Starr Insurance & Reinsurance Limited, Canada Branch Multi-Year Accessibility Plan 2026

Message from the Country Executive and Introductory Statement

The success of Starr requires the collective effort of many dedicated, skilled employees around the world and working with a diverse and extensive customer base. Cornelius Vander Starr established his first insurance company in Shanghai, China in 1919. Today, Starr is one of the world's fastest growing large insurance organizations, with a presence across six continents. No other global insurance company exceeds Starr's long history and comprehensive experience in complex business markets. Our goal is simple: to be the leading insurance company in the world by applying our knowledge, vision and relationships to help our clients succeed wherever they do business

Our management team is dedicated to ensuring accessibility with respect to recruiting, hiring, placement, promotion, transfer, training, compensation, benefits, employee activities and general treatment during employment. Starr’s leadership commits its time, creativity, and resources to continue to implement accessibility best practices to eliminate barriers to the access of our customers, employees, and other stakeholders.

Starr Insurance & Reinsurance Limited, Canada Branch (“Starr”) strives to meet the needs of its employees and customers with disabilities and is working hard to remove and prevent barriers to accessibility.

Starr is committed to meeting the needs of people with disabilities in a timely manner, and will do so by identifying, preventing and removing barriers to accessibility and meeting the accessibility requirements under the Accessibility for Ontarians with Disabilities Act, 2005 (“AODA”).

Our plan shows how we will play our role in making Ontario an accessible province for Ontarians.

Our plan is reviewed and updated at least once every 5 years. We will consult with employees and other stakeholders in the development and implementation of this Accessibility Policy and Plan.

We train every person as soon as practicable after being hired and provide training in respect of any changes to the policies.

We maintain records of the training provided including the dates on which the training was provided and the number of individuals to whom it was provided.

This Accessibility Policy and Plan is intended to meet the requirements of the Integrated Accessibility Standards Regulation (IASR) made pursuant to AODA.

This document will be posted on Starr's external website and internal intranet website for Ontario, and it is available upon request in an accessible format.

Past Achievements to Remove and Prevent Barriers

Starr has completed the following accessibility initiatives:

Customer Service Standard:

In the event of a planned or unexpected disruption to services or facilities for persons with disabilities, Starr will notify affected persons promptly. This 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. The notice will be clearly placed at the main entrances of our facilities, as well as where the disruption is taking place. Starr maintains a document setting out the steps it will take in connection with a temporary disruption, which is available upon request.

Starr is committed to ensuring that persons with disabilities have an equal opportunity to obtain, use, and benefit from its goods, services, and facilities. These goods, services, and facilities are provided in a manner that respects the dignity, independence, integration, and equal opportunity of persons with disabilities. Where necessary to enable a person with a disability to fully benefit from Starr's goods, services, or facilities, alternative measures may be implemented on either a temporary or permanent basis. Starr communicates with persons with disabilities in a manner that takes their individual accessibility needs into account. Persons with disabilities are also permitted to use assistive devices, service animals, and support persons, as required to access Starr's goods, services, and facilities, except where otherwise restricted by applicable law.

Employment:

Starr maintains robust and compliant Equal Employment Opportunity and Accommodation & Accessibility Policies. To ensure that employees who are able to work are not unfairly excluded from doing so, Starr is committed to making every reasonable effort to accommodate those needs related to Ontario Human Rights Code (“Code”)-protected grounds up to the point of undue hardship. As part of its commitment to accessibility, Starr ensures employees are not excluded from the workplace due to barriers to accessibility. To this end, Starr’s Benefits team works with employees to determine whether any equipment, software, or changes to the physical layout of the office will permit an employee to report to the office on either a full-time or hybrid basis. Starr’s Benefits team also administers a robust process for reviewing requests for workplace accommodations and maintaining an interactive dialogue with employees receiving accommodations to ensure that such accommodation remains fit for purpose.

Where an employee with a disability requests it, Starr will consult with the employee and provide or arrange for accessible formats and communication supports for information needed to perform the employee’s job and information generally available to employees in the workplace.

Starr maintains a written process for developing documented individual accommodation plans for employees who self-identify as having a disability. Starr will consult with the employee to determine accommodation needs; ensure individualized accommodation plans are developed in accordance with the elements of such plans outlined in the AODA, including the employee’s participation, individual assessment, the ability to request an evaluation by an outside expert at Starr’s expense, the participation of a workplace representative, protection of the employee’s privacy, the frequency of review, the manner of providing reasons for any denial, and provision of the plan in an accessible format; and, where necessary, coordinate with any steps taken by applicable benefits providers.

Starr maintains a documented return-to-work process for employees who have been absent due to a disability and require disability-related accommodations to return to work. Starr will consult with the employee to determine accommodation needs; develop an individualized return-to-work plan that outlines the steps taken to facilitate the return to work and uses any documented individual accommodation plan already in place; and, where necessary, coordinate with any steps taken by applicable benefits providers.

Where Starr uses performance management, career development and advancement, or redeployment processes, it will take into account the accessibility needs of employees with disabilities and any individualized accommodation plans, and will ensure equal opportunities for employees with disabilities to undertake professional development.

Training:

Starr is committed to training its Ontario employees on Ontario’s accessibility laws, including the customer service standard and the requirements of the IASR, and on the Code as it relates to persons with disabilities. Training is provided to all employees, to all persons who participate in developing Starr’s policies, and to all other persons who provide goods, services or facilities on Starr’s behalf, in a manner appropriate to their duties, as soon as practicable, and on an ongoing basis whenever changes are made to Starr’s accessibility policies. Starr maintains records of the training provided, including the dates on which training was provided and the number of individuals to whom it was provided.

Recruitment, Assessment, Selection and Onboarding:

Starr notifies its employees, the public and job applicants that it will accommodate applicants with disabilities during the recruitment, assessment, selection and onboarding process. Starr will incorporate language into its job postings and notifications to applicants for interviews in Ontario advising that accommodation is available upon request; consult with any applicant who requests accommodation to determine their individual accommodation needs; review its hiring process to ensure barriers may be removed or accessible features provided upon request; and notify successful applicants of Starr’s policies for accommodating employees with disabilities when making an offer of employment. Starr will inform all employees of its policies supporting employees with disabilities, including policies relating to workplace accommodations. New employees will be advised of these policies as soon as practicable after commencing employment, and employees will be notified whenever such policies are updated.

Information and Communications:

Starr is committed to meeting the communication needs of all people. When requested and where possible, Starr will provide publicly available information and communications materials in accessible formats or with communication supports in a timely manner and at no additional cost to the requestor. This includes publicly available information about our goods, services and facilities, as well as publicly available emergency information. Starr will consult with people to determine their information and communication needs, and will notify the public of the availability of accessible formats and communication supports.

Individuals who need to request publicly available information and communications materials in accessible formats can contact Starr using the contact information set out under “For More Information” below. The response for approving or declining a request will be shared in the same way the requestor initiated the process.

Starr strives to ensure that online content is accessible. Starr maintains WCAG functionality across its websites and electronic communications and is undertaking a platform rebuild of its website design and functionality. As part of that process, Starr will ensure that its internet websites and web content conform with the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0, Level AA, except where meeting the requirement is not practicable.

Design of Public Spaces:

Starr’s offices at 200 King Street West are managed in accordance with the AODA and applicable provisions of Section 3.8 of the Ontario Building Code. They are also Rick Hansen Foundation Accessibility Certified as exceeding the accessibility and usability of the built environment beyond minimum Ontario Building Code requirements.

Starr will provide individualized workplace emergency response information to employees who have a disability if the disability is such that the individualized information is necessary and Starr is aware of the need for accommodation. Where the employee consents, Starr will share the information with the person designated to provide assistance to the employee in an emergency. Starr will review the individualized information when the employee moves to a different location, when the employee’s overall accommodation needs are reviewed, and when Starr reviews its general emergency response policies.

Strategies and Actions

Starr is committed to fair and accessible employment practices. Starr will continue to administer accessibility and disability accommodation best practices through its Benefits team. The interactive process of addressing individual employees’ accessibility concerns and collaborating on finding solutions tailored to their specific needs and requirements will continue at Starr. Starr is committed to using new technologies and developments to more fully accommodate employees with accessibility limitations and allow them to fully participate in the workplace.

Starr is committed to making our information and communications accessible to people with disabilities. Starr is in the midst of a platform rebuild of its website design and functionality. As part of this process Starr is reviewing its current WCAG level and exploring opportunities for upgrades to enhance its accessibility functionality.

Starr is committed to providing training in the requirements of Ontario’s accessibility laws and the Code as it applies to people with disabilities. Starting in 2027 Starr will implement enhanced employee training on accessibility and inclusion for both existing employees and new hires.

Starr will meet accessibility laws when building or making major changes to public spaces. Starr will continue to ensure that all of its Toronto offices and facilities comply with applicable accessibility standards under the AODA and Ontario Building Code Section 3.8.

For More Information

For more information on Starr’s accessibility plan, or to provide feedback on the way Starr provides goods, services, and facilities to people with disabilities, please contact:

Lynder Festa, Benefits Director
(212) 401-2883
Lynder.Festa@Starr.com
399 Park Avenue
New York, NY 10022

Our accessibility plan is publicly posted at: Starr Canada Accessibility Compliance Plan

Standard and accessible formats of this document are free on request from:

Lynder Festa, Benefits Director
(212) 401-2883
Lynder.Festa@Starr.com
399 Park Avenue
New York, NY 10022

Definitions:

Accessible formats may include, but are not limited to, large print, recorded audio and electronic formats, braille, and other formats usable by persons with disabilities.

Communication supports may include, but are not limited to, captioning, alternative and augmentative communication supports, plain language, sign language and other supports that facilitate effective communication.

Disability means any degree of physical disability, infirmity, malformation or disfigurement that is caused by bodily injury, birth defect or illness; 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.