Multi-year Digital Accessibility Plan 2025-2026

What is digital accessibility?

Disability is defined as any limitation of activity or restriction of participation in society experienced by a person in their environment because of a substantial, lasting, or permanent impairment of one or more physical, sensory, mental, cognitive, or psychological functions, a combination of impairments, or a disabling health condition (Article L. 114 of the Social Action and Families Code).

Digital accessibility aims to ensure that online communication services can be used by people with disabilities. This means:

• Perceivable: for example, making visual and auditory perception of content easier for users; providing text alternatives for any non-text content; creating content that can be presented in different ways without loss of information or structure (for example, through a simplified layout);
• Operable: for example, providing users with orientation cues to navigate and find content; making all functionality available from a keyboard; giving users enough time to read and use the content; not designing content likely to trigger seizures;
• Understandable: for example, making pages work in predictable ways; helping users correct input errors
• Robust: for example, optimising compatibility with current and future assistive technologies.

Etam's inclusion policy and approach to disability

Committed for the long term to the professional inclusion of everyone, the Etam Group runs an active policy in favour of hiring and retaining employees with disabilities.

Through an agreement approved by the DREETS (Regional Directorate for the Economy, Employment, Labour and Solidarity), concrete actions have been rolled out for several years around 4 key areas:

• Recruiting and onboarding employees with disabilities: regular participation in job fairs and events dedicated to meeting qualified workers with disabilities, and the introduction of POEC programmes (Collective Operational Preparation for Employment) to support the professional integration of people with disabilities who are far from the job market, by training them directly in our trades to help them start a new working life.
• Support for retaining employees in their jobs and implementing suitable workplace adjustments: adapting workstations, and supporting employees through the process of having their disability officially recognised
• Running communication and awareness-raising campaigns to inform, break down prejudices related to disability, and train operational teams: rolling out the Disability Policy to raise awareness and build engagement, and creating dedicated training modules
• Developing the sheltered and supported employment sector: partnerships with ESATs (Disability Support and Employment Centres) and Adapted Enterprises to support the integration of workers with disabilities.

All four of these major policy pillars are overseen by the Disability Task Force, dedicated to supporting the employees concerned, as well as, more broadly, the Group's support and operational teams (Head Office, Retail, Warehouses). This task force is complemented by "Disability Liaisons" within each brand's Executive Committee and by all Regional Directors responsible for stores. Their role is to act as a closer point of contact for operational staff on all disability-related matters (information on procedures, local initiatives, follow-up, etc.).

It draws on all internal stakeholders, who act as key participants in and champions of the Group's disability commitments and approach: Senior Management, the Human Resources Department, Regional Retail Directors, local managers, and members of the Social and Economic Committee.

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

Digital accessibility at Etam

Digital accessibility is a topic the Etam Group is progressively taking ownership of, gradually being integrated into our digital thinking. Various teams (IT, digital, communications, etc.) are involved, although the approach is still at an early stage. The Group is considering using a specialised external service provider to help structure our approach, assess compliance, and build internal skills. This preparatory phase aims to lay the groundwork for a structured action plan across the Group.

To date, the Digital Factory teams, who are closest to the project, have been able to discuss with various specialists in order to understand the specific challenges of accessibility, and are able to support the rest of the teams.

Content covered

Online public communication services are defined as any means of making available to the public, or to categories of the public, by electronic communication, signs, signals, writings, images, sounds, or messages of any kind that do not have the character of private correspondence (Article 1 of Law No. 2004-575 of 21 June 2004 on confidence in the digital economy). In accordance with Article 47 of the above-mentioned law of 11 February 2005, they include in particular:

• Websites, intranets, extranets; software packages, insofar as they are applications used through a web browser or a mobile application;
• Mobile applications, defined as any application software designed and developed for use on mobile devices, such as smartphones and tablets, excluding the operating system or hardware;
• Digital street furniture, for its application or interactive components, excluding the operating system or hardware.

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

Brand	Type	URL
Etam	E-commerce website	https://int.etam.com/
Undiz	E-commerce website	https://int.undiz.com/
Maison 123	E-commerce website	https://int.maison123.com/
Etam, Undiz, Maison 123	In-store digital tools (self-checkout, kiosks, etc.)	-

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

• Files available in office document formats published before 23 September 2018, unless they are necessary for carrying out an administrative procedure falling within the tasks performed by the organisation concerned;
• Pre-recorded audio and video content, including content with interactive components, published before 23 September 2020;
• Live-streamed audio and video content, including content with interactive components;
• Maps and online mapping services, provided that, for maps intended to provide location or route information, the essential information is provided in an accessible digital format;
• Third-party content that is neither funded nor developed by the organisation concerned and that is not under its control;
• Intranet and extranet content published before 23 September 2019, until such sites undergo a substantial revision;
• Content on websites and mobile applications that is neither necessary for carrying out an active administrative procedure, nor updated or modified after 23 September 2019, in particular archives

Taking accessibility into account in new projects 

Digital accessibility and RGAA compliance will be taken into account as part of new projects, with the aim of improving and making the Group's e-commerce websites and mobile applications accessible.
We are already starting to fix accessibility issues on the current versions. The Group intends to use the actions in this multi-year plan to scale up and systematise the consideration of these requirements across all digital projects.
We need to work on incorporating accessibility into new projects for both internal and external tools (including the recruitment website)

Taking digital accessibility into account in tendering 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 included in the evaluation of bids and competencies. A specific clause will be added to the contract, along with an information campaign aimed at service providers.

Control and validation process 

Each website or application will undergo a review and/or audit at initial launch, at a substantial update, at a redesign, or at the end of compliance work, in order to establish a compliance statement in accordance with the terms of the law.
Each brand is responsible for carrying out audits for the websites and applications within its scope, as well as for publishing accessibility statements. Audits may be carried out internally (via the Digital Factory) or with the support of specialised external service providers.

User testing

To date, the Group does not carry out user testing involving people with disabilities. We will incorporate this principle into our panels for upcoming user tests that require this type of profile.

Handling user feedback

In accordance with the provisions set out in the RGAA, we will implement a contact form where users can report navigation difficulties on our e-commerce sites and applications.
In order to respond to these requests, a specific support procedure will be studied together with all the departments and people involved.
Requests may be sent via the contact form available on the sites and applications, allowing Accessibility Officers, once appointed, to route requests to the relevant project managers.

Training and awareness-raising

The Group is working on introducing training and awareness sessions on digital accessibility, initially for roles directly involved in these matters (designers, developers, testers, product owners, etc.), and later more broadly for all employees. The Group may call on an external service provider to run certain training sessions.

A training module on disability is already available and could be supplemented with content on digital accessibility.

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

Use of external expertise

The Group may call on external service providers acting as digital accessibility experts. Their work covers awareness-raising, training, support for teams, and audit supervision.

Diagnosis and audit

The methods for carrying out RGAA compliance diagnostics and audits are currently being defined. They will be detailed in this section in a future update of this multi-year plan.
In the meantime, Group entities will carry out diagnostics and audits using the methods they consider best suited to their situation and level of maturity.

Schedule of interventions

Based on the information gathered while drawing up this plan, as well as the complexity of the websites and applications assessed in terms of feasibility, compliance work began in 2025 and will continue in the coming years.

The plan will set out, through annual action plans, the corrective measures planned to ensure the accessibility of non-compliant content. Each measure will be accompanied by an implementation timeline, prioritising the most-visited content and the most-used services.

Mandatory notices on the website

The home page of each of the Group's websites, namely Etam, Undiz, and Maison 123, will display one of the following notices:

• "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 available to assess compliance with the criteria, or if fewer than 50% of the RGAA control criteria are met.

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

Websites will have a dedicated ("accessibility") page, directly accessible from the home page and from any page of the service, containing the following elements:

• The accessibility statement, following the model set out by the RGAA framework;
• The multi-year accessibility plan, or a link to it;
• The current year's action plan, or a link to it.

A standardised web address (URL), such as  www.sitename.extension/accessibility, will be used in all cases.

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

The annual action plan sets out the actions planned and implemented for the current year, as well as the progress of these actions. The annual plan may be updated; the online version is the only one considered authoritative. The action plans presented are common to all brands, as our digital tools share the same codebase, allowing actions to be shared across brands.

2025 Annual Plan

Type	Action	Details	Status
Multi-year plan	Development	Drafting and publication of the Group's Multi-year Plan	Done
Site map	Correction	Development and publication of a page for navigating the site	Done
Annual Plan	Development	Setting up action plans over 3 years	In progress
Governance	Management	Appointment of an accessibility officer for each stakeholder area	In progress
Continuous improvement	Correction	Following audits carried out (internal and/or external), committing resources to make significant corrections to the non-conformities identified	In progress
Support and awareness-raising	Support	Creation of Guidelines by the Digital Factory	In progress
Audit	Verification	Contacting third-party services in place on our platforms to check their compliance	In progress
Technical development	Correction	Bringing downloadable office documents into compliance	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	To be done
Technical development	Correction	Bringing images into compliance	To be done
Technical development	Correction	Bringing forms into compliance	To be done
Technical development	Correction	Bringing input validation into compliance	To be done
Technical development	Correction	Bringing page structure into compliance	To be done

Appendices

Regulatory references: applicable laws and standards

• Directive (EU) 2016/2102 of the European Parliament and of the Council of 26 October 2016 on the accessibility of the websites and mobile applications of public sector bodies
• Law No. 2005-102 of 11 February 2005 on 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
• Ordinance No. 2023-859 of 6 September 2023 amending Article 47 of Law No. 2005-102 and introducing a new Article 47-1, setting out digital accessibility obligations for private-sector organisations

Useful contacts: Contact form available on each of the Group's websites and applications