Multi-year Digital Accessibility Plan 2025-2026

Concept of Digital Accessibility

Disability is defined as any limitation of activity or restriction of participation in society experienced by a person in their environment due to a substantial, long-term, or permanent impairment of one or more physical, sensory, mental, cognitive, or psychological functions, multiple disabilities, or a disabling health disorder (Article L. 114 of the Social Action and Family Code).

Digital accessibility aims to ensure that online communication services are accessible to people with disabilities. This means:

• Perceivable: for example, facilitating visual and auditory perception of content by the user; providing text equivalents for all non-text content; creating content that can be presented in different ways without loss of information or structure (for example with a simplified layout);
• Operable: for example, providing the user with orientation elements to navigate and find content; making all functionalities accessible by keyboard; giving the user enough time to read and use the content; not designing content likely to cause epileptic seizures;
• Understandable: for example, ensuring that pages operate in a predictable manner; helping the user correct input errors
• Robust: for example, optimizing compatibility with current and future uses.

Inclusivity Policy and Disability Consideration at Etam

Sustainably committed to professional inclusion for all, the Etam Group pursues an active policy for the recruitment and retention of people with disabilities.

Through the signing of an agreement approved by the DREETS (Regional Directorate for Economy, Employment, Labor and Solidarity), concrete actions have been deployed for several years based on 4 key areas:

• Recruitment and integration of employees with disabilities: regular participation in trade shows and forums dedicated to meeting qualified disabled workers, implementation of POEC (Collective Operational Preparation for Employment program) to promote the professional integration of people with disabilities, distant from employment, by concretely training them in our professions to give them access to a new active life.
• Support for continued employment and implementation of adapted solutions: workplace accommodations, assistance with disability recognition procedures
• Conducting communication and awareness actions to inform, deconstruct prejudices related to disability, and train operational teams: deployment of the Disability Policy to raise awareness and unite, creation of dedicated training modules
• Development of the adapted and protected sector: partnerships with ESAT (Establishment and Service of Assistance through Work) and Adapted Companies promoting the integration of workers with disabilities.

All of these 4 major policy areas are managed by the Disability Mission cell, dedicated to supporting the employees concerned, and more broadly the Group's support & operational teams (Headquarters, Retail, Warehouses). In addition to this cell, there are "Disability Relays" within each brand's Management Committee and all Regional Directors concerning stores. Their mission is to be a point of contact closer to operational staff for all disability-related topics (information on procedures, local actions, monitoring...).

It relies on all internal stakeholders, who act as essential actors and relays of commitments and the disability approach: General Management, Human Resources Management, Regional Retail Directors, local managers, and members of the Social and Economic Committee.

The Group wishes to strengthen its mobilization and perpetuate its commitment to disability inclusion over time.

Digital Accessibility Consideration at Etam

Digital accessibility is a subject currently being appropriated within the Etam Group, progressively integrated into our digital reflections. Various teams (IT, digital, communication...) are mobilized, although the approach is still in its initial phase. The use of an external specialized provider is being considered to support the structuring of our approach, conformity assessment, and skills development. This preparatory stage aims to lay the foundations for a structured action plan at the Group level.

To date, the Digital Factory teams, who are most central to the project, have been able to exchange with various specialized interlocutors to understand the specific challenges of accessibility and can support the rest of the teams

Content Concerned

Public online communication services are defined as any provision to the public or categories of the public, by an electronic communication process, of signs, signals, writings, images, sounds, or messages of any nature that do not have the character of private correspondence (Article 1 of Law No. 2004-575 of June 21, 2004 for confidence in the digital economy). In accordance with Article 47 of the aforementioned law of February 11, 2005, they include in particular:

• Internet, intranet, extranet websites; software packages, insofar as they constitute applications used through a web browser or mobile application;
• Mobile applications that are defined as any application software designed and developed for use on mobile devices, such as smartphones and tablets, excluding operating system or hardware;
• Digital urban furniture, for their application or interactive part, excluding operating system or hardware.

For the Group, we have identified the following elements requiring compliance:

Brand	Type	Url
Etam	E-commerce site	https://www.etam.com/
Etam	Mobile application	-
Undiz	E-commerce site	https://www.undiz.com/
Undiz	Mobile application	-
Maison 123	E-commerce site	https://www.maison123.com/
Etam, Undiz, Maison 123	Digital tools in stores (automatic checkouts, terminals...)	-

Certain content is exempt from the accessibility obligation and falls outside the scope of the legal obligation:

• Files available in office formats published before September 23, 2018, unless they are necessary for the completion of an administrative procedure falling within the tasks performed by the organization concerned;
• Pre-recorded audio and video content, including those with interactive components, published before September 23, 2020;
• Live broadcast audio and video content, including those with interactive components;
• Online maps and mapping services, provided that, for maps intended to provide location or route information, essential information is provided in an accessible digital format;
• Third-party content that is neither financed nor developed by the organization concerned and is not under its control;
• Content of intranets and extranets published before September 23, 2019, until these sites undergo a thorough revision;
• Content of websites and mobile applications that are neither necessary for the completion of an active administrative procedure nor updated or modified after September 23, 2019, including archives

Consideration of Accessibility in New Projects

Digital accessibility and RGAA compliance will be taken into account in new projects with the objective of improving and making the Group's e-commerce sites and mobile applications accessible.
We are already starting to correct accessibility issues on current versions. The Group wishes to use the actions of this multi-year plan to multiply and systematize the consideration of these requirements across all digital projects.
We need to work on incorporating accessibility into new projects on internal and external tools (recruitment site)

Consideration of Digital Accessibility in Tender Procedures

For certain projects, the Group may use external service providers or suppliers for the development, purchase, and maintenance of digital tools.
Digital accessibility will now be an important criterion integrated into the evaluation of offers and skills. A specific clause will be added to the contract, accompanied by an information campaign aimed at service providers.

Control and Validation Process

Each site or application will be subject, at the time of initial launch, during a substantial update, during a redesign, or at the end of standardization operations, to a control and/or audit to establish a declaration of conformity in accordance with the terms of the law.
Each brand is responsible for conducting audits for the sites and applications within its scope, as well as publishing accessibility declarations. Audits can be conducted internally (via the Digital Factory) or with the support of specialized external service providers.

User Tests

Currently, the Group does not conduct user tests involving people with disabilities. We will integrate this principle into our panels for future user tests requiring this type of profile.

Processing User Feedback

In accordance with the provisions of the RGAA, we will implement a contact form where users can report difficulties they encounter when navigating our e-commerce sites and applications.
To respond to these requests, the implementation of a specific assistance procedure will be studied with all the services and people involved.
Requests can be sent via the contact form available on the sites and applications, allowing the Accessibility Referents, when appointed, to distribute the requests to the project managers.

Training and Awareness

The Group is working on implementing training and awareness on digital accessibility for professions directly related to these topics (Designers, developers, testers, Product Owners...) initially, and then more broadly for all employees. The Group may use an external service provider to deliver certain training sessions.

A training module on Disability is already available and could be supplemented with digital accessibility concepts.

A Guidelines project is underway within the Digital Factory to establish the main principles to be respected in a new project to comply with digital accessibility.

Use of External Skills

The Group may use external service providers acting as digital accessibility experts. Their missions include awareness actions, training, support and assistance for teams, and supervision of audits.

Diagnosis and Audit

The definition of the methods for conducting diagnoses and RGAA compliance audits is ongoing. They will be specified in this section during a future update of this multi-year plan.
In the meantime, the group's entities will conduct diagnoses and audits according to the methods they deem most appropriate to their situation and their level of maturity.

Intervention Schedule

Given the information collected during the development of this plan, as well as the complexity of the sites and applications evaluated in terms of feasibility, compliance operations were initiated in 2025 and will continue in the coming years.

The plan will define, through annual action plans, the corrective measures planned to ensure the accessibility of non-compliant content. Each measure will be accompanied by an implementation schedule, prioritizing the most consulted content and the most used services.

Mandatory Mentions on the Site

The homepage of the Group's different sites, namely Etam, Undiz, and Maison 123, will mandatorily display one of the following mentions:

• "Accessibility: fully compliant" if all RGAA control criteria are met;
• "Accessibility: partially compliant" if at least 50% of RGAA control criteria are met;
• "Accessibility: non-compliant" if there is no valid audit result to measure compliance with the criteria or if less than 50% of RGAA control criteria are met.

This mention is clickable and leads to the Accessibility page containing the accessibility declaration, as well as the link to the multi-year plan.

The websites will have a dedicated page ("accessibility") directly accessible from the homepage and from any page of the service and will contain the following elements:

• The accessibility declaration according to the model set by the RGAA framework;
• The multi-year accessibility plan or a link to it;
• The action plan for the current year or a link to it.

The use of a standardized internet address (or URL) such as www.sitename.extension/accessibility will be applied in all cases.

This multi-year plan is accompanied by action plans describing in detail the operations implemented to address all the Group's digital accessibility needs.

The annual action plan details the operations planned and implemented for the current year as well as the monitoring status of these actions. The annual plan may be updated; the online version is the only version considered authentic. The action plans presented are common action plans for all brands, as our digital tools share the same code base allowing different actions to be pooled.

Annual Plan 2025

Type	Action	Details	Status
Multi-year plan	Development	Drafting and publication of the Multi-year Plan at Group level	Done
Site map	Correction	Development and publication of a page allowing navigation on the site	Done
Annual Plan	Development	Implementation of 3-year action plans	In progress
Governance	Management	Appointment of an accessibility referent for each stakeholder	In progress
Continuous improvement	Correction	Following the audits conducted (internal and/or external), commitment of resources to make significant corrections to identified non-conformities	In progress
Support and awareness	Guidance	Creation of Guidelines by the Digital Factory	In progress
Audit	Verification	Contact with third-party services on our platforms to verify their compliance	In progress
Technical evolution	Correction	Compliance of downloadable office documents	In progress
Human resources	Identify	Creation of a group of internal testers with and without disabilities	To be done
Audit	Verification	Etam.com Undiz.com Maison123.com Etam Application Undiz Application	To be done
Technical evolution	Correction	Compliance of images	To be done
Technical evolution	Correction	Compliance of forms	To be done
Technical evolution	Correction	Compliance of input control	To be done
Technical evolution	Correction	Compliance of page structure	To be done

Annexes

Regulatory references: Legal texts and applicable standards

• Directive (EU) 2016/2102 of the European Parliament and of the Council of 26 October 2016 on the accessibility of websites and mobile applications of public sector bodies
• Law No. 2005-105 of February 11, 2005 for equal rights and opportunities, participation and citizenship of persons with disabilities
• Directive (EU) 2019/882 of the European Parliament and of the Council of 17 April 2019 on the accessibility requirements for products and services
• Order No. 2023-859 of September 6, 2023 which amended Article 47 of Law No. 2005-102 and introduced a new Article 47-1, specifying digital accessibility obligations for private actors

Useful contacts: Contact form available on each Group website and application