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ARNOLD BROS. TRANSPORT LTD.

Accessibility Plan

2026 – 2028

Initial Plan — Second Reporting Cycle

Prepared in compliance with the Accessible Canada Act, S.C. 2019, c. 10

and the Accessible Canada Regulations, SOR/2021-241

Published: June 2026

739 Lagimodiere Blvd, Winnipeg, MB R2J 0T8

hr@arnoldbros.com | (204) 257-6666 ext. 353 | www.arnoldbros.com

1. Introduction

Arnold Bros. Transport Ltd. is a federally regulated employer operating in the transportation industry, headquartered in Winnipeg, Manitoba. As a federally regulated company with 100 or more employees, we are required to prepare and publish Accessibility Plans, update them every 3 years, and report on our progress towards our goals annually.

The overarching goal of the Act is the realization of a barrier-free Canada by January 1, 2040. We believe accessibility is not a one-time project, it is a commitment to proactively identifying, removing, and preventing barriers to accessibility within our organization and in the services we deliver every day.

1.1 Legislative Framework

This Accessibility Plan has been prepared in accordance with the following legislation and regulations:

• Accessible Canada Act, S.C. 2019, c. 10
• Accessible Canada Regulations, SOR/2021-241
• Canada Labour Code, R.S.C. 1985, c. L-2 (Part III — Standard Hours, Wages, Vacations and Holidays; and relevant provisions respecting accommodation)
• Canadian Human Rights Act, R.S.C. 1985, c. H-6
• Web Content Accessibility Guidelines (WCAG) 2.1, Level AA (referenced in the December 2025 amendments to the Accessible Canada Regulations regarding ICT)
• CAN/ASC – EN 301 549: National Accessibility Standard for Information and Communications Technology (ICT), as adopted by amended Accessible Canada Regulations (December 2025)

1.2 The Seven Priority Areas

Consistent with the Act, this plan addresses barriers and commitments across the seven legislated priority areas:

• Employment
• Built Environment
• Information and Communication Technologies (ICT)
• Communication (other than ICT)
• Procurement of Goods, Services and Facilities
• Design and Delivery of Programs and Services
• Transportation

1.3 Definitions

Accessibility: Refers to the needs of persons with disabilities being intentionally and thoughtfully considered when products, services and facilities are built or modified so they can be used and enjoyed by all.

Barrier: The Accessible Canada Act defines a barrier as “anything—including anything physical, architectural, technological or attitudinal, anything that is based on information or communications or anything that is the result of a policy or a practice—that hinders the full and equal participation in society of persons with an impairment, including a physical, mental, intellectual, cognitive, learning, communication or sensory impairment or a functional limitation.”

Disability: The Accessible Canada Act defines a disability as “any impairment, including a physical, mental, intellectual, cognitive, learning, communication or sensory impairment—or a functional limitation— whether permanent, temporary or episodic in nature, or evident or not, that, interaction with a barrier, hinders a person’s full and equal participation in society.”

2. Statement of Commitment

Arnold Bros. Transport Ltd. is committed to making our organization and the services we provide accessible to all. We recognize that all Canadians have the right to live and work in a barrier-free environment, and we embrace the principles set out in the Accessible Canada Act: dignity, independence, inclusion, equality of opportunity, and full and meaningful participation.

We acknowledge that disability is experienced in many forms, including physical, sensory, cognitive, mental health-related, and communication-related differences. We are committed to removing barriers in all aspects of our operations, whether they are architectural, technological, attitudinal, or systemic.

Our commitment aligns with our organizational values:

• We act in the interest of safety and wellness.
• We are respectful and inclusive.
• We are here for each other, our customers, and our suppliers.

3. Feedback Process

In accordance with sections 94 and 95 of the Accessible Canada Act and Part 2 of the Accessible Canada Regulations, Arnold Bros. Transport Ltd. has established a process for receiving and responding to feedback on accessibility and on this Accessibility Plan.

We welcome feedback from employees, clients, contractors, and members of the public. All feedback will be carefully reviewed to ensure our Accessibility Plan remains current and effective. We will respond to all feedback in a timely manner.

Feedback may be submitted by any of the following methods:

Feedback may be provided anonymously. Where a response is requested, ABT will respond within fifteen (15) business days. All feedback is handled confidentially in accordance with applicable privacy legislation.

As required by the Regulations, a description of this feedback process is published alongside this Accessibility Plan on our website.

4. Consultations

The Accessible Canada Act and Accessible Canada Regulations require that persons with disabilities be meaningfully consulted in the development of accessibility plans. Arnold Bros. Transport Ltd. undertook consultation through the following methods:

4.1 Methods of Consultation

• A company-wide survey distributed to all employees, including those who identify as having a disability
• Focus groups and one-on-one interviews with employees who have disabilities, providing a confidential space to share ideas and identify barriers
• Roundtable discussions with frontline and administrative staff on accessibility in day-to-day operations
• Engagement with external organizations that support persons with disabilities to obtain recommendations for improving accessibility in our facilities, programs, and services

4.2 External Organizations Consulted

Arnold Bros. Transport Ltd. engaged the following external organizations during the development of this plan:

• None currently.

4.3 Ongoing Consultation

We will continue to survey employees, including those with disabilities, and any working groups established under this Accessibility Plan to measure progress and ensure we realize the changes we have committed to. Our Diversity, Equity, and Inclusion (DEI) committee will play a central role in ongoing consultation and will inform each annual progress report.

5. Priority Area 1: Employment

Arnold Bros Transport Ltd. is committed to building an inclusive environment. All staff receive mandatory onboarding training, and accommodations are available during recruitment, onboarding, and throughout employment.

5.1 Barriers Identified

• Absence of a consistent, confidential process for employees to voluntarily self-identify as persons with disabilities throughout employment
• Limited awareness among managers of accommodation obligations and available resources
• No designated “Person of Contact” at each location to champion DEI and serve as a first point of access for accommodation requests
• Recruitment and onboarding materials not reviewed for accessibility

5.2 Commitments and Actions

6. Priority Area 2: Built Environment

ABT is committed to providing physical workplaces that are accessible to all employees, candidates, clients, and visitors. We recognize that physical barriers disproportionately affect persons with mobility limitations, wheelchair users, and those with other physical disabilities.

6.1 Barriers Identified

• Due to the ground shifting, the accessible ramp at the front entrance is uneven and protrudes approximately two (2) inches, creating a tripping hazard for persons with reduced mobility and a navigation obstacle for wheelchair users and those using mobility devices.
• A broader audit of physical premises has not yet been completed for all ABT locations.

6.2 Commitments and Actions

7. Priority Area 3: Information and Communication Technologies (ICT)

The December 2025 amendments to the Accessible Canada Regulations introduced new requirements for digital accessibility, referencing the national standard, CAN/ASC – EN 301 549. As a large private-sector entity, we must ensure that new public-facing web pages, mobile applications, and digital documents published on public websites are accessible. Arnold Bros. Transport Ltd. is committed to meeting these requirements ahead the December 5, 2028, deadline where possible.

7.1 Barriers Identified

• The current ABT website has not been assessed against WCAG 2.1 Level AA or CAN/ASC – EN 301 549, and likely contains barriers such as low-contrast text, small font sizes, and absence of alternative text on images.
• Internally produced digital documents (forms, policy documents, training materials) have not been formally reviewed for accessibility.
• No formal process exists for procuring accessible ICT products and services.

7.2 Commitments and Actions

8. Priority Area 4: Communication (Other Than ICT)

Effective communication in accessible formats is fundamental to ensuring all employees, clients, and members of the public can fully access information about ABT’s services, policies, and programs.

8.1 Barriers Identified

• No formal process for providing communications in alternate formats upon request (e.g., large print, plain language, audio format).
• Employee and public-facing communications have not been reviewed for plain language compliance.
• No defined process for ensuring accessibility of signage, announcements, and emergency communications at ABT facilities.

8.2 Commitments and Actions

9. Priority Area 5: Procurement of Goods, Services and Facilities

Procurement decisions have a direct impact on accessibility outcomes. ABT is committed to ensuring that goods, services, and facilities we procure do not introduce new barriers or perpetuate existing ones.

9.1 Barriers Identified

• No formal accessibility criteria have been incorporated into existing procurement policies or vendor evaluation processes.

9.2 Commitments and Actions

10. Priority Area 6: Design and Delivery of Programs and Services

At Arnold Bros. Transport Ltd. we aim to provide a consistent framework for evaluating the accessibility of our initiatives, ensuring that individuals of all abilities can fully participate and benefit from our offerings.

10.1 Barriers Identified

• Training and onboarding programs have not been consistently reviewed for accessibility.
• Accessibility has not been formally incorporated as a design requirement when developing internal programs, services, or processes.

10.2 Commitments and Actions

11. Priority Area 7: Transportation

As a federally regulated transportation entity, Arnold Bros. Transport Ltd. acknowledges that transportation operations have specific accessibility implications. While our primary operations are commercial freight transportation, we are committed to ensuring that our operational policies and the way we engage with employees and third parties in transportation contexts does not create or perpetuate barriers.

11.1 Barriers Identified

• No formal policy exists for accommodating Drivers who identify as having disabilities.
• Driver and operations training has not been reviewed for accessibility of format or content.

11.2 Commitments and Actions

12. Reporting and Accountability

As required by the Accessible Canada Act, Arnold Bros. Transport Ltd. will publish annual progress reports measuring our progress against the commitments set out in this plan. Each progress report will be published by June 1 of the relevant year and will be developed in consultation with persons with disabilities and the ABT DEI Committee.

Progress reports will describe:

• Actions taken during the reporting year to implement this Accessibility Plan
• The results and impact of those actions
• Any new barriers identified and our response
• Revisions to planned timelines or commitments, with explanation
• Feedback received and how it influenced our actions

Within 48 hours of publishing this Accessibility Plan, Arnold Bros. Transport Ltd. will notify the Accessibility Commissioner as required by section 47 of the Act.

13. Conclusion

Arnold Bros. Transport Ltd. is proud to present this Accessibility Plan for the 2026–2028 cycle. We recognize that building a truly accessible and inclusive organization is an ongoing journey that requires sustained commitment, meaningful consultation, and accountability.

The commitments set out in this plan reflect the voices of our employees, including those with disabilities, and the guidance of external organizations with expertise in accessibility. We are committed to taking meaningful action and to transparently reporting our progress each year.

We invite ongoing feedback from all employees, clients, and members of the public. Your perspectives help us continuously improve.

Appendix A: Legislative and Regulatory References

The following legislation and standards are referenced throughout this plan: