Accessibility Plan (2026-2029)

1.0 - GENERAL   

2.0 - PRIORITY AREAS

3.0 - CONSULTATIONS

4.0 - CONCLUSION

1.1 - About the Company 

PKM Canada Services Inc. (PKMCSI)  is a dynamic energy transportation and midstream provider. Through our integrated value chain, we  seek  to provide safe and reliable infrastructure solutions which connect producers and consumers of energy across the world, support a more sustainable future, and  benefit  our customers, investors,  employees  and communities.   

1.2 - Requirements  

PKMCSI  operates in compliance with the Accessible Canada Act (ACA).  

The ACA is a federal law enacted by the Canadian government in 2019 to promote and ensure equal access and inclusion for persons with disabilities, particularly through the identification and removal of barriers, as well as the prevention of new barriers. The ACA applies to all federally regulated entities, including companies, organizations, and government agencies.   

Per the ACA, all federally regulated entities must:    

• Prepare and publish  an initial  Accessibility  Plan;  
• Establish an accessibility feedback process; and 
• Report annually on the progress towards the plan and address any feedback received.  

Our Accessibility Plan must be reviewed in its entirety and published at least every three years.  

Overall, the ACA  represents  a significant step towards creating a more inclusive and accessible society for all Canadians, including those with disabilities. By  complying with  these requirements,  PKMCSI  is working to ensure  equal access and opportunities for all members of society.  

1.3 - Executive Summary  

PKMCSI is committed to fostering a diverse, inclusive, and empowered workforce, and ensuring  equitable  access to its services, facilities, and communications. This Accessibility Plan (2026-2029)  outlines the actions PKMCSI will take to identify, remove, and prevent accessibility barriers across the seven priority areas as defined by the Accessible Canada Act. 

Table 1.  

Executive Summary: Accessibility Plan (2026-2029) 

1.4 - Accessibility Statement 

PKMCSI is committed to providing an inclusive workplace that ensures a barrier-free environment for all stakeholders, including clients, employees, job applicants, suppliers and any visitors who enter the premises, work for the company, access information provided by the company, or use the company’s goods and services. We believe in integration and equal opportunity in alignment with our core values: 

• Safe: We care for each other 
• Trustworthy: We have each other's backs 
• Respectful: We seek to be gracious and kind 
• Collaborative: We are great together 
• Entrepreneurial: We create to succeed 

1.6 - Feedback 

PKMCSI is committed to providing an open and transparent feedback process to help us to identify, remove and prevent barriers.  

We invite your comments, ideas and feedback on: 

• Our Accessibility Plan (2026-2029)
• Implementation of the plan
• Barriers you may encounter (e.g., accessing our programs, services, or interacting with us)
• Our feedback process
• Our Progress Report (2025)

For more information, to provide feedback, or to request alternative formats, please contact PKMCSI using one of the following methods. You may choose to include your name and contact information if you would like us to follow up with you: 

• Anonymous feedback form: EthicsPoint
• Email: [email protected] 
• Direct mail: Manager, Governance, HRIS & Reporting, 4000, 585 - 8th Avenue S.W., Calgary, Alberta T2P 1G1
• Telephone: 1-844-587-5499

1.7 - Alternative Formats  

PKMCSI Accessibility Plans and Progress Report (2025) are available in the following formats:

• Print
• Large Print 
• Electronic 
• Audio 

A Braille copy of the Accessibility Plans and Progress Report (2025) may be requested by email at [email protected] and by phone at 1-844-587-5499.  

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2.0 – AREAS DESCRIBED UNDER SECTION 5 OF THE ACA  

2.1 - Area 1: Employment   

Our Accessibility Goal   

Cultivate a positive employee experience by promoting a diverse and inclusive environment where all our employees, including those with disabilities, feel engaged, recognized, and empowered.  

Potential Barriers 

Under the Accessible Canada Act, employment barriers are features of workplace policies, practices, systems, or environments that may limit the full participation of persons with disabilities at any stage of employment. These barriers may be physical, digital, procedural, or attitudinal and can affect recruitment, onboarding, accommodation, career development, and ongoing employment. 

Commitments for 2026-2029: 

Commitment 1: Further our commitment to creating an environment that supports employees in feeling engaged, recognized, and empowered. 

• By October 2026, integrate accessibility into enterprise learning through Disability Employment Awareness Month (DEAM) and Equity, Diversity and Inclusion (EDI) Foundations, with annual updates through 2029.
• By November 2026, leverage the Legislative Employment Equity Program (LEEP) surveys and existing consultation channels to collect and apply accessibility feedback annually through 2029. This will include incorporating insights gathered through the Waterfront Accessibility Consultation and ongoing employee feedback mechanisms to validate, refine, and evolve actions over time, ensuring the Accessibility Plan remains responsive to identified barriers and lived experiences.
• By December 2026, reinforce accessible practices through Inclusion Networks and acknowledgement campaigns, delivered annually through 2029.

2.2 - Area 2: Built Environment  

Our Accessibility Goal  

Our goal is to ensure persons with disabilities are provided with safe and barrier-free access to their workplace – not only access to and from the site, but wherever possible, throughout the site. Our commitment is to remove barriers wherever possible while maintaining high standards of safety and productivity for all our employees.  

Potential Barriers 

Under the Accessible Canada Act, barriers in the built environment are physical features of buildings or outdoor spaces that may limit or prevent access for persons with disabilities. This includes how spaces are designed, constructed, maintained, or modified, and whether they support safe, dignified, and independent use. Barriers may affect entry and exit, movement within a space, access to amenities, or the ability to respond safely in emergency situations. 

Commitments for 2026-2029: 

Commitment 1: Ensure that all employees have an accessible path to their workstations.

• Implement consistent way finding and room identification signage along primary routes of travel to support independent navigation between entrances, shared spaces, and work areas by June 2029.

Commitment 2: Provide access, wherever possible, to all employees while maintaining the high safety standards required to operate at our worksites.  

• Improve clarity of pedestrian routes through the use of visual cues (e.g., signage, contrast, and lighting) that enhance safe movement without compromising operational requirements by June 2029.

Commitment 3: Ensure that people with disabilities are treated with dignity and respect in the event of an emergency at our worksites.  

• Enhance visibility and orientation along key circulation routes by improving way finding and visual cues that support safe evacuation and complement existing emergency procedures by June 2029.

2.3 - Area 3: Information and Communication Technologies (ICT)  

Our Accessibility Goal  

We aim to provide our employees with barrier-free access to the digital tools and workspaces that they need to thrive in their roles. Whether they are connecting with a client or looking for information on their benefits, everyone should have the technology and systems to support their work.   

Potential Barriers 

Under the Accessible Canada Act, in the area of information and communication technologies, barriers are present when digital tools, systems, or platforms are not designed or configured to be accessible to all users. This may include software, hardware, applications, websites, or internal systems that are difficult to perceive, operate, or understand for persons with disabilities, or that are not compatible with assistive technologies. 

Commitments for 2026-2029: 

Commitment 1: Ensure that employees have access to and are aware of the accessibility tools and features available to them through our existing third-party systems.   

• Establish guidelines and best practices that measure ICT third-party providers’ level of accessibility to assist in the selection of future tools by Q1 2028.

Commitment 2: Provide digital accessibility training to employees whose roles involve the development, maintenance, or procurement of digital technologies, and maintain training records to support accountability and continuous improvement.

• Provide digital accessibility training to employees whose roles involve the development, maintenance, or procurement of digital technologies, and maintain training records to support accountability and continuous improvement by December 5, 2027.

2.4 - Area 4: Communication, other than ICT  

Our Accessibility Goal  

Our goal is that all communications are accessible to the intended audience, both internal and external, without barriers.  

Potential Barriers 

Under the Accessible Canada Act, barriers in communication (other than ICT) occur when information is shared in ways that are not accessible or inclusive. This includes written, spoken, or visual communication that may be difficult to understand, perceive, or engage with due to language complexity, format, timing, or delivery method. Barriers may affect internal or external communications and can limit meaningful participation or access to information. 

Commitments 2026-2029: 

Commitment 1: Ensure that all public web pages (including web applications), and digital documents, that are newly published or updated on or after December 5, 2028, meet clauses 4-7 and 9 of the ICT Standard. 

Commitment 2: Ensure that all communications—internal and external—are clear, inclusive, and accessible to their intended audiences, without barriers, and that communication supports are offered proactively. 

• By June 2029, ensure the following are met: 
  • Ensure communication practices are accessible across written, verbal, and in‑person formats.
  • Use plain language and clear formatting to improve understanding and reduce communication barriers.
  • Provide information in accessible formats and communication supports upon request, in a timely and respectful manner.
  • Establish and communicate a clear, simple process for requesting communication supports.
  • Proactively offer communication supports in advance of meetings, training, and key communications.
  • Build employee awareness and capability in accessible communication practices.
  • Track communication accessibility efforts to support continuous improvement and compliance.

Commitment 3:  Complete digital accessibility training required for all employees whose roles involve the development, maintenance, or procurement of digital technologies.

• Complete digital accessibility training required for all employees whose roles involve the development, maintenance, or procurement of digital technologies by December 5, 2027 (See Area 3: Information and Communication Technologies (ICT), Commitment 2) 

2.5 - Area 5: Procurement of Goods, Services and Facilities  

Our Accessibility Goal  

Our goal is to hold our suppliers and vendors accountable for providing accessible workplaces for their employees and barrier-free goods, services, and facilities to their customers.  

Potential Barriers 

Under the Accessibility Canada Act, barriers arise when accessibility is not considered in the purchasing or contracting of goods, services, or facilities. This can include procuring products or services that are not accessible by design, or procurement processes that unintentionally limit participation by suppliers or service providers who support accessibility and inclusion. 

Commitments for 2026-2029 

Commitment 1: Ensure we are engaging suppliers who operate responsibly, ethically, and in alignment with applicable laws, and our expectations for safe, inclusive, and sustainable business practices. 

• Require all suppliers to acknowledge and comply with our Supplier Code of Conduct, which outlines standards for safety, environmental responsibility, human rights, equity, diversity and inclusion, and ethical business practices.
• Leverage supplier pre-qualification processes, including our third-party qualification platform, to gather information on suppliers’ commitments and practices, including accessibility and barrier-free approaches.
• Require suppliers to meet all applicable laws and regulations in the delivery of goods and services, including accessibility-related obligations such as the Accessible Canada Act.

Commitment 2: Complete digital accessibility training required for all employees whose roles involve the development, maintenance, or procurement of digital technologies. 

• Complete digital accessibility training required for all employees whose roles involve the development, maintenance, or procurement of digital technologies by December 5, 2027 (See Area 3: Information and Communication Technologies (ICT), Commitment 2) 

2.6 - Area 6: Design and Delivery of Programs and Services  

Our Accessibility Goal  

Provide barrier-free services and communications to our customers to strengthen our partnerships and promote accessibility for all our stakeholders.  

Potential Barriers  

Under the Accessible Canada Act, barriers in the design and delivery of programs and services occur when programmes, processes, or services are not designed to be inclusive or accessible to persons with disabilities. This may include how services are structured, how people interact with them, or how accommodations are offered or communicated, potentially limiting equitable access or participation. 

Commitments for 2026-2029: 

Commitment 1: Provide customers with barrier-free communication, wherever possible.  

• Ensure that all public web pages (including web applications), and digital documents, that are newly published or updated on or after December 5, 2028, meet clauses 4-7 and 9 of the ICT Standard.(See Area4:Communication, other thanICT,Commitment1)
• Complete digital accessibility training required for all customer-facing employees whose roles involve the development, maintenance, or procurement of digital technologies by December 5, 2027 (See Area 3:Information and Communication Technologies (ICT), Commitment 2)  

2.7 - Area 7: Transportation  

Our Accessibility Goal  

Improve accessible site access by ensuring individuals can obtain clear, accessible information about transportation options and site entry points in advance of arrival, supporting safe, independent, and barrier-free access, wherever possible. 

Potential Barriers 

Under the Accessible Canada Act, transportation‑related barriers are features of transportation systems or services that restrict accessible use by persons with disabilities. This includes barriers related to vehicles, infrastructure, information, or service delivery within federally regulated transportation contexts, where applicable. Such barriers may affect the ability to travel safely, independently, or with dignity. 

Commitments for 2026-2029: 

Commitment 1: Ensure a barrier-free federal transportation network, wherever possible. 

• Create accessible transportation instructions to our sites, which may include details such as public transit options, driving instruction, and accessible access points upon arrival. Encourage employees and our recruitment team to provide these instructions to all guests including customers and interview candidates when arranging for a visit to one of our sites, starting in June 2027.

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3.0 - CONSULTATIONS

The concept of “Nothing Without Us” supports the notion that persons with disabilities must be involved in the ideation of PKMCSI’s Accessibility Plan to support the company in identifying opportunities to progress accessibility in policies, procedures, and the built environment. We are committed to ensuring that the voices of people with disabilities are at the center of our accessibility planning. Their insights and lived experiences are invaluable in helping us identify barriers and co-create meaningful solutions. 

In 2026, we engaged in two consultation activities: the Waterfront Accessibility Consultation, and an internal Employment Equity Survey.  

3.1 – Waterfront Accessibility Consultation  

As part of the development of accessibility plans under the Accessible Canada Act, the BCMEA, on behalf of waterfront employers, engaged subject matter experts to support the development of an accessibility audit tool. The subject matter experts included  Adaptability  Canada,  the  BC Centre for  Ability,  and  Meaningful Access Consulting.  

The audit tool is intended for employers to review accessibility across the areas identified under the Accessible Canada Act, including employment, the built environment, information and communication technologies, communication, procurement, design and delivery of programs and services, and transportation where applicable, and to provide a practical and consistent way to identify potential barriers.   

3.1.1 – Consultation Process 

Employees were invited to provide feedback through two mechanisms: the Waterfront Accessibility Consultation and the Legislative Employment Equity Program (LEEP) survey, both of which were open to all PKMCSI employees.  

As part of the Waterfront Accessibility Consultation, employee feedback was gathered through confidential interviews conducted by an independent third party. Employees of waterfront employers, including all PKMCSI locations, could participate by booking an interview via link, QR code, or email, with accommodations available upon request. Interviews were conducted virtually via Zoom unless otherwise requested, and information about the consultation was shared through email and printed posters to support broad awareness and accessibility. Together, subject matter expert input and employee interviews provided both a structured assessment approach and direct feedback from employees. 

The interviews focused on employees’ experiences of accessibility at work, including what is working well, where barriers may exist, and what would make accessibility more meaningful in practice. Disability was discussed broadly and included visible and invisible disabilities, physical disabilities, cognitive disabilities, neurodivergence, mental health-related disabilities, chronic conditions, temporary injuries, and recovery from illness or surgery.  

Participation was voluntary. Employees were told that their feedback would be anonymized, combined with feedback from other participants, and reported without identifying individual employees or distinguishing their employer.  

The feedback suggests that employers are not starting from scratch. Employees pointed to supportive managers, responsive leadership, existing Health and Safety or hazard-reporting processes, and accessible features already in place at some sites. At the same time, employees identified areas where accessibility could be clearer, more consistent, and easier to access in practice.  

3.1.2 - Results  

The findings outlined below reflect feedback gathered through the Waterfront Accessibility Consultation.  

Employment  

Employment was the area where employees had the most feedback. Several employees described managers or leaders who were supportive and willing to help when concerns were raised. Existing Health and Safety or hazard-reporting processes were also identified as useful channels in some situations.    

The main opportunity is to make support easier to find and navigate. Employees may not always know who to contact for ergonomic support, an accommodation request, temporary injury support, return-to-work needs, or other accessibility-related concerns. This can be especially difficult for new employees, hybrid workers, or employees working across more than one location.  

Training and onboarding were also raised. Employees noted that long verbal explanations, slide decks, videos, and virtual onboarding sessions do not work equally well for everyone. More accessible options could include shorter sessions, practical demonstrations, written step-by-step guides, checklists, captions, and materials employees can return to later.  

 Employees also spoke about the need to better recognize invisible disabilities, including ADHD, neurodivergence, learning disabilities, and mental health-related needs. Some feedback also pointed to workplace culture as a barrier. The waterfront was described as physically demanding and, at times, shaped by toughness, hierarchy, confrontation, and seniority. While the industry has clear strengths, including teamwork, resilience, direct communication, and operational  expertise, employees may be less likely to ask for support if they feel it will be viewed negatively.  

Built Environment  

Employees  identified  some physical access barriers, particularly in older facilities and secure access areas. Examples included heavy self-closing doors, stairs, wet or slippery surfaces, and entry points designed primarily around security requirements. These barriers can be difficult for employees with mobility limitations, employees recovering from surgery, or employees dealing with temporary injuries.  

Employees also noted that some accessible features are already in place, including accessible parking, washrooms, ramps, and automatic door openers in some locations. The opportunity is to review whether these features are consistent across sites and whether employees can move through the workplace safely and independently from arrival to departure.  

Information and Communication Technologies  

Digital tools were generally seen as useful, particularly for virtual meetings and training. However, employees noted that long virtual sessions, slide-heavy training, and passive video content can be difficult for some learning and attention needs.  

Employers may want to consider more consistent use of captions, agendas, written follow-up, recordings or transcripts where appropriate, and accessible digital training materials. Clearer expectations around Teams and email may also help employees manage interruptions, response-time expectations, and focus time.  

Communication, Other Than Information and Communication Technologies  

Employees  identified  a need for clearer communication about accessibility supports. Information about accommodation, ergonomic support, EAP or counselling resources, and accessibility contacts should be easy to find and written in plain language.  

Employees should also continue to hear that accessibility includes more than physical disability. This includes invisible disabilities, temporary and episodic disabilities, neurodivergence, mental health-related disabilities, chronic conditions, and recovery from injury or illness.  

Employees appreciated being asked for feedback. Reporting back on accessibility improvements would help show that feedback is being used and would support trust in the process.  

Procurement of Goods, Services and Facilities  

Procurement did not come up as a standalone issue in the employee interviews. However, several findings have procurement implications. These include ergonomic equipment, accessible doors and access systems, accessible training tools, and counselling or employee support services that can meet a range of needs.  

The accessibility audit tool can help employers consider accessibility earlier when  purchasing  goods, services, systems, and facilities, rather than addressing barriers after decisions have already been made.  

Design and Delivery of Programs and Services  

 No specific barriers were identified in this area during the employee consultation. The feedback received related to employees’ workplace experiences rather than customer-facing or client-facing programs and services.  

Transportation  

No specific transportation-related barriers were identified during the employee consultation. Comments about parking, exterior routes, entrances, and movement through worksites are reflected under the built environment section.  

3.2 Employment Equity Survey 

As part of PKMCSI’s Legislated Employment Equity Program (LEEP) initiative, an Employment Equity Survey was developed and all PKMCSI employees were invited to provide feedback. Employees were given the opportunity to share feedback on their workplace experiences and identify potential barriers affecting designated groups. The survey included targeted questions assessing employee comfort in requesting accommodations, whether requests are addressed in a timely and respectful manner, accessibility of workplace systems, tools, and environments, and awareness of the accommodation process. Employees were also invited to identify opportunities to improve the accommodation experience (e.g., clearer policies, increased communication, manager training, or access to confidential supports), as well as provide open-ended suggestions to strengthen accessibility and support for employees with diverse needs. 

Insights from both the Waterfront Accessibility Consultation and the LEEP survey will be incorporated into ongoing actions, beginning in November 2026 in alignment with Commitment 1 in the Employment section. 

3.3 - Future Consultations  

Future versions of PKMCSI’s Accessibility Plan will continue to place emphasis on conducting a comprehensive consultation process to fully align with the concept of "Nothing Without Us". The goal is to engage broader mechanisms for consultation with customers, employees, and Inclusion Networks through testimonials and storytelling, feedback surveys, and facilitated consultative sessions.  

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4.0 - CONCLUSION  

PKMCSI aims to foster an inclusive environment where employees and customers, including those with disabilities, are empowered and provided with equitable opportunities. Through commitments ranging from enhancing employment practices to refining digital tools, communication, and procurement processes, PKMCSI demonstrates its dedication to leading with equity, diversity and inclusion.  

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Appendix A: Progress on Accessibility Plan (2023-2026)