SETTLEMENT AGREEMENT BETWEEN THE UNITED STATES OF AMERICA AND ATLANTIS EVENTS, INC. UNDER THE AMERICANS WITH DISABILITIES ACT

B. Adoption and Implementation of ADA Accessibility Policy

17. As of the effective date of this Agreement, Atlantis has adopted and implemented an ADA Accessibility Policy (“ADA Policy”) that includes the following:

    1. Effective Communication

    2. Service Animals

    3. Reservations

    4. Website

    5. Training

    6. General provisions

    A copy of the ADA Policy is attached and incorporated into this Agreement as Attachment A.  Atlantis may revise and update the ADA Policy periodically with notice to the United States during the term of this Agreement.

18. Within ten (10) days of the effective date of this Agreement, Atlantis will distribute the ADA Policy to all employees and contractors who have contact with the public either in person, through the telephone, by the computer, or by any other means.  Atlantis will send to the United States documentation confirming the implementation and distribution of the ADA Policy to Atlantis’ employees and contractors. 

19. Within three (3) days of their hire or engagement date, Atlantis will distribute the ADA Policy to all newly hired employees and contractors who have duties involving contact with the public either in person, through the telephone, by the computer, or by any other means.

20. Within three (3) days of the effective date of this Agreement, Atlantis will post and maintain a copy of the ADA Policy in all Atlantis office locations in a conspicuous place where employees and the public can readily read it, such as the employee lounge area or at public entrances.  The ADA Policy posted in Atlantis office locations must be printed in a bold font no smaller than 20 points on a contrasting background.  The heading on the posted ADA Policy will be printed in capital letters in a bold font no smaller than 26 points.  Physical copies of the posted ADA Policy will be maintained, refreshed, and reposted, as necessary, for the term of this Agreement.

21. Within ten (10) days of the effective date of this Agreement, Atlantis will post and maintain a copy of the ADA Policy on its website in a location that is easy for the public to find (i.e., directly linked to the primary web portals used by the public with an appropriate description of the Policy at the link located on those portals – e.g., ADA Accessibility Policy), in a format accessible to persons with disabilities.

22. Within forty-five (45) days of the effective date of this Agreement, Atlantis will provide the United States with reasonable proof of posting the ADA Policy in all Atlantis office locations and on its website.

23. Within sixty (60) days of the effective date of this Agreement and thereafter at least once per year, Atlantis shall provide an educational training program regarding its obligations under title III of the ADA, this Agreement, and the ADA Accessibility Policy to all Atlantis managers, employees and contractors who have contact with the public  Newly hired employees who have contact with the public shall be provided with the training within sixty (60) days of their hire date.  The training program, the trainer and materials, which must be approved in advance by the United States, will be no less than one hour in duration, will be conducted separately from any training on nondiscrimination in employment, will provide employees and contractors an opportunity to ask questions and get them answered, and will be conducted by a person or organization with expertise regarding the requirements of title III of the ADA.  Atlantis will bear all costs associated with the development and delivery of this training program to its employees and contractors.  Pursuant to its reporting obligations under this Agreement, Atlantis will send the United States reasonable proof that each training has occurred and that all employees and contractors have received it.