Accessibility at Index: Policy and Multi-Year Plan

At Index Exchange (“Index”), we are committed to building a diverse, equitable, barrier-free environment and inclusive community where everyone feels a true sense of belonging, both in the workplace and in our business engagements. We believe that a diverse and inclusive company sparks innovation and fuels success. We are dedicated to continuous learning, open dialogue, and actions that promote fairness and respect for all, and to developing a community and culture that embraces individuals from all identities and backgrounds.

As part of our commitment to supporting diversity and inclusion, we welcome and encourage individuals with Disabilities, as defined in the Accessibility for Ontarians with Disabilities Act, to work and conduct business with Index. We are proud to share our Accessibility Policy (“Policy”) and Multi-Year Accessibility Plan (“Plan”), which work together with our internal policies and processes to ensure Index maintains and sustains a welcoming and accessible environment for those with Disabilities, in line with the Accessibility for Ontarians with Disabilities Act (“AODA”).

You can learn more about our evolving diversity, equity, inclusion, and belonging (“DEI&B”) programs here.

This Policy and Plan applies to:

• Current or prospective employees of Index working in or applying to a position located in Ontario;
• Clients, partners, or other individuals who conduct business with Index, receive services from Index, may access our information or supply goods or services to Index (collectively, “Partners”); and
• Members of the public who engage with Index’s website.

This Policy outlines the standards that Index implements to accommodate individuals with Disabilities.

SECTION I: Applicant and Employee Accessibility

Index is committed to supporting Index job applicants and employees with Disabilities in a manner which respects the dignity and independence of each individual and allows them to fully participate in the employee lifecycle, from recruitment to offboarding.

Applicant Notification

All open roles advertised on the Index website include a statement outlining Index’s commitment to providing reasonable accommodation (i.e., modifications or adjustments made to the job application process, work environment or job performance methods) to ensure that applicants with Disabilities can participate in the application process, unless such required accommodation would impose an undue hardship on Index.

When an applicant is selected to participate in the assessment process, Index will notify the applicant, in writing, that accommodation is available upon request at any time during the recruitment cycle. If an applicant requests accommodation, Index will consult with the applicant to determine their specific accommodation needs. Index will make reasonable efforts to accommodate applicants to ensure they can participate equitably in the recruitment lifecycle.

When an offer of employment is made, Index will notify the successful applicant of its policies for accommodating employees with Disabilities and inform the employee that they can connect with their manager or assigned Human Resource Business Partner (“HRBP”) at any time during their employment to request an accommodation.

Internal Policies

Index has established internal policies related to accommodation and accessibility, which are detailed in the Employee Handbook. These policies ensure that employees’ rights to accommodation for Disabilities and other protected grounds are upheld and provide guidance on how employees can request such accommodation.

Employees are informed of these policies during onboarding and through ongoing annual training. Additionally, all employees are required to acknowledge and sign the policies. By requiring employees to acknowledge these policies, Index can ensure that employees are aware of the process for seeking Disability-related support or accommodation and available recourses if these supports are denied without valid reason.

Accommodation Requests for Employees

Index is committed to providing reasonable accommodation to Employees with Disabilities. Employees with Disabilities are encouraged to request accommodation from their manager and/or HRBP to help support them in their job duties.

When a request for reasonable accommodation is received, the People Team will develop an individualized accommodation plan in close collaboration with the requesting employee. Employees are actively engaged in assessing their needs and suggesting accommodation that would benefit them. The process also includes regular follow-ups to monitor the plan’s effectiveness and adjust as needed. Confidentiality is maintained throughout the process to protect the employee’s privacy.

Performance Reviews

Growth within Index is performance-driven, which is the key focus for managers as they assess and evaluate growth opportunities and potential. Managers and HRBPs, together with the broader People Team, consider the accessibility needs of employees during the annual performance review cycle.

Evacuation and Emergency Procedures

Index maintains a confidential list of employees who require specialized emergency evacuation procedures. This information is shared with the Workplace Team and the designated fire wardens and first aiders in applicable offices to effectively support the affected employees in case of the need for emergency evacuation.

SECTION II: Partner Accessibility

Index is dedicated to providing Partners with Disabilities with an equal opportunity to access and use Index services or products, provide goods or services to Index, or otherwise engage in business with Index.

Personal Supports

Partners with Disabilities may use their personal assistive devices and/or bring their support person when accessing Index services or facilities.

Although pets are not allowed on premises, Partners with Disabilities are welcome to bring their service animals with them.

In cases where a service animal or device presents a significant and unavoidable health or safety concern, or violates another law or regulation, Index will make reasonable efforts to accommodate the Partner in another manner that meets their needs.

If Partners have any questions or need to notify Index of any support or accommodation they may require, they are encouraged to contact accessibility@indexexchange.com. This will help ensure that Index can make the necessary arrangements to provide appropriate assistance and effectively meet the Partner’s needs.

Communications

Index strives to release public communications in an accessible format and makes best efforts to communicate with Partners with Disabilities in ways that consider their individual needs. If a Partner requests information in an alternate format, Index will consult with the person making the request to determine the appropriate support and will make best efforts to accommodate with the appropriate support.

Notice of Temporary Disruption

In the event of a planned or unexpected disruption to Index services or facilities (e.g., elevator maintenance), Index will make reasonable efforts to notify affected Partners on premises. Index will share any relevant information on the reason for the disruption, the expected duration of the disruption and alternate available services, as applicable.

SECTION III: Accessibility Training

All applicable employees, including those who participate in the development of Index’s policies, and all other people who provide goods, services, and facilities on behalf of Index are required to take a course outlining accessibility requirement under the law. The course has two modules covering the topics outlined below:

• Employee’s rights and responsibilities under the Ontario Human Rights Commission (“OHRC”) and accessibility legislations (i.e., AODA) and their responsibilities for providing accessible service and supports to Partners; and
• Information on the standards for providing accessible services or doing business with people with Disabilities.

Mandatory training is provided as soon as practicable within the onboarding process and on an annual basis thereafter. Completion of training is tracked and recorded. These records consist of the dates and names of Employee who completed the training.

In addition, Index delivers specialized training to employees involved in managing employment processes or developing information and communication materials, as applicable.

This Plan outlines actions Index has achieved or will implement to promote accessibility and remove barriers for individuals with Disabilities. Our goal is to ensure individuals of all abilities can meaningfully participate and engage in the workplace, with our business, and with our product offerings.

SECTION I: Customer Service

Index is committed to designing our products and services in an accessible format wherever possible.

Our achievements, ongoing initiatives, and goals to improve the accessibility of our customer support and products are outlined below.

• Our customers use the User Interface (“UI”), to engage with our product and transact on the exchange. Our goal is to consistently improve the user experience and accessibility of the UI for our customers, as outlined below:
  • Since 2018, all new pages have been designed with our established design system components and pattern guidelines, which include strict requirements for text accessibility and standards around how we design forms, tables, and navigation to ensure ease of use and accessibility for users.
  • We are consistently updating our design system components and guidelines to ensure they meet the latest standards.
  • We are actively working to update legacy pages released prior to 2018, to ensure they meet the latest accessibility standards.
  • Since 2024, any new page released on the UI meets the WCAG 2.1 standard visually. We will continue to apply this standard to all future releases.
• We are committed to providing customers with an accessible experience on the External Knowledge Base (“EKB”), the system we use to share detailed information with our customers. Some of the ways we incorporate accessibility into the EKB include:
  • The content management system that hosts our EKB has several built-in accessibility features, including keyboard navigation, alternative text, and accessible search functions. Additionally, all individual pages can be accessed with screen readers.
  • We are currently auditing the EKB to ensure all tables have captions and colors meet sufficient contrast standards according to WCAG 2.1 AA level.
• Index collects feedback on our products in the following ways:
  • On a quarterly basis, we send out a survey to customers provide feedback on the user experience with the UI.
  • Customers can submit any feedback on the EKB, including any accessibility concerns, via a feedback link we maintain at the bottom of each page.
• Index is committed to responding to user feedback on the design or accessibility of the UI and EKB and will make improvements accordingly.
• Our account representatives will make reasonable efforts to provide information and account support to our customers in an accessible format, if requested.

SECTION II: Information and Communications

Index strives to share all internal and external information in a format that is accessible to members of the public, including all Partners and anyone who engages with our website.

External Communications

Our achievements and ongoing initiatives to improve the accessibility of our public website are outlined below. Index Exchange is responsible for:

• Index launched new brand guidelines to all employees which outline instructions to ensure all external materials meet color contrast standards, as noted in the WCAG 2.1 standard. Employees are encouraged to use the color combinations, fonts, and sizes in the guide for all external communications.
• Index completed an audit of our public-facing website. The audit confirmed that our website was in full compliance with WCAG 2.1 Level AA, and that many of our website modules met Level AAA compliance.
• On an ongoing basis, we partner with an external web development company to ensure all new website releases are compliant with the WCAG 2.1 accessibility standards.

Internal Communications

We aim to provide communication materials for employees in an accessible format and are actively working to improve accessibility as outlined below.

• Index’s internal project tracking software complies with the WCAG 2.0 AA standard.By the end of 2025, we are slated to upgrade our internal project tracking software to a newer version which includes improved accessibility features for users.
• Our intranet content is available in alternate color contrasts and can be downloaded as a PDF as needed, to support employees with accessibility needs.
• The Learning and Development team is working to ensure all our in-house created training content has closed captions available for users. This project is expected to be completed by the end of 2025.

SECTION III: Employment

Index is an equal opportunity employer. We are committed to providing reasonable accommodation to applicants and existing employees with Disabilities. Below, we outline our achievements, ongoing initiatives, and upcoming projects to improve accessibility for applicants and employees with Disabilities throughout the employee lifecycle.

Recruitment

To make the hiring process more inclusive, we are developing the following initiatives:

• Offering onboarding and hiring materials in alternate formats to employees with Disabilities; and
• Providing inclusive recruitment training to our talent team.

Current Employees

Once onboarded, we provide continuous support to minimize barriers for employees with Disabilities, to ensure they can thrive in the workplace.

We are proud of the recent achievements we have made to improve accessibility for employees. These initiatives include:

• In 2022, we launched a new employee resource group, Diversability, to promote accessibility in the workplace. The group has shared awareness and education around mental health, physical Disabilities, and neurodiversity.Membership to Diversability is open to all employees with Disabilities and allies and is supported by an executive lead and our DE&I Core Group.
• In 2023, we revamped our Health Day and Short-Term Disability Policy to allow employees to use their sick leave for a wider range of health needs, including medical appointments and other preventative healthcare. We further updated the policy to provide continuous benefits between short-term and long-term disability leave.
• In 2023, we refreshed our employer-sponsored benefits plan to provide coverage for mental health care.

Index Exchange implements the following processes, policies and resources to support employees with Disabilities:

• We have a formal process to support employees returning to work after short-term disability leave, documented in our Health Day and Short-Term Disability Leave Policy. While support is unique to each individual employee, some accommodation can include implementing a gradual return to work or modifying an employee’s work schedule.

Index, in partnership with our Diversability group will continue to review our programs and policies to improve diversity, promote inclusion and ensure our standards give all employees a feeling of belonging, regardless of any disability they may have.

SECTION IV: Training

In addition to our mandatory training, Index offers training to employees to further support our goals of diversity and inclusion and ensure employees are aware of their responsibilities under applicable legislation. Our additional training initiatives include:

• Index has an enterprise subscription to LinkedIn Learning and encourages employees to take optional LinkedIn Learning courses to promote awareness of diversity in accessibility in the workplace.
• Index provides job-specific training to employees in applicable departments, as needed.
• Index offers optional mental health first aider training. As of 2024, Index has trained over twenty (20) employees globally on best practices for listening to those with mental health concerns without judgements and referring them to the appropriate external supports or services when needed.

SECTION V: Building Accessibility

Index is committed to meeting accessible building code requirements, as outlined below:

• Index incorporates applicable building code accessibility standards into our building designs.
• Our office buildings have documented emergency evacuation plans, which outline the building standards for evacuating individuals with Disabilities.
• Our employee management software securely and confidentially manages individualized employee’s evacuation plans. Employees have the flexibility to update this at any time, and Index ensures relevant information is shared with fire wardens and first aid representatives in each office.
• Index uses internal communication channels to update employees on building service disruptions and remind employees of ongoing emergency evacuation procedures.
• In case of temporary disruptions or maintenance to building services, Index will make reasonable efforts to notify affected individuals appropriately.

Our Commitment to Privacy

Index understands that information related to an individual’s Disability or accessibility needs are sensitive. Index is committed to protecting individual’s privacy and maintaining the confidentiality of information related to an accommodation request.

Personal information is only disclosed to those with a demonstrated “need-to-know” to support or provide an accommodation request, or as required to take corrective action for violation of this Policy, or as otherwise required by law.

Individuals are encouraged to review the Privacy Center for more information on our privacy practices.

Reprisal Policy

Index has a zero-tolerance policy for reprisals and strictly prohibits reprisals or other penalties against an individual who requests accommodation in good faith.

Policy Review and Modification

This Policy and Plan will be reviewed, at a minimum, once every five (5) years, in accordance with applicable legislation. Modification to these documents will be made in consultation with employees with Disabilities, wherever possible.

Index reserves the right to change, modify, or delete the provisions of this Policy. The date at the top of this Policy reflects the most recent changes made. If any changes to this Policy are significant, Index may take additional measures to inform its employees and Partners as required by applicable law.

Statutory Compliance

This Policy and Plan are intended to meet or exceed the requirements outlined in the AODA and the OHRC. In case of a discrepancy between this Policy or Plan, and applicable law, the applicable law will apply.

Disability: as defined in the Accessibility for Ontarians with Disabilities Act, 2005:

• any degree of physical disability, infirmity, malformation or disfigurement that is caused by bodily injury, birth defect or illness and, without limiting the generality of the foregoing, includes diabetes mellitus, epilepsy, a brain injury, any degree of paralysis, amputation, lack of physical co-ordination, blindness or visual impediment, deafness or hearing impediment, muteness or speech impediment, or physical reliance on a guide dog or other animal or on a wheelchair or other remedial appliance or device;
• a condition of mental impairment or a developmental disability;
• a learning disability, or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language;
• a mental disorder; or
• an injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997.

Index welcomes feedback on this Policy, Plan or overall accessibility practices at Index. To share feedback or request this Policy or Plan in an alternate format, please contact accessibility@indexexchange.com. Please note this email is monitored for accessibility-related feedback or requests only.

Index will ensure that the feedback process is accessible to people with Disabilities by providing or arranging for accessible formats and communication support, if requested.