Policies


  • Conflict Minerals Policy

     1. PURPOSE

    This policy provides a framework through which RTDS Technologies Inc. (“RTDS”) shall comply with Section 1502 of the Dodd Frank Wall Street Reform and Consumer Protection Act pertaining to Conflict Minerals.

    2. SCOPE

    On August 22nd, 2012, the U.S. Securities and Exchange Commission (“SEC”) published regulations implementing Section 1502 of the Dodd Frank Wall Street Reform and Consumer Protection Act (“Act”) governing Conflict Minerals. The Act requires companies to perform due diligence on the source and chain of custody of Conflict Minerals contained in their products. RTDS is not a SEC registrant and therefore not required to file a Conflict Minerals Report in accordance with Rule 13p-1 under the Securities Exchange Act of 1934 (“Rule 13p-1”). However, RTDS does recognize the need to comply to the Rule 13p-1 standards where applicable in relation to reporting requirements of its customer base who may be subject to such Rules, and have therefore taken steps to become compliant where appropriate and applicable.

    3. DECLARATION

    1. RTDS strives to have a Conflict Free supply chain, and is committed to sourcing products and materials from non-conflict sources;
    2. RTDS expects that its suppliers have due diligence processes in place to identify the source of the Conflict Minerals contained in their products, and that those sources do not support conflict and violations of human rights;
    3. To further the benefits of Section 1502 and promote its intended purpose, RTDS will work with suppliers with underdeveloped processes, providing information and guidance in an attempt to increase supply chain transparency throughout the world and into the DRC and surrounding region.

    RTDS undertakes to provide all suppliers identified under the SEC regulations with a Reasonable Country of Origin survey (“RCOI”). This survey must be completed by those suppliers to ensure continued eligibility to do business with RTDS. By signing and submitting the survey, suppliers certify that they have procedures in place to demonstrate that materials and products are sourced in accordance with RTDS standards, and attest to the reliability of the survey responses. Based on the survey results, RTDS may require additional information from those same suppliers in order to determine whether or not a supplier’s products or materials are indeed “Conflict Free”.

    RTDS is dedicated to working with its suppliers to help establish traceability of Conflict Minerals and assure that our products and materials are responsibly sourced. However, suppliers who are not responsive to RTDS’s requests for information via the RCOI survey process may be disqualified from doing business with RTDS. At a minimum, RTDS will look to establish new sources for products and materials where the origin of Conflict Minerals in those products cannot be ascertained.

  • Accessible Customer Service Policy

     1. STATEMENT OF PURPOSE

    This policy provides the framework through which RTDS Technologies Inc. (“RTDS”) shall comply with the Accessible Standard for Customer Service under The Accessibility for Manitobans Act (“AMA”).
    RTDS strives to provide exceptional customer service and recognizes the importance of providing an accessible, barrier-free environment for people of all abilities who seek to obtain, use or benefit from our goods and services.
    RTDS is committed to meeting the requirements of the AMA and its Customer Service Standard. We will make reasonable efforts to ensure that our policies, procedures and practices, including those outlined in this accessible customer service policy, are consistent with the principles of dignity, independence, integration and equality opportunity for people with disabilities.

    2. SCOPE

    This policy applies to all Employees, consultants, officers and directors of RTDS who interact with customers, service recipients, suppliers or vendors in Manitoba. As such, each person has a duty to review, understand and comply with the requirements outlined in this policy.
    It is important to note that nothing in the AMA or its regulations diminishes the obligations of a person or organization with respect to persons with disabilities under any other enactment, and, in particular, under The Human Rights Code.

    3. DEFINITIONS

    Accessibility – As it relates to this policy, accessibility means people of all abilities have the opportunity to participate fully in everyday life. Accessible customer service is provided when all persons who are reasonably expected to seek to obtain, use or benefit from a good or service have the same opportunity to obtain, use or benefit from the good or service.

    Assistive Device – A technical aid, communication device or other instrument or equipment used to maintain or improve people’s functional abilities in daily living. Some examples include wheelchair, screen reader, listening device, magnifying glass or cane.

    Barrier – Anything that prevents a person with a disability from fully participating in everyday life, including physical barriers, architectural barriers, informational barriers, attitudinal barriers, technological barriers and systemic barriers. As it relates to this policy, accessibility barriers limit or prevent people from being able to get information, service and goods or to enter a space or be part of an activity.

    Service Animal – An animal that has been trained to provide assistance to a person with a disability that relates to that person’s disability.

    Support Person – In relation to a person who is disabled by a barrier, a person who accompanies the person to support the person obtaining, using or benefiting from a good or service provided by an organization, or assist the person in addressing his or her communication, mobility, personal care or medical needs.

    The Human Rights Code – Provincial human rights law that protects specific individuals and groups in Manitoba from discrimination, including persons with physical or mental disabilities. Under The Code, failure to provide reasonable accommodation to a special need that is based on a protected group or characteristic is considered discrimination. The Code has special status over all other laws of the Province of Manitoba.

    4. PROCEDURES

    Communication
    RTDS will make reasonable efforts to ensure that, when communicating with a person who self-identifies as being disabled by a barrier, the communication is done in a manner that takes into account the barrier. This may include offering alternative methods of communication or measures to meet their communication needs.

    Assistive Devices
    Persons disabled by barriers may use their own assistive devices as required when accessing our goods, services or facilities. In cases where the assistive device presents a safety concern or where accessibility might be an issue, other reasonable measures will be considered to ensure the access of goods and services.

    Support Persons
    Support persons are welcomed on RTDS premises. Persons with disabilities and their support person will not be prevented from having access to each other while on our premises. All customer/client confidentiality requirements and practices will also apply to support persons. We will let the public know in advance if support persons have to pay admission or service fees for training courses or conferences.

    Service Animals
    Persons with disabilities are permitted to be accompanied by their service animal and keep that animal with them in areas/premises that are open to the public. The person requiring the service animal is responsible for the care and control of the service animal at all times. A service animal may not be permitted when any one of the following conditions exists:

    • The service animal is disruptive and the animal’s owner is not able to effectively control it;
    • The service animal’s presence, behavior, or actions pose an unreasonable or direct threat to property or the health or safety of others; and
    • When other laws specifically prohibit service animals.

    In the event that a service animal’s access is not permitted, RTDS will make reasonable efforts to accommodate the individual and will suggest other alternatives to provide assistance.

    Accessibility Features and Temporary Disruption of Services

    To ensure barrier-free access to our goods, services or facilities, RTDS will maintain our accessibility features on our premises so they can be used as intended, for example:

    • Keeping aisles, reception areas, meeting/training rooms, and accessible restrooms clear of clutter
    • Ensuring our entranceway is clear of snow and ice.
    • Allowing space for mobility devices and removing any potential tripping hazards.

    In the event of a planned or unexpected disruption of services or facilities affecting persons disabled by barriers, we will post notices as soon as possible. A clearly posted notice will include information about the reason for the disruption, its anticipated length of time, and a description of alternative facilities or services, if available. Notices may be displayed on our premises or by other means that are reasonable in the circumstances.

    Feedback
    RTDS welcomes feedback on how we provide accessible customer service. Feedback will help us identify barriers and respond to concerns. Feedback can be provided in the following ways:

    • By mail or In-person: RTDS Technologies Inc. 100-150 Innovation Drive, Winnipeg, MB, R3T 2E1
    • By Telephone: 204-989-9700
    • By E-mail: feedback@rtds.com

    All feedback is directed to the Accessibility Committee. If the feedback requires a follow-up or action, we will respond as soon as possible and in a way that meets the specific communication needs.

    Training and Documentation Requirements
    RTDS will provide accessible customer service training to all employees, consultants, officers and directors of RTDS who interact with customers, service recipients, suppliers or vendors in Manitoba. New employees will be trained as part of their orientation upon employment. Continuous, on-going training will be provided as necessary. Training will include:

    • An overview of The Human Rights Code (Manitoba), The Accessibility for Manitobans Act, and the Customer Service Standard.
    • How to interact and communicate with people who face barriers to accessing goods and services, including people who use assistive devices, are assisted by a support person and/or are assisted by a service animal.
    • Our organizational policies, practices and measures, including updates or changes.

    We will keep written record of our accessibility and training policies including a summary of our training material and detailed records of the training provided. Through our company website, we will let the public know that our written policies are available upon request.