Multi-annual Digital Accessibility Scheme (SPAN)

1 - REGULATORY CONTEXT

Article 47 of Law no. 2005-102 of 11 February 2005 "for equal rights and opportunities, participation and citizenship of persons with disabilities", together with Decree no. 2019-768 of 24 July 2019 on "the accessibility for persons with disabilities of online public communication services", make the accessibility of online public communication services mandatory.

Definition of digital accessibility

Digital accessibility refers to the set of good practices and obligations aimed at making digital services usable by everyone, including users with disabilities.

Disability is defined as "any limitation of activity or restriction of participation in society experienced in one's environment by a person due to a substantial, lasting or permanent impairment of one or more physical, sensory, mental, cognitive or psychological functions, a multiple disability or a disabling health condition." (Article L114 of the French Code of Social Action and Families)

2 - DEVELOPMENT OF THE MULTI-YEAR PLAN

Sport 2000 France operates the following websites:

• sport2000.fr

• location-ski.sport2000.fr and its variants

• ekosport-rent.com and its variants

• carte-cadeau.sport2000.fr

The Multi-Year Digital Accessibility Plan sets out the approach adopted to ensure progressive and lasting accessibility of our company's digital services.

It is accompanied by annual action plans that make it possible to track progress and continuously improve the user experience, including for people with temporary or permanent disabilities.

This multi-year digital accessibility plan, valid for the next three years (2026-2028), aims to present to our users our approach to improving and developing digital accessibility.

Our objectives are as follows:

• Progressive accessibility of our websites in line with the RGAA criteria (the French general framework for accessibility improvement), in order to guarantee simplified navigation and equal access to our products and services;

• Improvement of the working environment, in particular our employees' digital environment, with an emphasis on the accessibility of workstations for employees with disabilities;

• Progressive implementation of "native accessibility", i.e. taking digital accessibility criteria into account from the moment our new services or content are published.

3 - CURRENT SITUATION

As a first step, we carried out an assessment of the following websites:

• sport2000.fr

• location-ski.sport2000.fr and its variants

• ekosport-rent.com and its variants

• carte-cadeau.sport2000.fr

in order to evaluate their current level of accessibility.

An accessibility audit was therefore carried out by FACIL'iti, based on the RGAA criteria (Référentiel Général d'Amélioration de l'Accessibilité).

An audit has been carried out but not yet published for carte-cadeau.sport2000.fr.

These initial diagnostics made it possible to prioritise the corrective measures to be taken, starting with those most critical for users in terms of accessibility.

4 - TAKING DIGITAL ACCESSIBILITY INTO ACCOUNT

Digital accessibility is a subject that is still being embraced within the CERACLES Group and is gradually being integrated into our digital thinking.

Digital Accessibility Officer

The Group plans to appoint a Digital Accessibility Officer.

Their role will be to coordinate all projects related to this topic, in particular:

• Defining and monitoring continuous improvement actions for digital accessibility;

• Supporting teams through the different phases;

• Promoting the spread of accessibility by sharing standards and good practices;

• Ensuring regulatory monitoring;

• Acting as the preferred point of contact on digital accessibility matters.

Digital accessibility topics may involve several departments within the Group: IT, communication, digital, human resources, legal, etc.

Human and financial resources

Several teams (IT, digital, HR, Legal) have been identified, although the approach is still at an early stage.

The use of a specialised external provider is being considered to support the structuring of our approach, the assessment of compliance and skills development. This preparatory step aims to lay the foundations of a structured action plan at Group level.

In terms of financial resources, each digital project must take into account its specific digital accessibility needs.

These budgets will be assessed and reviewed annually based on progress in implementing this multi-year plan and on the achievement of the Group's ambitions.

Taking accessibility into account in new projects

Digital accessibility will be integrated into the design of all new projects. The aim is to improve and make fully accessible the Group's e-commerce websites and mobile applications.

At the same time, corrective actions are already under way to resolve the accessibility issues identified on the current versions. The Group wishes to use the implementation of this multi-year plan to embed these requirements permanently in all of its digital projects.

Training and awareness-raising for teams

The Group is committed to a progressive upskilling and awareness-raising on digital accessibility, first for the roles directly concerned by this topic, then gradually for all employees.

The aim is to promote native accessibility as far as possible from the creation of new media and/or content.

Accessibility in everyday life

Beyond our internal efforts to integrate accessibility into our projects, digital accessibility and compliance with regulatory criteria will also be included in our contracts with service providers working in these areas.

5 - MULTI-YEAR PLAN