XPO Logistics Freight Canada Inc. Accessibility Plan

1.0 General

XPO Logistics Freight Canada Inc. (“XPO”) is one of the largest providers of asset-based less-than-truckload freight transportation shipping in North America, with coverage that spans the U.S., Canada, Mexico, and the Caribbean.

XPO is committed to the realization of a Canada without barriers. As such, we have adopted this plan as part of a proactive approach to identify, remove, and prevent barriers faced by persons with disabilities when they interact with our organization, whether as employees, job applicants, or customers.

This plan responds to the Accessible Canada Regulations (SOR/2021-241) and describes what XPO is doing to identify, remove and prevent barriers in the following areas:

• Employment
• The built environment
• Information and communications technology
• Communication
• Procurement
• Programs and services
• Transportation

1.1 Feedback and contact information

The Vice President of Employee Experience and Diversity, the Senior Manager of Affirmative Action and Compliance, the Canada Human Resources Team, and the Legal Department (the “Team”) were responsible for the development and coordination of this Accessibility Plan for XPO in accordance with regulations under the Accessible Canada Act. The Team is also responsible for the feedback process and progress reporting on this Plan.

If you have questions about this Plan or wish to share accessibility feedback with us, please contact Chris Hertling, Senior Manager of Affirmative Action and Compliance, in one of the following ways:

By mail: XPO, Inc., Attn: Chris Hertling, 2800 Forrest Park Rd SE, Atlanta, GA 30354
By email: christopher.hertling@xpo.com
By phone: 1 404-985-4256

Feedback can be in the form of a complaint, a compliment, or a suggestion, and it can be sent in a way that identifies the sender or it can be shared anonymously. We will acknowledge receipt of any feedback in the same means in which it was received unless we are unable to do so because the feedback was submitted anonymously.

Copies of this plan and information about our feedback process is available in print, large print, Braille, audio format, or electronic format that is compatible with adaptive technology that assists persons with disabilities upon request. Requests for documentation in Braille or audio format will be fulfilled within 45 days. All other requests will be fulfilled within 15 days.

2.0 Employment

2.1 Where we are

XPO has identified the following potential barriers in the area of employment:

• Some job posting sites may not reach or be available to candidates with disabilities.
• Candidates may not be aware that accommodations are available during the hiring process.
• The self-identification process is currently done manually with paper forms that must be saved to PDFs and which are not centrally stored.
• Several employees misinterpreted the self-identification questions promulgated by XPO, resulting in them incorrectly identifying themselves as an individual with a disability.
• Currently, XPO only requests that employees complete our self-identification forms once a year, in preparation for XPO’s Employment Equity Report submission.
  XPO has already implemented a number of policies, programs, and practices to address these barriers, including:
  • XPO increases the chance that job postings will reach candidates who have disabilities by posting opportunities through its job posting delivery provider’s Canada diversity network. This ensures that every career opportunity at XPO shows up on websites such as Aboriginal Job Board, BCJobs.ca, Canada Youth Works, Community Outreach Canada, disabledperson.ca, and others.
  • XPO partners with organizations that support the hiring, placement and onboarding of candidates with both visible and invisible disabilities across our multiple regions.
  • XPO created a Diversity, Inclusion and Belonging Steering Committee to identify the diversity and inclusion needs of the business and develop strategies to foster a culture in which every employee feels valued and experiences a true sense of belonging.
  • XPO’s affinity group, Employees with Disabilities and Allies, continues to focus on supporting and advocating for individuals with disabilities.
  • XPO advertises and maintains an accommodations mailbox (accommodations@xpo.com) which candidates with disabilities can use to request accommodation at any point in the hiring process.
  • XPO provides guidance to managers and employees on workplace accommodations.
  • XPO’s Alterative Work Arrangement (“AWA”) Policy offers employees in non-field roles flexible work options, including the ability to work remotely part- or full-time and flexible work hours.
  • XPO provides a number of programs and services that support employees in maintaining and improving their health, such as our Employee Assistance Program (EAP).

2.2 What’s next

• By the end of 2024, XPO will revamp the annual self-identification process by:
  (i) conducting a campaign that explains visible and invisible disabilities to employees and encourages persons with disabilities to self-identify;
  (ii) having employees complete the annual self-identification forms via XPO’s HR software SucessFactors, thereby creating an easily accessible system of record for this information;
  (iii) revising the instructions and questions on the self-identification forms so that employees understand we are not asking them to confirm the definitions provided but to identify whether they fall within such definitions; and
  (iv) asking employees to self-identify during onboarding and allowing them to update their status at any point thereafter.
• In Q3 2023, XPO will add the AWA Policy to the intranet to increase awareness and utilization of the policy.
• In Q3 2023, XPO will supplement the accommodations mailbox with a separate toll-free number.
• In Q3 2023, XPO will roll out discrimination, harassment, and retaliation training to every Canadian employee that will include, inter alia, training on disability awareness and accommodations, and unconscious bias.
• In July 2024, XPO will work to increase the visibility of Employees with Disabilities and Allies and other affinity groups (collectively, “ERGs”) by reintroducing the ERGs to employees via multiple channels, including Workplace, WIN meetings, XPO Go, and the intersections TVs at the service centers.
• XPO will give employees an opportunity to provide feedback on accessibility challenges by adding questions about accessibility in the annual Employee Engagement Survey.
• XPO is considering redesigning its external and internal career sites so that they comply with Web Content Accessibility Guidelines (WCAG) 2.1 AA.
• By 2024, XPO will ensure that all of XPO’s hiring documents and systems include information about an employee’s right to accommodation in the workplace and a link to the accommodations request mailbox.
• By 2024, XPO will review our HR systems to identify systemic barriers that affect persons with disabilities and develop an action plan to remove or prevent them. This includes our: employment systems, workforce data collection, policies, and practices.

3.0 Built Environment

3.1 Where we are

As of 2023, XPO has 11 service centers in various provinces and territories in Canada, which include office space and loading dock/warehouse space. We lease all but three of our service centers and so our control over these spaces can be limited. The current state of accessibility across our network differs from location to location depending on whether the space is owned or leased, the applicable building codes, and the age of the building.

Potential Barriers: Some service centers have wheelchair ramps, motion detected lighting, adjustable height work surfaces; adjustable height work surfaces; and designated accessible parking spots; however, many do not. Currently, none of our service centers have automated/wave-to-open doors. Due to certain structural issues with the building and the foundation, the Regina service center entrance is not currently wheelchair accessible. Individuals using wheelchairs may not be able to reach alarms or security systems at certain service centers.

3.2 What’s next

XPO is in the process of making repairs to its service centers, including to the Regina service center entrance. By the end of 2023, XPO will establish a working group of stakeholders from our operations, real estate, human resources, and legal departments to identify and assess potential upgrades to increase accessibility at each service center.

In addition, XPO will ensure that any renovation plans incorporate accessibility measures, and that any newly acquired facilities and leases have accessible entrances, lighting, and signage in place.
Finally, XPO will train managers and local HR personnel to recognize and respond to employee requests for ergonomic furniture.

4.0 Information and Communication Technologies (ICT)

4.1 Where we are

XPO information and communication technology includes hardware, software, applications and websites with both external and internal facing systems for clients and employees. XPO’s current website follows some accessibility standards, such as aria labels, alternative text for images, tile text for videos, and a sans serif font, but is not fully WCAG compliant. XPO has formed an initial investigative committee comprising of XPO’s customer experience team, a product manager, a user experience engineer, and developers from the digital experience team to evaluate and implement WCAG accessibility standards.

XPO’s internal IT support center provides TTY access for hearing impaired employees. XPO has begun to implement closed captioning and text transcriptions in our employee training videos so that individuals with hearing and visual disabilities are able to access the material.

4.2 What’s next

XPO is committed to advancing digital accessibility. In furtherance of this goal, XPO will begin auditing internally and externally facing websites, portals, and applications for accessibility, including conducting useability studies for XPO’s highest trafficked URLs to verify that our websites work effectively with screen reading and other assistive technology. In 2024, XPO plans to update its main website (https://canada.xpo.com) by, e.g., considering accessibility standards, with the aim of meeting WCAG 2.0 A compliance. As part of that effort, XPO will provide close captioning on all video content on its website. By the end of 2024, XPO will offer training to the IT support center on handling requests from employees for accessible formats.

5.0 Communication Other Than ICT

5.1 Where we are

XPO currently lacks guidelines for its communications and publications to ensure that everyone can communicate, share and access information. Consequently, not all XPO communications are in written in plain language.

XPO uses Workplace to give its employee a voice, acknowledge key employee contributions, allow the leadership to communicate with the workforce, and to host XPO’s global town hall and other key employee communications. Workplace offers several accessibility features, including dark mode (which turns Workplace’s background from white to black to reduce eye strain and glare in low light situations), close captioning, access keys, and automatic alt text (which uses object recognition to create a description of a photo for people with vision impairments). In addition, all internal XPO videos that are shared on digital screens at our service centers contain subtitles.

5.2 What’s next

XPO will review its communication channels for potential improvements to accessibility and develop and implement plain language guidelines for its communications based on current best practices.

6.0 Procurement of Goods, Services, and Facilities

6.1 Where we are

XPO does not currently have a system for reviewing whether services, goods, and facilities purchased from third parties are accessible to persons with disabilities. This means that third parties may supply XPO with services, goods, or facilities that create or increase barriers for our employees or customers.

6.2 What’s next

XPO will review current procurement directives, policies, and practices to incorporate accessibility considerations, and audit the inventory of current goods and services and enquire about the accessibility practices and services of current suppliers.

7.0 Design and Delivery of Programs and Services

7.1 Where we are

Customers access XPO’s freight transportation services in a variety of ways, including online, by phone, and by email. XPO’s website does not currently comply with Web Content Accessibility Guidelines (WCAG) 2.1 AA and thus individuals with disabilities may encounter difficulties submitting a rate quote, creating a pickup request, filing a claim, and using other tools on the website. Persons with disabilities may also experience challenges when interacting with XPO by phone and email.

7.2 What’s next

By Q3 2024, we will start reviewing the channels used by clients to contact us to better identify accessibility barriers and address gaps.
8.0 Transportation
This section is not applicable to XPO.
9.0 Consultations

The experiences of people with disabilities guided the development of this plan from the outset. To have a nuanced understanding of accessibility in employment, the built environment, transportation and communications, we consulted XPO employees who self-identified as having a disability. Specifically, XPO conducted one-on-one virtual meetings with these employees to identify any barriers to accessibility and potential implementation strategies. XPO also consulted with internal stakeholders in Legal, Procurement, Technology, and Real Estate. Comments and next step recommendations received were integrated in the finalization of the Plan, where feasible.