Multi-year Digital Accessibility Scheme 2025-2026

Concept of digital accessibility

Disability is defined as any limitation of activity or restriction of participation in social life experienced in one's environment by a person due to a substantial, lasting or definitive alteration of one or more physical, sensory, mental, cognitive or psychic functions, a multiple disability or an invalidating health disorder (Article L. 114 of the Social Action and Families Code).

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

• Perceivable: for example, facilitating the user's visual and auditory perception of content; offering textual equivalents for all non-textual content; creating content that can be presented in different ways without loss of information or structure (e.g., with a simplified layout);
• Operable: for example, providing the user with orientation elements to navigate, find content; making all functionalities accessible via the 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 function predictably; helping the user correct input errors;
• Robust: for example, optimizing compatibility with current and future uses.

Inclusivity policy and consideration of disability at Etam

Durably committed to the professional inclusion of all, the Etam Group pursues an active policy in favor of hiring and retaining employment for 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 across 4 key axes:

• The recruitment and integration of employees with disabilities: regular participation in fairs and forums dedicated to meeting qualified disabled workers, setting up POEC (Collective Operational Employment Preparation program) to promote the professional integration of people with disabilities, far from employment, by concretely training them in our trades to allow them to access a new active life.
• Support for maintaining employment and implementing adapted solutions: job adaptations, support in disability recognition procedures.
• Conducting communication and awareness-raising 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.
• The development of the adapted and protected sector: partnerships with ESAT (Establishment and Service for Work Support) and Adapted Companies promoting the integration of workers with disabilities.

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

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

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

Consideration of digital accessibility at Etam

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

To date, the Digital Factory teams, who are at the heart of the project, have been able to exchange with various specialized contacts to understand the specific challenges of accessibility and can support the rest of the teams.

Affected Content

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

• Websites, intranets, extranets; enterprise software, provided they constitute applications used via a web browser or a mobile application;
• Mobile applications which 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 website	https://www.etam.com/
Etam	Mobile application	-
Undiz	E-commerce website	https://www.undiz.com/
Undiz	Mobile application	-
Maison 123	E-commerce website	https://www.maison123.com/
Etam, Undiz, Maison 123	Digital tools in store (self-checkout, kiosks...)	-

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 under the tasks performed by the organization concerned;
• Pre-recorded audio and video content, including those with interactive components, published before September 23, 2020;
• Live audio and video content, including those with interactive components;
• Maps and online mapping services, provided that, for maps intended to provide a location or an itinerary, essential information is provided in an accessible digital format;
• Third-party content that is neither funded nor developed by the organization concerned and that is not under its control;
• Content of intranets and extranets published before September 23, 2019, until these sites undergo a major overhaul;
• 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, in particular archives.

Human Resources

The Group must appoint a Digital Accessibility Referent per stakeholder (CSR, Finance, IT, Brand...). Their main missions will be to:

• Define and monitor continuous improvement actions for digital accessibility.
• Support project teams in the different phases.
• Oversee accessibility declarations on the Group's media.
• Participate in awareness, training, and internal communication.
• Ensure regulatory watch.
• Be the privileged point of contact for digital accessibility topics.

Topics related to digital accessibility mobilize several departments within the Group and are subject to a transversal organization via:

• The Digital Factory: project management, design, and development.
• Human Resources: implementation of specificities during recruitment, employee training.
• CSR: disability policy.
• Legal: legal watch on digital accessibility topics, contract review with service providers.
• Finance: budget allocation.
• E-commerce Manager of each brand: Steering digital projects, developing functional evolutions in liaison with technical teams, CRM adaptation...

Financial Resources

For each digital project, the allocated budget must take into account the specific needs in terms of digital accessibility. 

For each project, a specific budget may be provided for the team in charge of its scope, for the following elements: 

• Support service on technical topics.
• Audit (site, graphic mock-ups...).

These budgets will be evaluated and reviewed annually based on the progress of the implementation of this multi-year scheme and the achievement of the group's ambitions.

Considering 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 leverage the actions of this multi-year scheme to multiply and systematize the consideration of these requirements across all digital projects.
We must work on incorporating accessibility into new projects for both internal and external tools (recruitment website).

Consideration of digital accessibility in tender procedures

For certain projects, the Group may call upon 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 competencies. 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 to a control and/or audit upon initial online publication, during a substantial update, a redesign, or at the end of standardization operations, in order 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 for publishing accessibility declarations. Audits can be carried out internally (via the Digital Factory) or with the support of external specialized service providers.

User Tests

To date, the Group does not conduct user tests integrating people with disabilities. We will incorporate 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 set up a contact form where users can report their navigation difficulties on our e-commerce sites and applications.
To respond to these requests, the implementation of a specific assistance procedure will be studied with all relevant departments and individuals.
Requests can be sent via the contact form available on the websites and applications, allowing Accessibility Referents, once appointed, to distribute requests to project managers.

Training and Awareness

The Group is working on implementing training and awareness on digital accessibility for professions directly related to these subjects (Designers, developers, testers, Product Owners...) in a first phase, and then more broadly for all employees. The Group may call upon an external service provider to lead certain training sessions.

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

A Guidelines project is underway within the Digital Factory to establish the main principles to be followed for any new project in order to comply with digital accessibility.

Use of External Expertise

The Group may engage external service providers acting as digital accessibility experts. Their missions notably cover awareness, training, support, and assistance for teams, as well as oversight of audits.

Diagnosis and Audit

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

Intervention Schedule

In light of the information collected during the development of this scheme, as well as the complexity of the sites and applications evaluated in terms of feasibility, compliance operations began in 2025 and will continue in the coming years.

The scheme 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 various sites, namely Etam, Undiz, and Maison 123, will be required to display one of the following mentions:

• «Accessibility: fully compliant» if all RGAA control criteria are met;
• «Accessibility: partially compliant» if at least 50% of the 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 the RGAA control criteria are met.

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

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

• The accessibility statement according to the model set by the RGAA framework;
• The multi-year accessibility scheme or a link to it;
• The current year's action plan 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 scheme is accompanied by action plans detailing the operations implemented to address all the Group's digital accessibility needs.

The annual action plan details the operations scheduled 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 valid version. The action plans presented are common action plans for all brands, as our digital tools share the same codebase, allowing for the mutualization of different actions.

2025 Annual Plan

Type	Action	Details	Status
Multi-year scheme	Development	Drafting and publication of the Multi-year Scheme 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	Steering	Appointment of an accessibility referent per stakeholder	In progress
Continuous improvement	Correction	Following audits conducted (internal and/or external), commitment of resources to make significant corrections to identified non-conformities	In progress
Support and awareness	Support	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 an internal testing group 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