This Accessibility for Ontarians with Disabilities Act Policy and Multi-Year Plan (this “Plan”) outlines the policies, practices, and actions that Cardtronics Canada Holdings Inc. and its Canadian affiliates (collectively, “NCR Atleos” or the “Company”) has or will put in place to improve accessibility for people with disabilities in the Province of Ontario and will be implemented in accordance with the time frames set out in the Accessibility for Ontarians with Disabilities Act, 2005 and its regulations (collectively, the “AODA”).

Part I: General

1. Statement of Commitment

NCR Atleos 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 people with disabilities in a timely manner and will do so by preventing and removing barriers to accessibility in the Company’s operations and services and meeting applicable accessibility requirements under the AODA. 

2. Self-Service Kiosks

The Company has regard to the accessibility for persons with disabilities when designing, procuring, or acquiring self-service kiosks in Ontario (“Kiosks”).

We offer some accessible forms of communication on select Kiosks, which can include:

• audio jacks with optional voice guidance available;
• screens with accessible text size and colour contrast;
• a tactilely discernible input device that allows all onscreen content to be controlled by those with limited reach or vision; and
• braille stickers.

Actions to be taken:

To facilitate the ease of use by persons with disabilities, the Company will endeavour, when designing or acquiring new Kiosks, to equip (or provide the option to equip) such Kiosks with:

• audio jacks with optional voice guidance available;
• screens with accessible text size and colour contrast;
• a tactilely discernible input device that allows all onscreen content to be controlled by those with limited reach or vision;
• braille stickers; and
• The Company will continue to review and take reasonable steps to prevent and remove other accessibility barriers that are identified with respect to Kiosks that are newly designed or acquired by the Company.

3. Training

The Company has provided training, or required training to be provided, to all:

1. Company employees and volunteers in Ontario,
2. Persons involved in developing the Company’s policies, and

• Other persons who provide goods, services, or facilities on behalf of the Company in Ontario or to persons located in Ontario, 

on the requirements of the accessibility standards set out in the AODA and on the Ontario Human Rights Code as it pertains to persons with disabilities. 

Training is provided in a way that best suits the duties of the applicable person, as soon as practicable after employees commence their duties through the on-boarding process, and on an ongoing basis when changes are made to this Plan, or the policies referenced in this Plan. A record of this training is kept, including the dates on which training is provided and the individuals to whom it is provided.

 The training will include: 

• An introduction to the AODA, including its purposes, and the requirements of the customer service standards;
• An overview of the Human Rights Code as it pertains to the AODA, and the standards referred to in the Integrated Accessibility Standards Regulations (“IASR”) that impact on the delivery of services; and
• Instructions about the following matters:

• How to interact and communicate with people with various types of disabilities;
• How to interact with persons with disabilities who use an assistive device or require the assistance of a service animal or a support person;
• How to use equipment or devices available on the Company’s premises or otherwise provided by the Company that may help with the provision of goods, services, or facilities to a person with a disability; and
• What to do if a person with a particular type of disability is having difficulty accessing the Company’s goods, services, or facilities.

All new and existing employees are also trained on NCR Atleos’ Code of Conduct, Harassment and Violence in the Workplace (which includes topics such as preventing harassment in the workplace including discrimination as it pertains to persons with disabilities), and Whistleblower policies and programs.

Actions to be taken:

• The Company will ensure that updated training is provided on an ongoing basis when changes are made to this Plan, the policies referenced in this Plan or the AODA.

Part II: Information and Communication Standards

1. Feedback Processes

The Company has established processes for receiving and responding to feedback. Such processes are available in accessible formats and communication supports are available upon request, including, via telephone, mail, or email.

The Company has an established AODA Accessibility webpage as part of its feedback process, which provides contact information and an online form to provide feedback regarding the customer experience.

 Actions to be taken:

• The Company will continue to review its feedback processes, taking into consideration any feedback received, to prevent or remove any barriers to accessibility.

2. Accessible Formats and Communication Supports

The Company is committed to meeting the communication needs of persons with disabilities. The Company will ensure that all publicly available information controlled by the Company is provided in an accessible format and with communication support upon request. The Company will also consult with the person making the request to determine the suitability of an accessible format or communication support for such person. The Company will provide the accessible format in a timely manner that considers the applicable person’s accessibility needs and, at a cost no more than the regular cost charged to other persons.

When communicating with a person with a disability in relation to the Company’s goods or facilities, the Company will do so in a way that considers the person’s disability.

3. Emergency Information and Procedures

The Company is committed to providing publicly available emergency information, if any, in an accessible format or with appropriate communication supports as soon as practicable upon request. 

4. Websites

Except where meeting the requirement is not practicable as permitted by the AODA, all websites controlled by the Company, and web content on those websites (other than live captions and pre-recorded audio descriptions), if any, conform with the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0, Level AA. 

Actions to be taken:

• An Accessibility webpage will be added to the Company’s website.

Part III: Employment Standards

1. Workplace Emergency Response Procedure

Where the Company is aware that an employee has a disability and that there is a need for accommodation due to such disability, individualized workplace emergency response information is provided to the employee as soon as practicable if such information is necessary given the nature of the employee’s disability. Reviews of any individualized workplace emergency response information will be conducted as soon as practicable when an employee moves to a different location in the Company, when the overall accommodations needs or plans are reviewed, and when the Company reviews its general emergency response policies.

2. Accessibility in Employment

The Company is committed to fair and accessible employment practices that attract and retain employees with disabilities. This includes providing accessibility across all stages of the employment cycle.

Actions taken:

• The Company notifies the public, potential candidates, and employees that, when requested, it will accommodate people with disabilities during the recruitment and assessment processes in accordance with the AODA.
• The Company has informed employees of its policies used to support employees with disabilities and will, whenever there is a change to existing policies on the provision of job accommodations, provide such changed policies and information to all employees.
• The Company has developed and put in place a process for developing individual accommodation plans for employees with disabilities.
• The Company has developed and put in place a return-to-work process for employees who have been absent from work due to a disability and require disability-related accommodations in order to return to work.
• The Company ensures the accessibility needs of employees with disabilities are considered if using performance management, career development and advancement, or redeployment processes.

Actions to be taken: 

• The Company will, when making offers of employment, notify the successful applicant of its policies for accommodating employees with disabilities.
• Where requested by an employee with a disability, the Company will consult with the employee to provide or arrange for the provision of accessible formats and communications supports with respect to information that is needed in order to perform the employee’s job duties, and information that is generally available to employees in the workplace. The Company will also consult with the person making the request to determine the suitability of an accessible format or communication support for such person.
• The Company will also review and take reasonable steps to prevent and remove other accessibility barriers that are identified.

Part IV: Design of Public Spaces Standards

The Company will meet the Design of Public Spaces Standards of the AODA when it is newly constructing or making significant alterations to public spaces in Ontario, including:

• Exterior paths of travel and related elements, like sidewalks, ramps, and stairs,
• Accessible off-street parking; and
• Service-related elements, such as service counters and waiting areas.

The Company has put procedures in place to prevent service disruptions to accessible parts of these public spaces and to deal with temporary disruptions when accessible elements of these public spaces required under the AODA are not in working order.

Part V: Customer Service Standards

The Company is committed to providing its goods, services and facilities in a manner that respects the dignity and independence of people with disabilities. The Company is committed to giving people with disabilities equal opportunity to that provided to persons without disabilities to obtain, use or benefit from the Company’s good, services, and facilities, and the Company is committed to the integrated provision (other than where an alternative measure is necessary) of such goods, services, and facilities among persons with disabilities and persons without disabilities.

1. Assistive Device(s)

Persons with disabilities may use their own assistive devices as required when accessing the Company’s goods, services, and facilities. Should the Company provide any assistive devices, employees will be trained on their proper use.

In cases where the assistive device may present a health or safety concern or may not be permitted for other reasons, other reasonable measures may be used to ensure access to such goods, services, and facilities. 

2. Support Persons

Any person with a disability who is accompanied by a support person will be allowed to have the support person present while on Company premises unless it becomes a health and safety risk (such as restricted access or areas). Where such support person’s presence is a health and safety risk other provisions will be made to ensure that the person with a disability receives the support otherwise provided by the support person. In some cases, it may be necessary to seek the consent of the person with the disability prior to discussing confidential information in front of the support person.

The Company may require a person with a disability to be accompanied by a support person when on the Company’s premises, but only if, after consulting with the person with a disability and considering the available evidence, the Company determines that a support person is necessary to protect the health or safety of the person with a disability or the health or safety of others on the premises, and there is no other reasonable way to protect the health or safety of the person with a disability and the health or safety of others on the premises. 

3. Use of Service Animals 

When a person with a disability is accompanied by a service animal, the service animal shall be permitted to enter the Company’s premises and remain with the person with a disability unless the service animal is excluded by law from the premises. If a service animal is excluded by law from the premises, the service animal shall remain at a mutually- agreed upon location and the Company will ensure that the person with a disability is able to obtain, use or benefit from its goods, services, or facilities.

When the Company cannot easily identify that an animal is a service animal, the Company may ask for documentation from a regulated health professional that confirms the person needs the service animal for reasons related to their disability. 

4. Notice of Disruption

The Company will provide customers with notice in the event of a planned disruption in the facilities or services usually used by people with disabilities in Ontario. In the event of an unexpected disruption, the Company will make reasonable efforts to notify customers in Ontario of the disruption, the reason for the disruption, its anticipated duration, and instructions to secure alternative services, if possible. Notice of a disruption will be posted at public entrances of our affected Ontario facilities.

Actions to be taken:

• The Company will continue to prepare, review, and file the Company’s Accessibility Report as required by the AODA.
• The Company will continue to review and take reasonable steps to prevent and remove customer service accessibility barriers as identified.

Part VI: For More Information

For more information on this Plan, please contact Human Resources at: 

NCR Atleos
3269 American Drive
Mississauga, Ontario L4V 1V4
Attention: AODA Coordinator
AODA.Requests@ncratleos.com
Website: "

Standard and accessible formats of this Plan are free upon request.