommandLink”) is taking to identify, remove and prevent barriers to accessibility in respect of the following seven areas:

• employment;
• the built environment;
• information and communication technologies (ICT);
• communication, other than ICT;
• the procurement of goods, services and facilities;
• the design and delivery of programs and services; and

In order to request this Accessibility Plan in an alternate format, to request the description of CommandLink feedback process in an alternate format or to provide feedback to CommandLink, please contact our Tax & Regulatory Manager by any of the following means:

• Mail: PO Box 4085, Portsmouth, NH 03802-4085
• Telephone: 1-855-270-5465
• Email: [email protected]
• Online form on our website: https://www.commandlink.com/accessibility/

Employment

CommandLink is committed to creating an inclusive and accessible workplace for all employees. Our hiring processes are conducted online and are designed to be accessible, with accommodations provided upon request during recruitment, selection, and onboarding. Job postings are made available in accessible formats, and all internal employee systems conform to accessibility best practices, including compatibility with screen readers.

Although CommandLink currently has no employees or physical operations in Canada, our employment policies and practices apply globally and adhere to principles of universal accessibility. Any future hiring of Canadian-based employees will be conducted in compliance with the Accessible Canada Act and relevant human rights legislation.

The Built Environment

CommandLink does not maintain any physical offices, retail locations, or built environments in Canada. As such, there are no customer-facing or employee-occupied facilities in Canada subject to the built environment accessibility requirements.

Nevertheless, CommandLink designs any physical locations it does operate (outside of Canada) to follow all applicable building codes and legislated accessibility standards. Should CommandLink establish a physical presence in Canada in the future, accessibility standards under the ACA and applicable provincial regulations would be implemented while doing so.

Information and Communication Technologies (ICT)

CommandLink maintains a strong commitment to digital accessibility. Our public-facing website (https://www.commandlink.com) is designed to be accessible in accordance with WCAG 2.1 Level AA guidelines. We routinely assess the accessibility of digital tools used by both our customers and employees.

Our customer portals, online billing systems, and managed IT platforms are built using accessible frameworks to ensure usability for persons using assistive technologies. As part of our commitment to continuous improvement, CommandLink regularly evaluates and updates ICT systems to prevent and eliminate accessibility barriers.

Communication, other than ICT

CommandLink ensures that all communications—beyond digital channels—are inclusive and respectful of accessibility needs. We provide telephone-based support through accessible call centres and accommodate alternative formats of communication upon request, including print, large font, and accessible PDF formats.

Support staff are trained to assist customers with accessibility requests, and interpreter services such as TTY and relay services are available when necessary. We make reasonable efforts to communicate in plain language and to respond to communication preferences expressed by individuals with disabilities.

The Procurement of Goods, Services and Facilities

While CommandLink does not operate Canadian facilities, our procurement policies reflect our commitment to accessibility. Vendors and service providers are evaluated in part on their ability to deliver accessible solutions, and we consider accessibility features when procuring customer- facing and internal platforms.

In future procurement involving Canadian customers or vendors, CommandLink will incorporate relevant ACA accessibility requirements into its vendor assessment and contract processes.

The Design and Delivery of Programs and Services

• (a) conditions imposed under section 24 or 1 of the Telecommunications Act to which the regulated entity is subject that relate to the identification and removal of barriers and the prevention of new barriers
  • Website accessibility is provided in accordance with the requirements set out in Broadcasting and Telecom Regulatory Policy CRTC 2009-430. It is WCAG 1 Level AA compliant and available in accessible formats upon request.
    
    
  • Call centre accessibility is provided in accordance with the requirements set out in Broadcasting and Telecom Regulatory Policy CRTC 2009-430. This includes training staff in accessibility support and offering real-time assistance for individuals with disabilities, including access through TTY or IP Relay.
    
    
  • Alternative formats are provided in accordance with requirements set out in the Wireless Code and the Internet Code or Telecom Regulatory CRTC 2017-11, and Telecom Decision CRTC 2002-13.

• (b) the provisions of any regulations made under the Telecommunications Act that relate to the identification and removal of barriers and the prevention of new barriers and that apply to the regulated entity
  
  
  • CommandLink monitors developments in Canadian regulatory accessibility obligations. While CommandLink is not subject to all provisions due to the absence of a physical presence in Canada, our service offerings to Canadian customers are designed to meet the accessibility standards applicable to telecom resellers, including those outlined in the ACA and related CRTC policies. Our services are managed remotely and delivered via cloud and telecommunications infrastructure that is accessible and compliant with industry best practices.
    
    
• (c) CommandLink’s Accessibility Policy outlines our principles for inclusive design, and we are committed to embedding accessibility into the planning, testing, and deployment of all customer service offerings. Accessibility testing is incorporated into product development cycles. Feedback mechanisms are actively monitored to identify potential barriers, and enhancements are made based on input from customers and accessibility experts.

Transportation

CommandLink does not own or operate any transportation services or fleets in Canada. Accordingly, transportation-related accessibility requirements under the ACA do not apply.

Should the company ever provide transportation services, it will ensure compliance with all applicable ACA transportation standards, with specific focus on accessibility for persons with disabilities.

Consultations

For the preparation of this Accessibility Plan, CommandLink reviewed internal feedback mechanisms (including its existing, publicly available Accessibility Feedback Process), consulted subject matter experts on accessibility standards, and reviewed best practices under the ACA and comparable telecommunications plans. We also considered guidance from our Canadian legal advisors and analyzed feedback received from individuals with disabilities via support channels.

Principles

In preparing this Accessibility Plan, CommandLink has been guided by the following principles outlined in s. 6 of the Accessible Canada Act:

• (a) all persons must be treated with dignity regardless of their disabilities;
• (b) all persons must have the same opportunity to make for themselves the lives that they are able and wish to have regardless of their disabilities;
• (c) all persons must have barrier-free access to full and equal participation in society, regardless of their disabilities;
• (d) all persons must have meaningful options and be free to make their own choices, with support if they desire, regardless of their disabilities;
• (e) laws, policies, programs, services and structures must take into account the disabilities of persons, the different ways that persons interact with their environments and the multiple and intersecting forms of marginalization and discrimination faced by persons;
• (f) persons with disabilities must be involved in the development and design of laws, policies, programs, services and structures; and
• (g) the development and revision of accessibility standards and the making of regulations must be done with the objective of achieving the highest level of accessibility for persons with disabilities.