Accessible Customer Service Plan and Policy Providing Goods and Services to People with Disabilities  

Our Mission

The mission of ICCS Americas is to provide accessible and equitable services to all individuals, including people with disabilities. ICCS Americas is committed to removing barriers where reasonably possible and providing services in a manner that respects the dignity, independence and equal participation of people with disabilities.

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This Policy applies to employees, contractors, vendors and other individuals who provide services or interact with customers and other third parties on behalf of ICCS Americas.

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Questions regarding this Policy or accessibility at ICCS Americas may be directed to the appropriate Compliance or Management representative.

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Definitions

“Assistive device” means a device or technology used by a person with a disability to assist with communication, mobility, access to information or other activities.

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“Disability” means a physical or mental impairment that substantially limits one or more major life activities, as defined under applicable U.S. law.

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“Service animal” means a dog that is individually trained to perform tasks for the benefit of an individual with a disability, as recognized under the Americans with Disabilities Act (ADA).

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“Support person” means an individual who assists a person with a disability with communication, mobility, personal care or access to services.

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“Service disruption” means a temporary interruption or unavailability of an ICCS Americas facility, service, communication channel or other resource that may affect accessibility.

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Privacy & Confidentiality

ICCS Americas respects the privacy of information relating to an individual's disability or accommodation needs. Information provided for accessibility or accommodation purposes will be handled confidentially and used only as reasonably necessary to provide appropriate services or accommodations and to meet applicable legal requirements.

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Policy Statement

ICCS Americas is committed to providing equitable access to its services for people with disabilities. We strive to provide services in a manner that respects dignity, independence and equal opportunity.

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ICCS Americas will make reasonable efforts to communicate with individuals in ways that accommodate their needs and will work with individuals to identify reasonable alternatives when a barrier affects access to our services.

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This policy is intended to support ICCS Americas' commitment to accessibility and compliance with applicable U.S. federal, state and local accessibility requirements.

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Assistive Devices

ICCS Americas supports the use of personal assistive devices by people with disabilities when accessing our services.

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Where an individual experiences difficulty accessing a service because of a disability or assistive device, ICCS Americas will make reasonable efforts to identify an appropriate alternative or accommodation.

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Communication

ICCS Americas will communicate with people with disabilities in a manner that takes their individual needs into account. Where reasonably possible, we will work with individuals to identify effective methods of communication that allow them to access our services.

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Service Animals

ICCS Americas welcomes individuals with disabilities who are accompanied by service animals in areas where the public or other third parties are permitted, subject to applicable law.

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Employees and representatives who interact with customers will be expected to understand appropriate practices for interacting with individuals accompanied by service animals.

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Where a service animal is excluded by law from a particular area, ICCS Americas will make reasonable efforts to provide an alternative means of accessing the applicable service.

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Support Persons

ICCS Americas welcomes individuals with disabilities who require the assistance of a support person when accessing our services.

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A person with a disability will generally be permitted to access applicable services with their support person, subject to applicable law and legitimate safety or confidentiality requirements.

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Notice of Temporary Disruption

If a service, facility or communication method becomes temporarily unavailable and the disruption affects accessibility, ICCS Americas will make reasonable efforts to provide notice and, where possible, identify an alternative method of accessing the affected service.

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Training

ICCS Americas provides employees and other applicable personnel with training and guidance relating to accessibility, disability awareness and appropriate interactions with people with disabilities.

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Training may include:

• An overview of applicable accessibility and nondiscrimination requirements

• How to communicate and interact appropriately with people with different disabilities

• How to interact with individuals who use assistive devices, service animals or support persons

• How to identify and respond to accessibility barriers

• ICCS Americas' accessibility policies, practices and procedures

• The employee's responsibilities when providing accessible services or accommodations

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Training will be provided as part of applicable onboarding and when significant changes are made to relevant policies or procedures.

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Employment

ICCS Americas is committed to equal employment opportunity and reasonable accommodation for qualified individuals with disabilities in accordance with applicable U.S. law.

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Where appropriate, ICCS Americas will provide reasonable accommodations during recruitment, assessment and employment, unless doing so would create an undue hardship.

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Employees who require an accommodation may contact the appropriate ICCS Americas Management or Human Resources representative to discuss their needs and available accommodation options.

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Feedback Process

ICCS Americas welcomes feedback regarding the accessibility of its services. Individuals may provide feedback through the contact methods made available by ICCS Americas, including mail, email or telephone.

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Feedback will be reviewed and addressed in accordance with ICCS Americas' applicable complaint and accessibility procedures. Individuals may request an accessible format or communication method when providing feedback.

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Modifications to This or Other Policies

ICCS Americas is committed to continually improving accessibility. Policies and procedures may be reviewed and updated as necessary to reflect changes in applicable law, technology, business practices and identified accessibility needs.

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Accessibility Plan

ICCS Americas will continue to identify and address accessibility barriers within its services, facilities and communications where reasonably practicable.

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Publicly available information will be provided in an accessible format or through an accessible communication method upon request, where required by applicable law.

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ICCS Americas will consider accessibility when developing or updating customer-facing services, digital content and business processes.

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Transportation

ICCS Americas does not provide conventional or specialized commercial transportation services to passengers. Transportation accessibility requirements applicable to transportation providers therefore do not generally apply to ICCS Americas' services.

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Facilities and Public Spaces

Where ICCS Americas constructs, modifies or redevelops facilities or areas accessible to customers or other members of the public, accessibility will be considered in accordance with applicable federal, state and local requirements.

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ICCS Americas will make reasonable efforts to identify and address accessibility barriers within its facilities and service areas and will maintain accessible features where required by applicable law.