1.1 This policy establishes the Organization's commitment to full compliance with the Americans with Disabilities Act of 1990 (ADA), as amended by the ADA Amendments Act of 2008 (ADAAA), codified at 42 U.S.C. sections 12101 through 12213, and its implementing regulations at 29 C.F.R. Part 1630. The Organization is committed to providing reasonable accommodations to qualified individuals with disabilities to enable them to perform the essential functions of their positions, to participate in the application process, and to enjoy equal access to the benefits and privileges of employment. This policy establishes the procedures for requesting, evaluating, and providing reasonable accommodations through an interactive process that respects the dignity of the individual, protects confidential medical information, and ensures that accommodation decisions are made consistently, promptly, and in good faith.

1.2 This policy applies to all aspects of the employment relationship, including but not limited to job application procedures, recruitment and hiring, job assignment and classification, training and professional development, promotion and advancement, compensation and benefits, social and recreational programs, discipline, leave administration, and separation. The policy covers all employees, regardless of employment type, grade, or location, and all applicants for employment at the Organization. The Organization recognises that the ADA applies to employers with 15 or more employees, and the Organization meets this threshold. Where state or local disability discrimination laws provide broader protections than the federal ADA, including broader definitions of disability, additional protected conditions, or more expansive accommodation requirements, the Organization shall comply with the more protective provisions. This policy shall be read in conjunction with the Organization's Equal Employment Opportunity Policy and any applicable leave or return-to-work policies.

1.3 The Organization shall designate an ADA Coordinator within the HR department who shall oversee the implementation and day-to-day administration of this policy. The ADA Coordinator shall serve as the primary point of contact for all accommodation requests from employees and applicants, facilitate and document the interactive process for each request, consult with managers, medical professionals, and Legal Counsel as needed to identify effective accommodations, maintain confidential records of all accommodation requests, evaluations, and outcomes, provide training and guidance to managers and supervisors on their obligations under this policy and the ADA, and monitor compliance with accommodation agreements and follow up on their effectiveness. The ADA Coordinator's contact information shall be prominently displayed in the Organization's employee handbook, on the intranet, and in all job postings. The ADA Coordinator shall report to the Head of Human Resources on accommodation activity, trends, and any systemic issues on a quarterly basis.

2.1 Under the ADA as amended by the ADAAA, a disability is defined as a physical or mental impairment that substantially limits one or more major life activities, a record or history of such an impairment, or being regarded as having such an impairment. Major life activities include, but are not limited to, caring for oneself, performing manual tasks, seeing, hearing, eating, sleeping, walking, standing, lifting, bending, speaking, breathing, learning, reading, concentrating, thinking, communicating, working, and the operation of major bodily functions including the immune system, normal cell growth, digestive, bowel, bladder, neurological, brain, respiratory, circulatory, endocrine, and reproductive functions. The ADAAA directs that the definition of disability shall be construed broadly and shall not require extensive analysis. Mitigating measures, other than ordinary eyeglasses or contact lenses, shall not be considered in determining whether an impairment substantially limits a major life activity. Impairments that are episodic or in remission qualify as disabilities if they would substantially limit a major life activity when active.

2.2 A qualified individual with a disability is a person who satisfies the requisite skill, experience, education, and other job-related requirements of the employment position held or desired and who can perform the essential functions of that position with or without reasonable accommodation. Essential functions are the fundamental job duties of the position that the individual holds or seeks, as distinguished from marginal or incidental functions. Evidence of whether a particular function is essential includes, but is not limited to, the employer's judgment as to which functions are essential, written job descriptions prepared before advertising or interviewing, the amount of time spent performing the function, the consequences of not requiring the incumbent to perform the function, the work experience of past incumbents in the position, and the current work experience of incumbents in similar positions. The Organization shall maintain current, accurate job descriptions for all positions that clearly distinguish essential functions from marginal functions, and these descriptions shall be reviewed at least annually by the HR department in consultation with the hiring or supervising manager.

2.3 A reasonable accommodation is any modification or adjustment to the job application process, the work environment, or the manner or circumstances under which the position held or desired is customarily performed that enables a qualified individual with a disability to perform the essential functions of the position or to enjoy equal benefits and privileges of employment. Examples of reasonable accommodations include, but are not limited to, making existing facilities physically accessible, restructuring a job by removing or redistributing marginal functions, providing part-time or modified work schedules, acquiring or modifying equipment or devices, adjusting or modifying examinations, training materials, or policies, providing qualified readers or interpreters, permitting the use of accrued paid leave or providing additional unpaid leave for treatment, reassigning a qualified individual to a vacant position for which they are qualified, and permitting telework or remote work arrangements. The Organization is not required to provide an accommodation that would impose an undue hardship on the operation of the business, eliminate an essential function of the position, create a new position, or promote or advance the individual with a disability.

3.1 When an employee or applicant for employment requests an accommodation, or when a manager or the Organization otherwise becomes aware that an accommodation may be needed due to a known disability, the ADA Coordinator shall promptly initiate a good-faith interactive process with the individual. A request for accommodation does not need to use specific language such as ADA or reasonable accommodation; any communication indicating that the individual needs an adjustment or change at work due to a medical condition is sufficient to trigger the Organization's obligation to engage in the interactive process. The interactive process shall be initiated within 5 business days of the request or the Organization's awareness of the potential need. The process involves a collaborative dialogue between the ADA Coordinator, the individual with the disability, and, as appropriate, the individual's manager, medical professionals, and external consultants, to identify the precise limitations resulting from the disability, the essential functions of the position that are affected, the range of potential reasonable accommodations, and the effectiveness and feasibility of each potential accommodation.

3.2 Where the disability or the need for accommodation is not obvious or already known to the Organization, the ADA Coordinator may request that the individual provide medical documentation from a qualified healthcare provider to support the accommodation request. The request for documentation shall be limited to information sufficient to establish that the individual has a disability as defined by the ADA, to describe the functional limitations that result from the disability and that are relevant to the individual's ability to perform the essential functions of the position or access employment benefits, and to support the need for the specific accommodation requested or to identify alternative effective accommodations. The Organization shall not request the individual's complete medical records or any medical information that is not directly relevant to the accommodation request. All medical information received shall be treated as confidential, maintained in a separate file apart from the individual's personnel records, and disclosed only to individuals with a legitimate need to know, such as the ADA Coordinator, the individual's manager to the extent necessary to implement the accommodation, and safety personnel where the disability may require emergency treatment.

3.3 The ADA Coordinator shall maintain detailed, contemporaneous documentation of each step of the interactive process for every accommodation request. Documentation shall include the date and nature of the initial request or trigger, the name and position of the individual, the nature of the disability and functional limitations as communicated by the individual or supported by medical documentation, the essential functions of the position that are affected, all accommodations discussed and considered during the interactive process, an assessment of the effectiveness and feasibility of each potential accommodation, the accommodation selected and the rationale for the selection, or if no accommodation was provided, a detailed explanation of why each considered accommodation was determined to be ineffective or would impose an undue hardship, the implementation plan and timeline for the selected accommodation, and confirmation that the individual has been informed of the decision and any appeal rights. Documentation shall be maintained in a confidential accommodation file for a minimum of 5 years from the date of the request or the individual's separation from employment, whichever is later.

4.1 The Organization is not required to provide a reasonable accommodation that would impose an undue hardship on the operation of the business. Under the ADA, undue hardship is defined as an action requiring significant difficulty or expense when considered in light of the nature and cost of the accommodation needed, the overall financial resources of the facility or facilities involved, the number of persons employed at the facility, the effect on expenses and resources, the overall financial resources, size, number of employees, and type and location of facilities of the Organization as a whole, the type of operation of the Organization, including the composition, structure, and functions of the workforce, and the impact of the accommodation upon the operation of the facility, including the impact on the ability of other employees to perform their duties and the impact on the Organization's ability to conduct business. An undue hardship determination must be made on a case-by-case basis and cannot be based on generalised assumptions about a particular disability or type of accommodation. Where the ADA Coordinator determines that a requested accommodation would impose an undue hardship, the Organization shall explore alternative accommodations that would be effective without causing undue hardship before denying the request entirely.

4.2 The ADA Coordinator shall communicate the outcome of the accommodation evaluation to the individual in writing within 15 business days of completing the interactive process, or within a shorter period where the urgency of the situation requires it. Where the Organization grants the accommodation, the written communication shall describe the specific accommodation to be provided, the implementation timeline, any conditions or limitations, and the process for requesting modifications if the accommodation proves ineffective. Where the Organization determines that the requested accommodation cannot be provided due to undue hardship or because it would not effectively address the individual's limitations, the written communication shall explain the basis for the determination, describe any alternative accommodations that were offered, and inform the individual of their right to request reconsideration, to propose alternative accommodations, and to file a complaint through the Organization's internal grievance procedure or with the Equal Employment Opportunity Commission. The Organization shall not retaliate against any individual for requesting an accommodation, participating in the interactive process, or filing a complaint.

4.3 Approved accommodations shall be implemented as promptly as practicable, with a target implementation date of no more than 15 business days after the accommodation decision is communicated, unless the accommodation requires procurement of equipment or modifications that necessitate a longer lead time, in which case an interim accommodation shall be provided where feasible. The ADA Coordinator shall follow up with the individual and their manager within 30 calendar days of implementation to assess the effectiveness of the accommodation and to identify any adjustments that may be needed. Thereafter, the accommodation shall be reviewed at least annually as part of the individual's performance management cycle, or more frequently if requested by the individual, the manager, or the ADA Coordinator. Either the individual or the manager may request a reassessment of the accommodation at any time if the individual's condition changes, the essential functions of the position change, or the accommodation proves to be ineffective or unsustainable. Any reassessment shall follow the same interactive process procedures described in this policy.

5.1 Any employee or applicant who believes that they have been denied a reasonable accommodation, subjected to disability-based discrimination, or treated adversely in connection with an accommodation request may file a complaint with the ADA Coordinator, the HR department, or through the Organization's confidential reporting mechanism, including any anonymous hotline or online reporting portal maintained by the Organization. Complaints shall be acknowledged within 3 business days and investigated promptly and thoroughly by the HR department, with support from Legal Counsel where the complaint involves allegations of legal non-compliance or raises complex legal issues. The investigation shall include interviews with the complainant, relevant managers, and any witnesses, a review of the accommodation file and all related documentation, and an assessment of whether the Organization's interactive process obligations were met. The HR department shall communicate the findings and any corrective actions to the complainant in writing within 30 calendar days of the complaint, or within such longer period as the complexity of the investigation requires, with periodic status updates provided to the complainant.

5.2 The Organization strictly prohibits retaliation in any form, including adverse employment actions, harassment, intimidation, threats, coercion, or interference, against any individual who in good faith requests a reasonable accommodation, participates in or cooperates with the interactive process, files or supports a complaint of disability discrimination, provides information in connection with an investigation, or exercises any right or privilege protected by the ADA. Retaliation shall be treated as a separate, independently actionable violation of this policy, regardless of the outcome of the underlying accommodation request or discrimination complaint. All managers and supervisors shall be trained to recognise and avoid retaliatory conduct and to immediately report any suspected retaliation to the HR department. Substantiated retaliation shall result in disciplinary action against the offending individual, up to and including termination of employment.

5.3 This policy shall be reviewed comprehensively at least once every 12 months by the policy owner, in consultation with Legal Counsel, the ADA Coordinator, and the benefits administration team, to ensure continued compliance with the ADA, the ADAAA, EEOC regulations and enforcement guidance, and all applicable state and local disability discrimination and accommodation laws. An interim review shall be triggered by new EEOC guidance, regulations, or enforcement initiatives affecting reasonable accommodation practices, significant court decisions interpreting ADA accommodation obligations, internal audit findings or complaint trends that reveal systemic gaps in accommodation processes, or changes to the Organization's workforce structure, job descriptions, or workplace configuration that affect accommodation practices. All amendments shall be approved by the Head of Human Resources and the Chief Executive Officer, communicated to all managers and employees in writing at least 14 calendar days before the effective date, and recorded in the policy version history. The HR department shall ensure that all managers and supervisors receive annual training on the current version of this policy, including their obligations to engage in the interactive process, maintain confidentiality, and refrain from retaliation.