Sea Air’s Privacy Policy

Sea Air is committed to protecting your privacy. Please read the following statements regarding your privacy and the efforts Sea Air is taking to safeguard it.

To safeguard the personal information entrusted to Sea Air and to comply with the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and any other applicable legislation, Sea Air is committed to the following principles. (click each to expand).

Sea Air is committed to protecting the privacy of its employees, customers, and other stakeholders. We value the trust of those we deal with, and of the public, and recognize that maintaining this trust requires that we be transparent and accountable in how we treat the personal information that you choose to share with us.

During the course of our various activities, we frequently gather and use personal information. This information may be obtained directly from you or collected from third parties that have the right to disclose this information to us. Anyone from whom we collect such personal information should expect that it will be carefully protected and that any use of or other dealing with this personal information is subject to express or implied consent. Our privacy practices are designed to achieve this.

Depending on where you live, Sea Air may not be under any statutory obligations with respect to the protection of the information that you provide to us. Notwithstanding this, Sea Air has voluntarily decided to adhere to best practices for the collection, use and disclosure of personal information as outlined in this policy.

Personal information is information about an identifiable individual as defined, from time to time, in applicable Canadian (including federal, provincial and territorial) privacy legislation. This includes any information that can be used to distinguish, identify or contact a specific individual. An individual’s opinions or beliefs, as well as facts about, or related to, the individual may also be considered personal information. Business contact information and certain publicly available information, such as names, addresses and telephone numbers as published in telephone directories, may not be considered personal information.

Where an individual uses his or her home contact information as business contact information as well, we consider the contact information provided to be business contact information, and therefore may not be subject to the same level of protection as personal information.

Personal information collected by Sea Air may include: name, address, and other contact information, credit card, or bank account information for transaction purposes.

Sea Air collects personal information in order to service your account, and provide you with relevant communications.

We may share this information with Sea Air employees for the purposes of marketing, research and analysis. In some cases it may be necessary to share the information with a third party service provider on a confidential basis. When this occurs, we provide only the information that is required to provide the services and strict terms of confidentiality are established. In certain limited circumstances, personal information collected by Sea Air (excluding financial information) may be stored or processed outside of Canada and therefore subject to the legal jurisdiction of those countries.

Personal information gathered by our organization is kept in confidence. Our employees are authorized to access personal information based only on their need to deal with it for the reason(s) for which it was obtained. Safeguards are in place to ensure that personal information is not disclosed or shared more widely than is necessary to achieve the purpose for which it was gathered.

We contractually require any person or organization providing services to Sea Air to comply with federal and provincial privacy legislation.

We also take measures to ensure that the integrity of personal information is maintained and retained only as long as it is required. We collect, use and disclose personal information only for purposes that a reasonable person would consider appropriate in light of the circumstances.

We do not rent, sell, or trade personal information to any other organization.

We use password protocols and encryption software to protect personal and other information we receive when a service is requested on-line. Our software is routinely updated to maximize protection of such information. The Sea Air Website uses or may in the future use, technology features such as login registration, cookies, or click through tracking software. The site also logs information such as Website IP addresses and browser types. This information is used for analysis purposes and to provide better service for users.

Questions or concerns related to Sea Air’s Privacy and Security Policy and/or Sea Air’s treatment of personal information, should be directed to:

Attention: Privacy Officer
Sea Air
1720 Meyerside Drive
Mississauga, Ontario L5T 1A3 Canada

Additionally, you may call us at +1 905 677 7701.

Further information on privacy and your rights in regard to your personal information may be found on the Website of the Privacy Commissioner of Canada at http://www.privcom.qc.ca/.

Sea Air’s Accessibility Policy

Sea Air International (Sea Air) is subject to legislation, which has been enacted with the goal of developing standards that would improve accessibility for people with disabilities. Such legislation requires Sea Air to be in compliance with a number of customer service accessibility standards.

This policy is intended to meet current legislative requirements and applies to the provision of services to the public. This policy aims to ensure that persons with disabilities are provided equal opportunity to obtain, use and benefit from Sea Air services. Reasonable efforts will be made to ensure that:

  1. Services are provided in a manner that respects the dignity and independence of persons with disabilities;
  2. The services provided to persons with disabilities are integrated with the provision to others unless an alternate measure is necessary to allow a person with a disability to benefit from the services. The alternate measure may be temporary or permanent;
  3. Communication with a person with a disability is conducted in a manner that takes into account his or her disability;
    People with disabilities may use assistive devices, service animals and support persons as is necessary to access Sea Air services. If a service animal is excluded by law from a premise, other measures will be made available for the person with a disability to access the services.

This policy is intended to meet current legislative requirements and applies to the provision of services to the public. This policy aims to ensure that persons with disabilities are provided equal opportunity to obtain, use and benefit from Sea Air services. Reasonable efforts will be made to ensure that:

  1. This policy governs the provision of services by Sea Air at all Sea Air owned and operated facilities, as well as the provision of Sea Air services off the premises by Sea Air employees, agents and/or contractors who act on behalf or represent Sea Air.
  2. The part of the policy that deals with the use of service animals and support persons applies only to services provided by Sea Air at premises owned or operated by Sea Air.

Sea Air is a freight forwarding company dedicated to excellence in serving all customers including people with disabilities.

In fulfilling our mission, Sea Air is committed to providing its services in a way that respects the dignity and independence of people with disabilities. We are also committed to giving people with disabilities the same opportunity to access our services and allowing them to benefit from the same services, in the same place and in a similar way as other customers.

Sea Air is committed to excellence in serving all customers including people with disabilities and we will carry out our functions and responsibilities in the following areas:

  1. Communication: We will communicate with people with disabilities in ways that take into account their disability. We will train staff who communicate with customers on how to interact and communicate with people with various types of disabilities.
  2. Telephone services: We are committed to providing fully accessible telephone service to our customers. We will train staff to communicate with customers over the telephone in clear and plain language and to speak clearly and slowly. We will offer to communicate with customers by email and other services, which may become available if telephone communication is not suitable to their communication needs or is not available.
  3. Assistive devices: We are committed to serving people with disabilities, who use assistive devices to obtain, use or benefit from our services. We will ensure that our staff is trained and familiar with various assistive devices that may be used by individuals with disabilities while accessing our services.
  4. Billing: We are committed to providing accessible invoices to all of our customers. For this reason, invoices will be provided in the following formats upon request: hard copy, large print, and e-mail. We will answer any questions customers may have about the content of the invoice in person, by telephone or email.

We are committed to welcoming people with disabilities who are accompanied by a service animal on the parts of our premises that are open to the public and other third parties. We will also ensure that all staff and others dealing with the public are properly trained in how to interact with people with disabilities who are accompanied by a service animal.

We are committed to welcoming people with disabilities who are accompanied by a support person. Any person with a disability who is accompanied by a support person will be allowed to enter Sea Air’s premises with his or her support person. At no time will a person with a disability who is accompanied by a support person be prevented from having access to his or her support person while on our premises.

Fees will never be charged for support persons for admission to Sea Air’s premises.

Sea Air will provide customers with notice in the event of a planned or unexpected disruption in the facilities or services usually used by people with disabilities. This notice will include information about the reason for the disruption, the anticipated duration, and a description of alternative facilities or services, if available. The notice will be placed at all public entrances and service counters on our premises.

Sea Air will ensure that all persons to whom this policy applies receive training as required by applicable legislation. This training will be provided as soon as practicable following a new employee commencing employment with Sea Air. Training will include the following:

  1. The purposes of applicable law – including the Accessibility for Ontarians with Disabilities Act, 2005 and the requirements of the customer service standard.
  2. How to interact and communicate with people with various types of disabilities.
  3. How to interact with people with disabilities who use an assistive device or require the assistance of a service animal or a support person.
  4. How to use the equipment or devices available at Sea Air that may help with the provision of services to persons with disabilities.
  5. What to do if a person with a disability is having difficulty in accessing Sea Air’s services.
  6. Sea Air’s policies, practices and procedures relating to the customer service standard.

Applicable staff will be trained on policies, practices and procedures that affect the way services are provided to people with disabilities. Staff will also be trained on an ongoing basis when changes are made to these policies, practices and procedures

The ultimate goal of Sea Air is to meet and surpass customer expectations while serving customers with disabilities. Comments on our services regarding how well those expectations are being met are welcome and appreciated. Feedback regarding the way Sea Air provides services to people with disabilities can be made by letter, email or verbally. All feedback will be directed to Sea Air International’s Controller. Customers can expect to hear back within 5 business days.

We are committed to developing customer service policies that respect and promote the dignity and independence of people with disabilities. Therefore, no changes will be made to this policy before considering the impact on people with disabilities.

The purpose of this policy is to provide a framework through which Sea Air can achieve service excellence for people with disabilities. If anyone has questions about this policy, please contact:
Lana Sinuk
Sea Air International, Controller
(905) 677-7701
1720 Meyerside Drive, Mississauga, ON L5T 1A3

Integrated Accessibility Standards Policy

The following policy has been established by Sea Air International (“Sea Air”) to govern the provision of services with Regulation 191/11, “Integrated Accessibility Standards” (“Regulation”) under the Accessibility for Ontarians with Disabilities Act, 2005. These standards are developed to break down barriers and increase accessibility for persons with disabilities in the areas of information and communications and employment. Sea Air is governed by this policy as well as the Accessibility Standards for Customer Service Policy and the Accessibility for Ontarians with Disabilities Act, 2005 in meeting the accessibility needs of persons with disabilities.

Accessibility Plan

Sea Air will develop, maintain and document an Accessibility Plan outlining the company’s strategy to prevent and remove barriers from its workplace and to improve opportunities for persons with disabilities. The Accessibility Plan will be reviewed and updated at least once every five years, and will be posted on the company’s website. Upon request, Sea Air will provide a copy of the Accessibility Plan in an accessible format.

Training Employees

Sea Air will ensure that training is provided on the requirements of the accessibility standards referred to in the Regulation and continue to provide training on the Human Rights Code as it pertains to persons with disabilities, to:

  1. all its employees
  2. all persons who participate in developing Sea Air’s policies; and,
  3. all other persons who provide goods, services or facilities on behalf of the company

The training will be appropriate to the duties of the employees, and other persons. Employees will be trained when changes are made to the accessibility policy. New employees will be trained as soon as practicable. Sea Air will keep a record of the training it provides.

Commitment

Sea Air is committed to treating all people in a way that allows them to maintain their dignity and independence. We believe in integration and equal opportunity. We are committed to meeting the needs of persons with disabilities in a timely manner, and will do so by preventing and removing barriers to accessibility and meeting accessibility requirements under the Accessibility for Ontarians with Disabilities Act. This policy will be implemented in accordance with the time frames established by the Regulation.

EMPLOYMENT STANDARDS

Sea Air will notify its employees and the public about the availability of accommodation for applicants with disabilities in its recruitment process.

Sea Air will notify job applicants, when they are individually selected to participate further in an assessment or selection process that accommodations are available upon request in relation to the materials or processes to be used. If a selected applicant requests an accommodation, Sea Air will consult with the applicant and provide, or arrange for the provision of, a suitable accommodation in a manner that takes into account the applicant’s accessibility needs due to disability.

When making offers of employment, Sea Air will notify the successful applicant of its policies for accommodating employees with disabilities, upon request.

Sea Air will continue to inform its employees of its policies (and any updates to those policies) used to support employees with disabilities, including policies on the provision of job accommodations that take into account an employee’s accessibility needs due to disability. This information will be provided to new employees as soon as practicable after commencing employment.

Upon the request of an employee with a disability, Sea Air will consult with the employee to provide, or arrange for the provision of, accessible formats and communication supports for information that is needed to perform his/her job, and information that is generally available to other employees. In determining the suitability of an accessible format or communication support, Sea Air will consult with the employee making the request.

Sea Air 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 if Sea Air is aware of the need for accommodation due to the employee’s disability. Sea Air will provide this information as soon as practicable after becoming aware of the need for accommodation.

Where the employee requires assistance, Sea Air will, with the consent of the employee, provide the workplace emergency response information to the person designated by Sea Air to provide assistance to the employee.

Sea Air will review the individualized workplace emergency response information when the employee moves to a different location in the organization, when the employee’s overall accommodations needs or plans are reviewed.

Sea Air will maintain a written process for the development of documented individual accommodation plans for employees with disabilities.

If requested, information regarding accessible formats and communications supports provided will also be included in individual accommodation plans.

In addition, the plans will include individualized workplace emergency response information (where required), and will identify any other accommodation that is to be provided.

Sea Air will work together with members of the employee’s medical or paramedical team to develop a practical return to work for its employees who have been absent from work due to a disability and who require disability-related accommodations in order to return to work.

This return to work process will facilitate the return to work and will include documented individual accommodation plans.

This return to work process will not replace or override any other return to work process created by or under any other statute (ie: The Workplace Safety Insurance Act, 1997).

Sea Air will take into account the accessibility needs of employees with disabilities, as well as individual accommodation plans, when conducting performance management, providing career development and advancement to employees, or when redeploying employees.

This policy has been developed to break down barriers and increase accessibility for persons with disabilities in the areas of information and communications and employment. If anyone has a question about the policy, or if the purpose of a policy is not understood, an explanation will be provided by:
Lana Sinuk,
Sea Air International, Controller
(905) 677-7701
1720 Meyerside Drive, Mississauga, ON L5T 1A3

Sea Air International Multi-Year Accessibility Plan

As part of Sea Air International’s (Sea Air) commitment to accessibility, this multi-year Accessibility Plan has been developed outlining the company’s strategy and the actions that have, and will be, implemented to prevent and remove barriers from its workplace, and to improve opportunities for persons with disabilities. This multi-year Accessibility Plan outlines the steps Sea Air is taking to meet its requirements under the Accessibilities for Ontarians with Disabilities Act (AODA) and focuses on Sea Air’s initiatives in respect of the AODA’s Accessibility Standards in making Ontario an accessible province for all Ontarians.

Sea Air is committed to excellence in serving all customers including people with disabilities.

  • An accessibility policy was put in place so Sea Air’s employees and customers can know what to expect.
  • Sea Air staff is trained to serve customers of all abilities.
  • A written record of accessibility training provided by Sea Air is maintained.
  • Service animals and support persons are welcomed on all Sea Air premises.
  • Accessible ways for people to provide feedback on how Sea Air provides services to people with disabilities was made available.

Sea Air commits to provide accessible formats and communication supports for persons with disabilities upon request. Sea Air provides notice to the public of this availability and consults will the person making such a request to determine the suitability of an accessible format or communication support. As well, it is currently a Sea Air Company global web development requirement that all new Sea Air web content be built to meet the World Wide Web Consortium Content Accessibility Guidelines (WCAG) 2.0 standard. Sea Air is committed to ensuring all Sea Air internet websites and web content conform with Level AA of the WCAG 2.0 by June 30, 2021 as required by the AODA’s Information and Communications Standard.

Sea Air has and will continue to implement policies and initiatives in accordance with the AODA by taking the following steps:

  • Implementing policies outlining Sea Air’s commitment to accessibility. (Implemented as of January 1, 2012).
  • Providing training to Sea Air’s employees and volunteers on accessibility and human rights legislation, as it pertains to people with disabilities. (Implemented as of January 1, 2012, and ongoing as new employees/volunteers join the company).
  • This plan will be reviewed once every five years.

In accordance with the AODA’s Employment Standards, Sea Air implemented the following initiatives prior to January 1, 2016:

  • Ensure Sea Air’s employment processes for hiring, retention and career development are accessible.
  • Document Sea Air’s processes for developing individual accommodation plans and return-to-work plans.
  • Provide individualized workplace emergency response information to employees who have a disability where Sea Air is aware of the need for accommodation.

This multi-year Accessibility Plan will be reviewed and updated at least once every five (5) years. The current Accessibility Plan will be reviewed, and updated as appropriate, no later than January 1, 2026.

In 2012, Sea Air ensured it had accessible ways to receive and respond to feedback. Sea Air will continue to ensure that its process for receiving and responding to feedback is accessible to persons with disabilities and will respond to feedback promptly. Sea Air submitted its accessibility compliance report confirming compliance with its accessibility obligations as of June 25, 2021.

For more information on this Accessibility Plan, please contact:
Lana Sinuk
Sea Air International, Controller
(905) 677-7701
lana.sinuk@seaair.ca.
1720 Meyerside Drive, Mississauga, ON L5T 1A3

Sea Air International Forwarders Limited Code of Ethics and Anti Corruption Policy

Sea Air International Forwarders Limited (Sea Air) has adopted this Code of Ethics (Code”) to:

  • encourage honest and ethical conduct, including fair dealing and the ethical handling of conflicts of interest;
  • encourage full, fair, accurate, timely and understandable disclosure;
  • encourage compliance with applicable laws and governmental rules and regulations;
  • ensure the protection of Sea Air’s legitimate business interests, including corporate opportunities, assets and confidential information; and
  • deter wrongdoing.

All directors, officers and employees of Sea Air are expected to be familiar with the Code and to adhere to those principles and procedures set forth in the Code.

Each director, officer and employee owes a duty to Sea Air to act with integrity. Integrity requires, among other things, being honest and ethical. This includes the ethical handling of actual or apparent conflicts of interest between personal and professional relationships. Deceit and subordination of principle are inconsistent with integrity.

Each director, officer and employee must:

  • Act with integrity, including being honest and ethical while still maintaining the confidentiality of information where required or consistent with Sea Air’s policies.
  • Observe both the form and spirit of laws and governmental rules and regulations and accounting standards.
  • Adhere to a high standard of business ethics.
  • Accept no improper or undisclosed material personal benefits from third parties as a result of any transaction or transactions of Sea Air.

A “conflict of interest” arises when an individual’s personal interest interferes or appears to interfere with the interests of Sea Air. A conflict of interest can arise when a director, officer or employee takes actions or has personal interests that may make it difficult to perform his or her Company work objectively and effectively. For example, a conflict of interest would arise if a director, officer or employee, or a member or his or her family, receives improper personal benefits as a result of any transaction or transactions of Sea Air.

Fidelity or service to Sea Air should never be subordinated to or dependent on personal gain or advantage. Conflicts of interest should be avoided. In most cases, anything that would constitute a conflict for a director, officer or employee also would present a conflict if it were related to a member of his or her family.

Sea Air does not make political contributions using corporate funds. The use by employees or directors of Sea Air’s financial resources for political purposes is strictly prohibited.

A “facilitating payment” is a payment made to a public or government official that acts as an incentive for the official to complete some action or process expeditiously, to the benefit of the party making the payment. In general, a facilitating payment, often illegal, is made to smooth the progress of a service to which the payer is legally entitled, without making such a payment.

The making of facilitating payments by Sea Air or any of its directors or employees is strictly prohibited.

The request for such a payment by any government official, client or vendor representative or any other person must be reported immediately to the President.

Each director, officer or employee, to the extent involved in Sea Air’s disclosure process, including the President and the Controller, is required to:

  • Familiarize himself or herself with the disclosure requirements applicable to Sea Air as well as the business and financial operations of Sea Air.
  • Not knowingly misrepresent, or cause others to misrepresent fact about Sea Air to others, whether within or outside Sea Air, including to Sea Air’s independent external accountants, government regulators or other government agencies.

It is Sea Air’s policy to comply with all applicable laws, rules and regulations. It is the personal responsibility of each employee, officer and director to adhere to the standards and restrictions imposed by those laws, rules and regulations in the performance of their duties for Sea Air, including those relating to accounting matters.

A director, officer or employee who is unsure of whether a situation violates this Code should discuss the situation with the President or Controller to prevent possible misunderstandings and embarrassment at a later date.

Each director, officer or employee must:

  • Notify the President or Controller promptly of any existing or potential violation of this Code.
  • Not retaliate against any other director, officer or employee for reports of potential violations.

Sea Air will follow the following procedures in investigating and enforcing this Code and in reporting on the Code:

The Controller will take all appropriate action to investigate any violations reported. In addition, the controller shall report each violation and alleged violation involving an employee, director or an executive officer to the President. To the extent he deems appropriate, the President shall participate in any investigation of a director or employee. Upon being notified that a violation has occurred, the President or the Controller, as the case may be, will take such disciplinary or preventive action as deemed appropriate, up to and including dismissal or, in the event of criminal or other serious violations of law, notification of the appropriate law enforcement authorities.

Directors and employees are prohibited from using corporate property, information or position for personal gain and from competing with Sea Air.

In carrying out Sea Air’s business, employees, officers and directors often learn confidential or proprietary information about Sea Air, its customers, suppliers, or joint venture parties. Employees, officers and directors must maintain the confidentiality of all information so entrusted to them, except when disclosure is authorized or legally mandated. Confidential or proprietary information of our Company, and of other companies, includes any non-public information that would be harmful to the relevant company or useful or helpful to competitors if disclosed.

We have a history of succeeding through honest business competition. We do not seek competitive advantages through illegal or unethical business practices. Each employee, officer and director must deal fairly with Sea Air’s customers, service providers, suppliers, competitors and employees. No employee, officer or director should take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any unfair dealing practice.

All employees, officers and directors should protect Sea Air’s assets and ensure their efficient use. All Company assets should be used only for legitimate business purposes.

Dear Valued Customers,
Accessibility for our customers with disabilities is important to us. We welcome your feedback. Please call 1.800.208.9409 or email accessibility@seaair.ca to share your comments, or request a copy of our accessibility policy.
Thank you.

These principles will be enacted in accordance with the “Sea Air Policy to Protect Personal Information” (the “Policy”).

Sea Air, its directors, officers, and employees, are required to comply with the principles and the Policy and will be given restricted access to personal information solely to perform the services provided by Sea Air.

Other persons or organizations who act for, or on behalf of, Sea Air are also required to comply with the principles and the Policy and will be given restricted access to personal information solely to perform the services provided for Sea Air.

Sea Air has designated a Privacy Officer. Any inquiry, request, or concern related to privacy matters should be made in writing to Sea Air.

Sea Air’s Privacy Officer may be contacted c/o:
Personal Information Compliance Officer
Sea Air
1720 Meyerside Drive
Mississauga, Ontario L5T 1A3 Canada