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Accessibility plan

Stingray Group Inc. (“Stingray”) is committed to providing quality facilities and services to its employees and clients in a manner that is accessible to persons with disabilities, and which respects the dignity and independence of persons with disabilities. This includes ensuring that persons with disabilities are not disadvantaged in any way from accessing Stingray facilities or services.  Under the Accessible Canada Act (the “ACA”), the Canadian Radio-Television and Telecommunications Commission Accessibility Reporting Regulations and the Accessible Canada Regulations (collectively, the “Regulations”), Stingray must establish a process for receiving and responding to feedback about how Stingray is implementing its accessibility plan and the manner in which Stingray provides facilities and services to persons with disabilities. Feedback should include information regarding the barriers encountered by persons dealing with Stingray.  Stingray must accept and respond to feedback (and when requested will do so using alternate formats or accessible communication supports).  The ultimate goal of the feedback process under this legislation is to ensure that Stingray identifies and removes existing barriers and prevents new barriers from arising. Information on this feedback process will be readily available and will include information about what actions are required to be taken after feedback is received. The feedback may consist of a suggestion, compliment or complaint relating to the accessibility of Stingray’s facilities or services.  Stingray will consult the individual providing the feedback to determine what is the most accessible or appropriate alternate format or accessible communication support.

Contents

Accessibility Plan
Accessibility Plan Progress Report
Accessibility Plan – Updated (2026)

Feedback Channels

 

Accessibility Plan

June 1, 2023

1. General

In 2019, the Accessible Canada Act (the “ACA”) came into force. Its purpose is to make Canada barrier-free by January 1, 2040, by identifying and removing barriers and preventing new ones. The ACA applies certain requirements to federally regulated entities, including the broadcasting sector by way of the Canadian Radio-television and Telecommunications Commission (“CRTC”). As a federally regulated, broadcasting entity, Stingray Group Inc. (“Stingray”) is committed to accessibility and believes that everyone, regardless of their ability, should have equal access to its services and applications. This Accessibility Plan (the “Plan”) has been developed and implemented in accordance with the principles set out in section 6 of the Accessible Canada Act with a view to resolving usability issues that may negatively impact people with disabilities and adopting inclusive design and testing practices to prevent them from happening again. The Plan reflects the efforts that have been made by Stingray to provide the highest level of accessibility to persons with disabilities by way of inclusive communication, hiring and promoting practices and general policies and programs.

(a) Position / title of the person designated to receive feedback about accessibility:

Senior Vice-President, General Counsel and Corporate Secretary

(b) Contact information for the public to communicate with the broadcasting entity:

Address:

Stingray Group Inc.
Attention: Lloyd Perry Feldman
730 Wellington
Montreal, Quebec
H3C 1T4

Telephone Number:
(514) 664-1244, ext. 2428

E-Mail address:
lfeldman@stingray.com

2. Executive Summary

Stingray is a premium provider of curated direct-to-consumer and B2B services, including audio television channels, over 100 radio stations, subscription video on demand (SVOD) content, 4K UHD television channels, karaoke products, digital signage, in-store music, and music apps. To make our digital offerings, web and mobile apps, accessible to everyone, including people with visual, auditory, motor, speech or cognitive disabilities, we will need to implement various forms of assistive technology or usability features, including (where appropriate) the continuous use of captions, alt-text for screen readers, zoom functions, simple presentation layouts and more. It is Stingray’s mission to review its web pages, channels and applications to ensure that all Canadians have equal access to the power of music!

3. Accessibility Summary

Stingray’s mission is to bring the power of music to the masses and provide a music service or channel for every moment, place, and mood. Certainly, making our services accessible for everyone will widen our available target audience and open new business opportunities. Moreover, optimizations made in UI/UX for accessibility also benefit people without disabilities, providing for a better overall user experience.

4. Areas of Accessibility

4.1 Provisions of any Regulations made under Subsection 10(1) of the Broadcasting Act

Describe the provisions of any Regulations that relate to the identification and removal of barriers and the prevention of new barriers:

Stingray has not been the subject of any Regulations made under Subsection 10(1) of the Broadcasting Act.

4.2 Barriers by Area:

Stingray policies, programs, practices, and services in relation to the identification and removal of barriers (and the prevention of new barriers) in the following areas are discussed below:

(a) Employment

Stingray does not discriminate when engaging employees. Indeed, Stingray is committed to diversity in recruitment, retention, promotion, and in providing an accessible environment. Diversity gives our business a competitive edge.

Stingray takes proactive measures to eliminate barriers for individuals with disabilities by conducting Employment Systems Reviews, reviewing its processes, and consulting with employees. Every time new policies or tools are introduced, they are evaluated to ensure they do not create any additional barriers for people with disabilities.

Stingray’s commitment to diversity and willingness to provide accommodations where required are also communicated to prospective employees on all recruitment materials. The Company has robust anti-discrimination policies and provides information to all staff and managers in this regard. Stingray is committed to reasonable accommodations that allow individuals with a disability to apply for a job, perform the essential functions of the job, and enjoy equal access to benefits available to other Stingray employees in the workplace. Stingray understands that successful accommodations require an interactive process between the employer and the employee, and Stingray stands ready to accommodate all qualified employees and candidates. Accommodation policies are comprehensive and lay out a simple and objective methods for requesting and assessing requests for accommodation.

Stingray also provides a comprehensive extended medical insurance plan, including the access to a telehealth platform to promote wellness and support our employees with disabilities.

(b) The Built Environment

Stingray’s Montreal headquarters, Toronto offices and nearly all satellite offices and facilities in each Province across Canada are fully accessible to employees and other individuals with physical disabilities.

When considering the procurement of new facilities, renewal of leases, or renovation of existing spaces, the project manager will include consideration regarding accessibility for Stingray’s employees and visitors.

Stingray has systems in place that would allow almost every employee to work remotely if needed, and Stingray has made available the information communication technologies and policies to accommodate full and/or part-time remote or telework opportunities. Stingray also offers flexibility in work schedules where required.

Consultations with employees highlighted an opportunity to better utilize vacant space in some of our offices to offer quiet working spaces that could be available to be utilized from time to time by employees with sensory and certain psychological impairments.

Consultations with employees with disabilities have also highlighted a significant barrier in several of our smaller Rural Alberta facilities where our offices are located on the second floor of a building without an elevator, and in our Edmonton location where all studios are one step up. Additionally, the entrance to our Ottawa offices is difficult to access for people who use wheelchairs. Local teams will investigate options to eliminate these barriers with fixes in the short term where possible (ramps etc.), but others will require longer term planning. While Stingray’s Montreal headquarters are fully accessible to employees and other individuals with disabilities (as noted herein), consultations with employees have called attention to the need for an additional wheelchair accessible entrance to the office building which Stingray shares with other (third party) tenants. Stingray is currently investigating solutions, with a view to improving accessibility by way of adding an additional wheelchair accessible entrance in the short term.

As a potential barrier, Stingray also recognizes that photocopy machines cannot be easily accessed by individuals who use wheelchairs if the controls are not easy to reach and the systems are not at an accessible height. Similarly, those who have low vision cannot access instructions and labels available only in small print. Those who are blind cannot access instructions presented only in visual form. Accordingly, Stingray will undertake to ensure that these machines (and all office equipment/tools) are adapted and/or replaced with accessible machines and equipment in due course as the applicable equipment leases expire. Over the course of the next three years, this potential barrier will be removed.

(c) Information and Communication Technologies

Stingray considers itself as a leading technology company. As such, Stingray does and will make available to its employees all manner of adaptive and assistive technology, comprising a wide range of devices, that allow individuals with disabilities to access computers. It includes mini-, expanded, and other alternative keyboards; speech input systems; and alternatives to a standard mouse. For individuals with visual impairments, Stingray provides software for enlarging screen images; in addition, speech output systems for reading text presented on the screen. Similarly, for employees who are deaf or hard of hearing, Stingray will provide adaptive and assistive telecommunication devices.

Stingray also provides multiple communication channels that are accessible to people with disabilities, including email, telephone, video conference and Teams text messaging. These communication channels are compatible with assistive technologies.

Consultation with employees with disabilities indicated the need to ensure written corporate communication is concise, and point form where possible in order to be more accessible to employees with dyslexia. We will also look at ways to prevent the potential stigma faced by employees who are hearing impaired and less likely to engage during larger group meetings.

(d) The Procurement of Goods, Services, and Facilities

Stingray has always been sensitive to the needs of individuals with disabilities and has generally accommodated employees on a one-to-one basis, ensuring an accessible work environment and providing adaptive and assistive technologies to employees with disabilities on an “as needed” basis. However, to ensure the prevention of new barriers, Stingray undertakes to develop and institute a new procurement policy that will have accessibility criteria incorporated. This new procurement policy will adopt a flexible approach, with three primary considerations: (i) considering accessibility before making a purchase (to avoid costly retrofitting in the future); (ii) consider accessibility over the entire lifecycle of the goods, services, or facilities to be procured; and (iii) consultations with employees with disabilities and stakeholders (to involve the people who will use a product, service, or facility). The key question for Stingray will be: “Can people with disabilities use or benefit from the proposed goods or services on an equitable basis?”; and in the case of new facilities: “Is the proposed facility or infrastructure barrier-free and accessible?” Stingray expects to have a new procurement policy in place within the next twelve to eighteen months.

(e) The Design and Delivery of Programs and Services

As a leading global music company, many of stingray’s products and services are audio (Stingray Music) or audio-visual (short form music videos, long form concerts and documentaries, karaoke). Where possible, Stingray provides closed captioning for its audio-visual products for customers with hearing impairments. Indeed, many of Stingray’s distribution platforms in Canada and the United States already require closed captioning of all audio-visual content.

As mentioned hereinabove, to make Stingray’s digital offerings, web and mobile apps, accessible to everyone, including people with visual, auditory, motor, speech or cognitive disabilities, we will need to implement various forms of assistive technology or usability features, including (where appropriate) the continuous use of captions, alt-text for screen readers, zoom functions, simple presentation layouts and more. In this connection, Stingray’s economic interests are well-aligned with the ACA, as optimizations made in UI/UX for accessibility also benefit people without disabilities, providing for a better overall user experience. As such, Stingray undertakes to continually review and optimize its digital offerings, web and mobile apps to ensure that all barriers are removed and to prevent the creation of new barriers. We hope and expect that customer feedback and direct consultation with stakeholders will help Stingray identify barriers that have not already been remedied.

(f) Transportation

Stingray does not provide transportation services. However, we subsidize part of the monthly cost of public transit passes.

4.3 Licence Conditions under Part II of the Broadcasting Act

Describe any licence conditions that relate to the identification and removal of barriers and the prevention of new barriers.

None of Stingray’s licence conditions relate to the identification and removal of barriers and the prevention of new barriers:

4.4 Provisions of any order made under Subsection 9.4 of the Broadcasting Act

Describe the provisions of any order that relate to the identification and removal of barriers and the prevention of new barriers:

Stingray has not been the subject of any orders made under Subsection 9.4 of the Broadcasting Act.

5. Consultations

Describe the manner for conducting consultations with persons with disabilities in the preparation of the document:

Stingray has been collecting and collating feedback received from its employees and B2B and B2C customers for years, including employees and customers with disabilities, with a view to: (a) improving accessibility, (b) removing barriers; and (c) optimizing our digital offerings, web and mobile apps. More recently, Stingray has undertaken to formalize the consultation process and involve persons with disabilities in this process. Simultaneously to its publication, Stingray will share this document with its employees who identify as disabled and has reached out to organizations that represent or provide support to individuals with disabilities, seeking broader community feedback regarding Stingray’s services. The results of these consultations will be shared in our annual progress report.

In April and May 2023, Stingray Radio and Stingray Group inc. conducted a confidential survey of all employees asking specifically employees with disabilities to describe any barriers that they have or currently face in their employment with Stingray as part of the preparation of this Plan. Employees were also given the option to provide the feedback directly to HR or their manager verbally, by phone, Teams, or through email. 6% of Radio respondents and 9% of Stingray Group inc. respondents were people with disabilities, and results of the consultations are noted throughout this Plan.

Stingray also consults with employees on a weekly basis through an anonymous employee survey tool. Employees can provide suggestions, interact with their managers and HR on an anonymous basis, and answer questions on a variety of topics surrounding employee engagement that include safety, discrimination, and inclusivity.

 

Accessibility Plan Progress Rerport

May 30, 2025

1. General

The Accessible Canada Act (the “ACA”), enacted in 2019, charts a course for a barrier-free Canada by January 1, 2040. This legislation establishes requirements for federally regulated entities, including those in the broadcasting sector overseen by the Canadian Radio-television and Telecommunications Commission (“CRTC”). Stingray Group Inc. (“Stingray”), as such an entity, is deeply committed to accessibility, championing the principle that everyone, regardless of ability, should enjoy equal access to our services and applications. Our Accessibility Plan (the “Plan”), introduced in June 2023, was developed in alignment with the ACA’s core principles. It focuses on resolving usability issues that can negatively affect people with disabilities and on embedding inclusive design and testing practices to prevent new barriers. This year’s Progress Report highlights Stingray’s dedicated efforts to advance accessibility through inclusive communication, equitable hiring and promotion practices, and comprehensive policies and programs.

(a) Position / title of the person designated to receive feedback about accessibility:

Senior Vice-President, General Counsel and Corporate Secretary

(b) Contact information for the public to communicate with the broadcasting entity:

Address:

Stingray Group Inc.
Attention: Lloyd Perry Feldman
730 Wellington
Montreal, Quebec
H3C 1T4

Telephone Number:
(514) 664-1244, ext. 2428

E-Mail address:
lfeldman@stingray.com

2. Executive Summary

Stingray, a global music, media, and technology company, is an industry leader in TV broadcasting, streaming, radio, business services, and advertising. Stingray provides an array of music, digital, and advertising services to enterprise brands worldwide, including audio and video channels, 97 radio stations, subscription video-on-demand content, FAST channels, karaoke products and music apps, and in-car and on-board infotainment content. Stingray Business, a division of Stingray, provides commercial solutions in music, in-store advertising solutions, digital signage, and AI-driven consumer insights and feedback. Stingray Advertising is North America’s largest retail audio advertising network, delivering digital audio messaging to more than 30,000 major retail locations. Stingray has close to 1,000 employees worldwide and reaches 540 million consumers in 160 countries. It is Stingray’s mission to ensure that all Canadians have equal access to the power of music!

3. Progress Report Summary

Enhancing accessibility and dismantling barriers for individuals with disabilities has remained a persistent focus for our organization in the last year. This commitment is evident in the continuous improvement of our physical spaces, where facility upgrades are designed to boost building accessibility and foster a more inclusive atmosphere for both employees and visitors. Furthermore, our dedication to accessibility and usability is demonstrated through ongoing efforts to integrate and refine innovative IT solutions, which offer meaningful support to people with disabilities. Finally, we continued to grow our national partnership with MentorAbility Canada and the Canadian Association for Supported Employment hosting mentorships, training opportunities, and participating on the Abilities at Work Advisory Committee.

4. Areas of Accessibility

Progress by Area:

Below is an overview of Stingray’s advancements in carrying out its Accessibility Plan, including efforts to identify and eliminate existing barriers, as well as to prevent the emergence of new ones across the following areas:

(a) Employment

A core tenet at Stingray is the cultivation of an inclusive work environment, achieved by embedding non-discriminatory principles throughout every facet of employment. We are actively working to champion diversity within our recruitment, retention, and career advancement frameworks, alongside our efforts to ensure a universally accessible setting for all team members. Our commitment to a diverse workforce serves a dual purpose: it contributes to a vibrant internal culture and supports our broader business objectives. Stingray requires all employees to fill out a mandatory self-identification form, which allows us to have a better understanding of our population and ensure we put all necessary effort into fostering a diverse workforce.

Stingray continues to offer a comprehensive extended medical insurance plan, including access to a telehealth platform to promote wellness and support our employees with disabilities. Stingray Radio holds semi-annual employee information sessions promoting its Employee and Family Assistance Plan, which provides free and confidential support to all employees and their families including mental and physical health and wellness programs.

In addition, in early 2025, we organized a workshop on stress management. Hosted by Dialogue at our offices, this workshop was open to all employees and provided practical strategies to support mental health in the workplace.

We also launched a Manager Assistant Program (“MAP”) with TELUS Health, granting managers access to 24/7 counseling in-person, online or by phone, ensuring that all managers can access services via their preferred or required medium. Managers also have the option of referring their employees to the program, further extending the benefit and support to employees in need. Services include relational coaching, legal and financial counseling, and crisis management.

Stingray’s continued implementation of new IT technologies, discussed in section (c) below, continues to provide innovative solutions for its employees who live with disabilities to overcome barriers and thrive in their day-to-day work.

Over the past year, Stingray has grown its relationship with MentorAbility Canada, becoming a national partner. A national campaign was launched within Stingray’s Radio division to promote MentorAbility’s mandate of offering tailored, short-term mentoring opportunities (ranging from 1 hour to 1 day) that connect employers with individuals experiencing disabilities. In connection with MentorAbility’s hubs across Canada, this past year Stingray hosted mentoring sessions in New Brunswick, BC, and Newfoundland & Labrador, with plans in place for future mentorships in Ontario, Alberta and PEI. Stingray also offered all Radio employees training on how to be a mentor, disability awareness and etiquette, as well as best practices to ensure mentorships are positive, inclusive experiences for all involved.

Stingray’s Senior Director of HR for Radio joined The Abilities at Work Advisory Team, a group of Canadian employers who convene monthly to exchange knowledge, network, and collaboratively develop solutions that enhance business success by improving accessibility in talent recruitment and retention processes. This has provided valuable learnings this year – particularly research presented by the Conference Board of Canada regarding disability disclosure in Canada – which informed changes to Stingray’s practices surrounding accommodations. Stingray’s HR team also attended Accessibility Canada’s webinar series for National Accessibility Week.

(b) The Built Environment

The Montreal headquarters, Toronto offices, and most satellite offices and facilities across provinces in Canada are accessible to employees and individuals with physical disabilities.

Stingray continues to improve the accessibility of its facilities, including the following updates this year:

  • Initiation of a project to enhance accessibility at the Montreal headquarters including the planned installation of an elevator at the Prince Street entrance to improve access for people with mobility challenges.
  • Significant renovations to our Edmonton operations which included widening of doorways, elimination of steps, brighter and contrasting paint colours on the walls, incorporation of natural light, and dimmable LED lighting.
  • Updating its accommodation practices to remove red tape (ex: doctor’s notes) for certain accommodation requests.
  • Creating new workspaces to be used by employees who require a quiet space.
  • Relocating our Sydney, NS operations to new offices that are 100% accessible to people with mobility challenges, the former location was not.
  • Repaving outdoor pathways to ensure an even walking surface.
  • Providing full at-home setups for employees requiring work-from-home accommodations.
  • Replacing fluorescent lighting with LED daylight lighting which is less harmful to people with light sensitivity.
  • Procuring and installing additional standing desk supports to better accommodate individual needs.

Accessibility considerations for both employees and visitors are consistently prioritized in the management of new property acquisitions, lease renewals, and space updates, with the project manager overseeing their integration into each phase of decision-making.

Stingray continues to provide employees alternate work areas including quiet working spaces and a small dedicated standing desk area which may be preferable for those who experience certain sensory and/or psychological conditions.

(c) Information and Communication Technologies (ICT)

Stingray’s ongoing support for individuals with disabilities includes providing the adaptive and assistive tools necessary for effective computer use. In addition to specialized physical hardware accommodations such as alternative keyboards, adaptive mice, and large-format monitors, Stingray leverages the comprehensive suite of built-in accessibility features available across our workstations operating systems. Built-in features include visual accessibility tools such as display customization, color filters, and eye control navigation; hearing support through live captions and sound customization; mobility assistance via voice access commands and on-screen keyboards; and cognitive aids including Focus Assist and Immersive Reader.

Stingray regularly updates these systems to incorporate the latest accessibility innovations, ensuring our workplace technology remains inclusive and accessible to all employees regardless of ability.

Our video conferencing platforms feature built-in accessibility tools that enable inclusive remote collaboration for all participants, including those with hearing impairments or language differences. While some employees already have access to the transcript feature, Stingray will not hesitate to purchase additional licenses for any employee who requires this accommodation.

In early 2025, Stingray began actively monitoring and preparing for the rollout of new accessibility features in Windows 11 and macOS, including enhanced eye control navigation, AI-powered voice recognition improvements, and expanded sign language support in video conferencing. We are committed to implementing these advancements as soon as they become available, further strengthening our inclusive digital workplace.

As part of our ongoing efforts to enhance digital accessibility, we introduced the Personal Email Assistant, SweetPea- an intelligent tool designed to streamline email management. By automatically processing, sorting, and filtering out non-essential messages, SweetPea significantly reduces cognitive load and digital “noise.” This creates a more focused and manageable communication environment, which is especially helpful for employees who are sensitive to information overload or who experience difficulties processing large volumes of information. SweetPea complements our broader accessibility strategy by supporting clearer, more efficient digital interactions for all users.

In addition, we continue to leverage Sonata, our in-house developed AI assistant, quickly became an essential tool for simplifying access to information, automating tasks, and improving interaction with our enterprise systems. With its conversational interface and intelligent search capabilities, Sonata aims to eliminate barriers and make Stingray’s digital work environment more intuitive, efficient, and accessible for all employees, unique needs.

Sonata boosts productivity while also playing a pivotal role in fostering an accessible workplace. It offers features such as text-to-speech, speech-to-text, language translation, and routine task automation, helping employees with diverse needs fully engage with their work. Sonata further supports document accessibility through alternative formats and enhances virtual meetings with features like live captioning, ensuring participation for employees with hearing impairments.

The customizable interface of Sonata accommodates individual preferences for visibility and interaction, further enhancing usability for people with various accessibility needs. Its compatibility with a wide range of assistive technologies ensures that all employees can benefit from its features, promoting inclusivity and support in every aspect of their work environment.

Over the past year, our efforts have centered on enhancing and expanding the accessibility of Sonata’s capabilities. Deeper integration with key platforms such as Confluence, Tableau, SharePoint, and Jira has made Sonata’s assistance more readily available within employees’ daily workflows. This streamlined access not only improves efficiency but also reduces the need to navigate multiple systems—an important advancement for employees who may face barriers when using traditional digital interfaces. These ongoing improvements are designed to foster a more inclusive and supportive digital environment for all team members.

Looking ahead, improvements to Sonata will continue to enhance its effectiveness, further supporting employees who may encounter obstacles with traditional systems or information retrieval.

(c.1) Communication, other than ICT

Stingray continues to use a range of communication channels to keep our employees informed and engaged. Whether through email updates or in-person events such as town halls, we make certain that our communication methods are accessible to everyone. A consistent part of this effort is including alternative text for images, which aids individuals with visual impairments. In addition, important updates and announcements are regularly displayed on large digital screens located on each floor, helping to ensure that information is visible, timely, and accessible throughout the workplace. These screens serve as an additional touchpoint, particularly useful for employees who may miss emails or prefer visual communication. Together, these practices reflect Stingray’s broader commitment to inclusion—creating an environment where all employees can stay informed, feel supported, and fully participate in the workplace community.

(d) The Procurement of Goods, Services, and Facilities

Stingray actively fosters an accessible workplace, consistent with our Accessibility Plan. We provide individualized support, including necessary assistive technologies and ergonomic equipment, tailored to the specific needs of employees with disabilities. Our strategy for enhanced accessibility includes establishing a new procurement policy. Though the formal policy is still in development, it is founded on key tenets which Stingray has already incorporated into its procurement practices: integrating accessibility from the start for equal utility and barrier-free design, comprehensive lifecycle accessibility checks, and engaging stakeholders. This approach ensures our procurement decisions actively foster universal accessibility.

(e) The Design and Delivery of Programs and Services

Operating as a global music company, Stingray’s products and services are primarily audio (Stingray Music) or audio-visual (such as short-form music videos, long-form concerts and documentaries, and karaoke). For its audio-visual products, Stingray provides closed captioning to support customers with hearing impairments. As mentioned last year, many of Stingray’s distribution platforms in Canada, the United States, and Europe already require closed captioning for all audio-visual content.

Stingray has maintained its commitment to reviewing and optimizing its digital offerings, including web and mobile applications, to remove existing barriers and prevent the creation of new ones. We continue to welcome customer feedback and direct consultation with stakeholders to identify and address any remaining accessibility barriers.

This year, Stingray has also begun developing in-car products. On platforms such as Android Automotive OS (AAOS), our applications support the accessibility features provided by the operating system by default, ensuring an inclusive experience for all users.

(f) Transportation

Stingray does not provide direct transportation services. We do, however, maintain a program that partially covers the monthly cost of public transit passes for our team members.

5. Consultations

Stingray once again formally sought feedback from its employees who experience disability through an anonymous employee survey of the Radio division. The survey focused on two main questions:

  • What, if any, barriers do you encounter in your employment with Stingray?
  • What suggestions, if any, do you have that would improve accessibility at Stingray for people experiencing a disability?

83% of the respondents identified themselves as people who experience a disability. Overall, most respondents indicated that they do not encounter barriers at Stingray. Other responses highlighted some opportunities to continue to promote awareness and best practices with respect to:

  • Understanding “invisible disabilities” including hearing loss and chronic fatigue
  • Tailoring written communication to be accessible for people with dyslexia (concise, point form)

Stingray continues to engage all permanent employees through anonymous bi-weekly pulse surveys, providing a confidential platform for staff to share suggestions, communicate with managers and HR, and respond to questions on topics such as employee engagement, safety, discrimination, and inclusivity.

6. Feedback

Stingray continues to use a range of communication channels to keep our employees informed and engaged. Whether through email updates or in-person events such as town halls, we make certain that our communication methods are accessible to everyone. A consistent part of this effort includes alternative text for images, which aids individuals with visual impairments.

Throughout the recent year, Stingray noted no submissions of comments or concerns via its public feedback avenues pertaining to the Accessibility Plan, its rollout, or any impediments individuals met while engaging with the organization.

7. Conclusion

Across the organization, Stingray’s dedication to improving accessibility and eliminating barriers remains steadfast. Looking ahead, we will continue to introduce inventive measures and improvements that drive our accessibility goals, further solidifying our commitment to a universally supportive environment where everyone can thrive.

 

Accessibility Plan – Updated 2026

June 1, 2026

1. General

Stingray Group Inc. (“Stingray”) is committed to creating a barrier-free environment for its employees, clients, and community, in alignment with the principles of the Accessible Canada Act (“ACA”). This three-year strategic plan outlines our approach to identifying, removing, and preventing accessibility barriers across our operations.

Stingray has made progress in identifying and addressing accessibility barriers. However, we recognize that more work is needed. This plan details specific, actionable goals for the 2026-2029 period. Key initiatives include enhancing physical infrastructure at our offices, advancing digital accessibility in our products and internal tools, and strengthening our inclusive hiring and accommodation processes.

(a) Position / title of the person designated to receive feedback about accessibility:

Senior Vice-President, General Counsel and Corporate Secretary

(b) Contact information for the public to communicate with the broadcasting entity:

Address:

Stingray Group Inc.
Attention: Lloyd Perry Feldman
730 Wellington
Montreal, Quebec
H3C 1T4

Telephone Number:
(514) 664-1244, ext. 2428

E-Mail address:
lfeldman@stingray.com

2. Executive Summary

Stingray Group Inc. (TSX: RAY), the world’s leading connected streaming media company, delivers the best curated audio and video content to consumers worldwide. As a pioneer in multiplatform streaming and distribution, Stingray’s vast digital content portfolio includes thousands of live audio and radio stations, premium music channels, concerts and music documentaries, karaoke products, as well as ambience and wellness channels. Its offering is distributed via connected TVs, smart speakers, mobile, connected cars and retail. Reaching hundreds of millions of consumers every month, Stingray’s products offer an unparalleled advertising reach, enabling brands to connect with an engaged audience across the world. Home to globally renowned brands such as TuneIn, Singing Machine, Stingray Karaoke and Qello Concerts, Stingray is powered by a worldwide team of more than 1,000 employees.

To make our digital offerings, web and mobile apps, accessible to everyone, including people with visual, auditory, motor, speech or cognitive disabilities, we will need to implement various forms of assistive technology or usability features, including (where appropriate) the continuous use of captions, alt-text for screen readers, zoom functions, simple presentation layouts and more. It is Stingray’s mission to review its web pages, channels and applications to ensure that all Canadians have equal access to the power of music.

3. Accessibility Commitment

Stingray demonstrates a strong commitment to accessibility for both users of its services and its employees by aligning its practices with the foundational principles set out in Canadian accessibility regulations. This commitment is reflected in its efforts to design inclusive programming, accessible digital platforms, and equitable workplace policies that support individuals with diverse needs.

In preparing this Accessibility Plan, Stingray actively integrated the principles set out in Section 6 of the Accessible Canada Act to guide our methodology and strategic priorities. The principle that people with disabilities must be involved in the development of policies and programs (Principle f) was central to our approach; we directly consulted our employees who experience disabilities through anonymous surveys, focus groups, and one-on-one conversations to identify existing barriers and shape the initiatives outlined in this document. Furthermore, the principles of barrier-free access (Principle c) and achieving the highest level of accessibility (Principle g) drove our decision to conduct comprehensive audits of both our physical workspaces and digital infrastructure, ensuring our goals target the most impactful areas for improvement. Finally, by recognizing the diverse ways individuals interact with their environments (Principle e), we tailored our planned accommodations and digital tool enhancements to provide meaningful options (Principle d) that respect the dignity (Principle a) and promote the equal opportunity (Principle b) of every Stingray employee.

4. Areas of Accessibility

4.1 Provisions of any Regulations made under Subsection 10(1) of the Broadcasting Act

While Stingray is not the subject of any bespoke accessibility orders or regulations made exclusively for it under Subsection 10(1) of the Broadcasting Act, our broadcasting undertakings comply with the CRTC’s standard regulatory requirements and conditions of service relating to accessibility. This includes adhering to industry standards for the provision of closed captioning across our applicable audio-visual platforms, ensuring the continuous identification and removal of barriers for persons with hearing impairments.

4.2 Barriers by Area:

Stingray policies, programs, practices, and services in relation to the identification and removal of barriers (and the prevention of new barriers) in the following areas are discussed below:

(a) Employment

Stingray is committed to fostering a workplace where all employees, including those with disabilities, can thrive. We will focus on removing barriers in our employment practices, policies, and culture.

Standardizing Accommodation Processes: We will review and formalize our employee accommodation process to ensure it is transparent, confidential, and consistently applied. This will empower employees to request the support they need with clarity and confidence. In addition, we will track accommodation requests to identify recurring needs, trends, and systemic barriers, enabling us to implement broader, proactive solutions where possible and reduce the need for individual requests over time.

Enhancing Inclusive Hiring: Our talent acquisition team will continue to refine our recruitment, assessment, and onboarding processes to ensure they are inclusive and accessible, enabling us to attract and retain a diverse and talented workforce. To support this, we will ensure that our recruitment and selection training materials for hiring managers explicitly cover best practices for inclusive hiring and mitigating unconscious bias.

Promoting Employee Wellness and Support: We will launch initiatives to increase awareness and adoption of our Employee Assistance Program (EAP). Furthermore, we will explore new wellness initiatives, such as establishing a dedicated wellness space and formalizing a policy for ergonomic equipment like standing desks, to support the well-being of all employees. We will provide training to all employees and managers during the plan term on the topic of promoting an inclusive workplace free of discrimination.

Celebrating Diversity: Stingray is committed to celebrating diversity through the lens of persons with disabilities by actively recognizing and amplifying their contributions across the organization. This includes sharing success stories from MentorAbility mentorships, highlighting the achievements of employees from diverse backgrounds, and fostering an inclusive culture where all voices are valued. Stingray also strengthens its community impact by engaging with partners such as the Canadian Mental Health Association (CMHA), Special Olympics, and the United Way, supporting fundraising and other initiatives that advance awareness and support for people with disabilities.

(b) The Built Environment

We are dedicated to ensuring our physical spaces are safe and accessible for everyone.

Improving Physical Access at our Montreal Headquarters: We have taken meaningful steps to improve the physical accessibility of our Montreal headquarters, including upgrading the 1st-floor bathroom sink. We have also validated the accessibility of our fleet of multifunction printers. While we have already upgraded several units to fully compliant Konica devices designed for users with reduced mobility, we are committed to replacing the remaining units across our offices wherever accessibility demands require it. Building on this momentum, we will complete the planned access ramp project to provide a barrier-free entrance.

Enhancing Emergency Preparedness: Stingray is committed to the safety of all employees, including those with reduced mobility. In accordance with applicable legal obligations, we will make the necessary arrangements to ensure that appropriate emergency evacuation provisions are in place for all employees present on-site. This includes developing individualized Personal Emergency Evacuation Plans (PEEPs) and/or a buddy system, leveraging designated Areas of Rescue Assistance and trained staff support, in consultation with our safety committee. Flexible and remote work arrangements, and other accommodations as necessary, may also be offered as an accommodation measure, where appropriate.

Accessibility Audits: We will continue to expand our role as National Partner for the MentorAbility program and during this plan term, we will partner with them as they develop comprehensive accessibility audit materials which will be used at all Stingray Radio locations.

(c) Information and Communication Technologies

Stingray will ensure that our digital tools and technologies empower, rather than hinder, our employees.

Adopting Web Accessibility Standards: We will formally adopt the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA as our standard for employee-facing web pages and applications. We will also continue to make progressive improvements across our broader digital tools.

Preparing for New Federal Digital Accessibility Requirements: We will provide accessibility training to relevant employees, ensure our employee-facing web pages and applications meet recognized accessibility standards, offer alternative means of access where full conformance is not feasible, prepare for the timely publication of an accessibility statemen, and maintain proper records to support compliance.

Enhancing Internal Tool Accessibility: We will research and propose accessibility enhancements for our internal platforms, including exploring vocal command functionalities for our internal AI tool Sonata, to ensure all employees can collaborate and work efficiently.

Establishing a Digital Accessibility Training Program: We will put in place a training program on the fundamentals of digital accessibility for employees who develop, maintain, or purchase digital technologies. The program will draw on recognized resources from established industry providers and will be refreshed regularly to keep our teams current.

Inventorying Employee-Facing Digital Properties: We will take inventory of our employee-facing web pages and applications to identify the digital tools covered by the new requirements. New employee-facing web pages and applications, as well as updates to existing ones, will be designed to meet WCAG 2.1 Level AA standards going forward.

Building a Periodic Accessibility Review Process: Over time, we will gradually put in place a process for periodic accessibility reviews of our employee-facing web pages and applications. The goal of these reviews is to help us identify gaps against WCAG 2.1 Level AA criteria and remediate them as needed.

Publishing an Accessibility Statement: We are currently evaluating our digital ecosystem and internal processes to prepare for the publication of a comprehensive, public-facing accessibility statement ahead of the December 2028 regulatory deadline. Once published, the statement will describe the accessibility features we have in place, provide a contact for accessibility-related questions, note any known gaps and the alternative means of access we offer to address them, and outline our roadmap and timelines for closing those gaps. The statement will be reviewed and refreshed at least annually.

(d) The Procurement of Goods, Services, and Facilities

To ensure accessibility is seamlessly integrated into our operations, we are embedding accessibility criteria into our overall procurement and infrastructure strategy. Within the next 12-18 months, we will implement guidelines requiring that accessibility be a decision point in the acquisition of all goods, services, and facilities. This proactive approach extends to our physical spaces; when leasing new facilities, such as our upcoming upgrades in Kelowna, BC, and Sydney, NS, we prioritize locations that already incorporate barrier-free design features, ensuring an inclusive environment from the outset.

(e) The Design and Delivery of Programs and Services

Our commitment to accessibility extends to the programs and services we deliver to our customers.

Reviewing Radio Programming Accessibility: Accessibility of Stingray Radio’s programming to listeners experiencing disability continues to improve with increased multiplatform listening options. All Stingray Radio stations are available on various websites and streaming applications, including Stingray-owned TuneIn, a streaming app with built-in accessibility features including screen reader compatibility, keyboard navigation, and adjustable playback speeds. TuneIn is also compatible with smart speakers and iOS/Android accessibility features. During the Plan term we will also provide training on improving clarity and structure of spoken content, and accessible social media posts.

Ensuring Accessible Digital Content: We will continue to enhance the accessibility of our digital products by consistently implementing features such as closed captions, alt-text for images, zoom functions, and clear, simple layouts.

(f) Transportation

Stingray does not provide transportation services. However, we subsidize part of the monthly cost of public transit passes.

4.3 Licence Conditions under Part II of the Broadcasting Act

Describe any licence conditions that relate to the identification and removal of barriers and the prevention of new barriers:

None of Stingray’s licence conditions relate to the identification and removal of barriers and the prevention of new barriers.

4.4 Provisions of any order made under Subsection 9.4 of the Broadcasting Act

Describe the provisions of any order that relate to the identification and removal of barriers and the prevention of new barriers:

Stingray has not been the subject of any orders made under Subsection 9.4 of the Broadcasting Act.

5. Consultations

Consultation is at the heart of our accessibility strategy. We believe that meaningful progress can only be achieved by listening to and learning from the lived experiences of people with disabilities.

Employee Feedback: We will continue to use anonymous feedback tools like our weekly Officevibe survey to gather ongoing input. We also create more direct opportunities for employees with disabilities to share their perspectives and help shape our initiatives. In the preparation of this plan, we conducted an anonymous employee survey directed at employees living with disabilities about workplace barriers, accommodation experiences, and ideas for improvement. We also offered focus groups and one-on-one conversations. We will continue to consult all employees on an annual basis, as well as semiannually, through our Employment Equity Committees.

External Partnerships: We will collaborate with organizations, such as the Canadian Association for Supported Employment and their MentorAbility program to benefit from their expertise and ensure our plan is aligned with best practices. Stingray’s Senior Director of Human Resources continues to participate in the MentorAbility’s Abilities at Work committee – an advisory committee of national employers that meets on a semi-monthly basis to discuss initiatives, research, and support each other in the areas of accessibility and inclusivity for people experiencing disability.

Neurodiversity and Workspace Audit: Recognizing the importance of cognitive diversity, we are partnering with NeuroPlus to conduct a comprehensive audit of our workspaces. This assessment will evaluate our offices both from a physical accessibility standpoint and through a neurodivergent lens. The insights gained will help us develop a robust strategy to support our neurodivergent employees and create an environment where everyone can perform at their best.

Transparent Process: We are committed to a transparent consultation process. We will clearly document who we consulted with (while protecting privacy), the topics discussed, the methods used, and, most importantly, how the feedback we received was actioned in this plan and its implementation.

 

Feedback Channels

Stingray’s feedback process will take a person’s disability into account by permitting more than one way to provide feedback whether in person, by telephone, in writing, by email, on portable media or some other format accessible to the person providing feedback. Where an individual asks Stingray to receive and respond to feedback using alternate formats or accessible communication supports, Stingray will consult with the individual to determine a suitable method of communication. Employees and customers are invited to provide their feedback:

For Stingray Group Inc
  • In person at Stingray’s office located at: 730 Wellington, Montreal, Quebec, H3C 1T4
  • By telephone at (514) 664-1244, extension #2694 (Human Resources Director)
  • By mail in writing at: 730 Wellington, Montreal, Quebec, H3C 1T4 (attention Human Resource Director)
  • By e-mail at hr@stingray.com
For Stingray Radio Inc.
  • In person at Stingray Radio Inc.’s Toronto office located at: 2 St. Clair W., Suite 1000, Toronto, Ontario, M4V 1L5
  • By telephone at (778) 478-2223, (Jane Krindle, Human Resource Director)
  • By mail in writing at: 2 St. Clair W., Suite 1000, Toronto, Ontario, M4V 1L5 (attention Jane Krindle, Human Resource Director)
  • By e-mail at jkrindle@stingray.com

When feedback is provided via any of the foregoing channels, the following information is helpful:

  • Time and date
  • Description of interaction, suggestion or complaint
  • Additional comments
  • Contact information (if the person wishes to hear further in this matter)
  • Preferred alternate format or accessible communication support (as applicable).

Responding to Feedback

All feedback will be treated confidentially. Stingray will register the feedback if the matter cannot be resolved immediately. Stingray will acknowledge all feedback within two business days and will thereafter provide a timeframe for resolution or redress. Stingray will follow-up with any required action within the timeframe noted in the acknowledgement. Information on all feedback received (formal or informal), and any actions taken will be tracked and reported in Stingray’s annual progress reports.

In addition to the foregoing, in connection with the formulation and implementation of its accessibility plan, Stingray will proactively solicit feedback from its employees with disabilities and will seek additional input from organizations that support and provide assistance to persons with disabilities.