ACCESSIBILITY

II. Multi-Year Digital Accessibility Plan

1. Accessibility Policy

In accordance with Article 47 of Law No. 2005-102 of February 11, 2005 on equal rights and opportunities, participation and citizenship for people with disabilities, public online communication services must be accessible to all.

Group Banque Richelieu is committed to a continuous improvement approach to the digital accessibility of its digital services.

This approach is structured through this multi-year digital accessibility plan, complemented by annual action plans, aimed at supporting progressive compliance with the General Accessibility Improvement Framework (RGAA) and strengthening the quality of use of the digital services offered.

In this context, the Group has initiated a strategic transformation project of its digital ecosystem, aimed at consolidating its existing sites within a unified group platform.

1.1 Commitment of Group Banque Richelieu

Digital accessibility is a structural pillar of Group Banque Richelieu’s digital strategy.

It is taken into account in the design, redesign and maintenance projects of digital services, with the objective of progressive and sustainable improvement of the accessibility of interfaces and content.

As part of the ongoing redesign program aimed at implementing a single multi-entity group site, Group Banque Richelieu aims to achieve the highest possible level of RGAA compliance from the design phase of the new platform.

1.2 Accessibility Officer

The development, implementation and monitoring of this plan are under the responsibility of a digital accessibility officer appointed within Group Banque Richelieu.

Their responsibilities include:

• defining and monitoring the digital accessibility strategy;
• supporting project teams in implementing RGAA requirements;
• coordinating accessibility audits;
• contributing to raising awareness among internal teams;
• monitoring accessibility statements for digital services;
• serving as the central point of contact on digital accessibility matters.
  
  

1.3 Concept of Digital Accessibility

Digital accessibility consists of making public online communication services usable by people with disabilities, by ensuring content that is:

• perceivable, particularly through text alternatives and adaptation of multimedia content;
• operable, particularly through keyboard navigation and non-restrictive interfaces;
• understandable, through clear, consistent and predictable content;
• robust, compatible with current and future assistive technologies.
  
  

Disability is understood as any limitation of activity or restriction of participation in society resulting from a lasting or permanent impairment of physical, sensory, mental, cognitive or psychological functions.

1.4 Scope of Services Covered

The scope of Group Banque Richelieu currently includes several sites and digital services:

• Banque Richelieu (institutional site of the holding company Compagnie Financiere Richelieu)
• Banque Richelieu France
• Banque Richelieu Monaco
• Banque Richelieu GCC (sister company)
• Banque Richelieu Switzerland
• Richelieu Invest
• Richelieu Corporate Finance
  
  

As part of the ongoing digital transformation program, these sites are intended to be progressively consolidated within a single multi-entity group digital platform.

The services covered include internet, intranet, extranet sites and associated web or mobile applications.

Certain content may be excluded from the scope of the accessibility requirement, particularly uncontrolled third-party content, archived content or content subject to duly justified technical constraints.

2. Human and Financial Resources

Group Banque Richelieu has appointed a digital accessibility officer responsible for managing and coordinating the implementation of the approach.

As part of digital projects, accessibility requirements are progressively integrated into design, development and maintenance budgets.

Depending on needs, the following may be mobilized:

• RGAA accessibility audits;
• UX/UI support during the design phase;
• correction and optimization services;
• user testing including, when possible, people with disabilities;
• support from external experts specialized in digital accessibility.
  
  

3. Organization of Accessibility Implementation

The implementation of digital accessibility is based on a progressive organization integrated into the lifecycle of Group Banque Richelieu’s digital projects.

It relies on:

• progressive integration of RGAA requirements into projects;
• skill development of internal teams;
• consideration of user feedback;
• structuring a compliance approach as part of the future group platform.
  
  

3.1 Awareness and Training

Awareness-raising actions on digital accessibility are implemented for teams involved in the design, development and management of digital services.

These actions particularly concern:

• project managers;
• editorial contributors;
• product and digital marketing teams.
  
  

3.2 Use of External Expertise

When necessary, Group Banque Richelieu engages service providers specialized in digital accessibility to:

• conduct RGAA audits;
• support design and redesign phases;
• perform technical corrections;
• contribute to updating accessibility statements.
  
  

3.3 Integration into Projects

As part of the redesign program toward a single group platform, digital accessibility is integrated from the design phases.

The objective is to ensure high compliance from the launch of the new platform, based on:

• inclusive design principles;
• RGAA standards;
• enhanced requirements for user journeys.
  
  

3.4 User Testing

User testing may be conducted, particularly as part of the redesign project, integrating when possible users with disabilities to evaluate the actual accessibility of interfaces.

3.5 Procurement and Tenders

Digital accessibility requirements are progressively integrated into Group Banque Richelieu’s consultations and tenders.

They may constitute an evaluation criterion for service providers, particularly regarding their ability to meet RGAA requirements.

3.6 Recruitment

Group Banque Richelieu ensures that digital accessibility skills are considered in profiles working on digital projects.

3.7 Handling User Feedback

A contact mechanism allows users to report any difficulty accessing digital content or services.

This feedback is considered as part of a continuous improvement approach.

3.8 Control Process

Each digital service undergoes a progressive evaluation of its accessibility level.

As part of the digital information system redesign program, an RGAA accessibility audit is planned for 2027, to evaluate the compliance of existing services and the new group platform.

3.9 Action Planning

Accessibility actions are managed through annual plans including:

• preparation and conduct of audits;
• corrective actions;
• team awareness-raising;
• support for the redesign project toward the group platform.
  
  

3.10 Accessibility Notices

Each Group Banque Richelieu site displays an accessibility notice linking to:

• the accessibility statement;
• this multi-year plan;
• the current annual action plan.
  
  

4. Technical and Functional Scope

4.1 Inventory

The scope includes all sites and digital services of the Group Banque Richelieu entities listed above, as well as the future single group digital platform currently being designed.

4.2 Prioritization

Actions are prioritized according to:

• service criticality;
• traffic;
• technical complexity;
• their integration into the redesign program;
• their lifecycle.
  
  

5. Annual Action Plans

This plan is implemented through annual plans to structure the progressive implementation of the approach.

2026 Annual Plan

The 2026 annual plan constitutes a structuring and preparation phase for the digital accessibility approach.

The planned actions include:

• consolidation of digital accessibility governance;
• continued awareness-raising of internal teams on RGAA issues;
• progressive integration of accessibility requirements into ongoing projects;
• identification and prioritization of digital services within the audit scope;
• preparation of frameworks and materials necessary for the future group platform redesign.
  
  

2027 Annual Plan

The year 2027 represents a structural milestone in implementing Group Banque Richelieu’s digital accessibility approach, in connection with the digital transformation program.

The planned actions are:

• design, development and implementation of the new single group digital platform, consolidating the existing sites of Group Banque Richelieu entities;
• integration of RGAA requirements from the design phase of the new platform (“accessibility by design” approach);
• support for project teams in implementing digital accessibility best practices;
• conduct of an RGAA 4.1.2 accessibility audit covering the new single group platform and the digital services within its scope;
• analysis of audit results and definition of a corrective action plan if necessary;
• update of accessibility statements for the services concerned following the audit.