Accessibility

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, online public communication services must be accessible to all.

The Group Banque Richelieu is committed to continuously improving the digital accessibility of its digital services.

This initiative is structured around this multi-year digital accessibility plan, supplemented by annual action plans, aimed at supporting gradual compliance with the General Framework for Accessibility Improvement (RGAA) and to enhance the user experience of the digital services offered.

As part of this effort, the Group has launched a strategic initiative to transform its digital ecosystem, with the goal of consolidating its existing websites into a unified group-wide platform.

1.1 The Group Banque Richelieu’s Commitment

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

It is taken into account in the design, redesign, and maintenance of digital services, with the goal of gradually and sustainably improving the accessibility of interfaces and content.

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

1.2 Accessibility Coordinator

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

Its responsibilities include, in particular:

• defining and monitoring the digital accessibility strategy;
• supporting project teams in complying with RGAA requirements;
• coordinating accessibility audits;
• helping to raise awareness among internal teams;
• monitoring accessibility statements for digital services;
• the role of central point of contact for issues related to digital accessibility.

1.3 The Concept of Digital Accessibility

Digital accessibility involves making online public communication services usable by people with disabilities by ensuring that content:

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

A disability is defined as any limitation on activity or restriction on participation in society resulting from a long-term or permanent impairment of physical, sensory, mental, cognitive, or psychological functions.

1.4 Scope of the Services in Question

The Group Banque Richelieu currently comprises several locations and digital services:

• Banque Richelieu (corporate website of the Compagnie Financière Richelieu holding company)
• Banque Richelieu France
• Banque Richelieu Monaco
• Richelieu GCC Bank (sister company)
• Banque Richelieu Switzerland
• Richelieu Invest
• Richelieu Corporate Finance

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

The services in question include websites, intranets, extranets, and related web or mobile applications.

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

2. Human and Financial Resources

The Group Banque Richelieu has appointed a digital accessibility officer to lead and coordinate the implementation of the initiative.

In the context of digital projects, accessibility requirements are gradually being incorporated into design, development, and maintenance budgets.

Depending on the needs, the following may be mobilized:

• RGAA accessibility audits;
• UX/UI support during the design phase;
• proofreading and optimization services;
• user testing that includes, whenever possible, people with disabilities;
• support from external experts specializing in digital accessibility.

3. Organizing the Implementation of Accessibility Measures

The consideration of digital accessibility is based on a phased approach integrated into the lifecycle of the Group Banque Richelieu’s digital projects.

It is based on:

• the gradual integration of RGAA requirements into projects;
• the development of internal teams’ skills;
• taking user feedback into account;
• Developing a compliance framework as part of the future group platform.

3.1 Awareness and Training

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

These actions include, in particular:

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

3.2 Use of External Expertise

When necessary, the Group Banque Richelieu engages service providers specializing in digital accessibility in order to:

• conduct RGAA audits;
• support the design and redesign phases;
• make technical corrections;
• help update the accessibility statements.

3.3 Integration into Projects

As part of the program to transition to a single group-wide platform, digital accessibility is incorporated from the design phase onward.

The goal is to ensure a high level of compliance from the moment the new platform goes live, by relying on:

• principles of inclusive design;
• RGAA standards;
• Stricter requirements for user flows.

3.4 User Testing

User testing can be conducted—particularly as part of the redesign project—by including users with disabilities whenever possible in order to assess the actual accessibility of the interfaces.

3.5 Procurement and Bidding

Digital accessibility requirements are gradually being incorporated into the Group Banque Richelieu’s consultations and requests for proposals.

They can serve as a criterion for evaluating service providers, particularly with regard to their ability to comply with RGAA requirements.

3.6 Recruitment

The Group Banque Richelieu ensures that digital accessibility skills are taken into account in the job profiles of those working on digital projects.

3.7 Handling User Feedback

A contact form allows users to report any difficulties accessing digital content or services.

This feedback is taken into account as part of our commitment to continuous improvement.

3.8 Control Processes

Each digital service undergoes a phased assessment of its level of accessibility.

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

3.9 Action Planning

Accessibility initiatives are managed through annual plans that include, in particular:

• the preparation and conduct of audits;
• corrective actions;
• raising awareness among teams;
• Support for the project to migrate to the group platform.

3.10 Accessibility Statements

Each website of the Group Banque Richelieu displays an accessibility notice that links to:

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

4. Technical and Functional Scope

4.1 Census

The scope includes all digital sites and services of the Group Banque Richelieu entities listed above, as well as the future unified Group digital platform currently under development.

4.2 Prioritization

Actions are prioritized based on:

• the critical nature of the services;
• attendance;
• technical complexity;
• their inclusion in the redesign program;
• their life cycle.

5. Annual Action Plans

This framework is broken down into annual plans that help structure the phased implementation of the initiative.

2026 Annual Plan

The 2026 annual plan is a phase focused on structuring and preparing the digital accessibility initiative.

The planned actions include the following:

• strengthening digital accessibility governance;
• continuing to raise awareness among internal teams about RGAA issues;
• gradual integration of accessibility requirements into ongoing projects;
• Identification and prioritization of digital services within the scope of the audit;
• preparing the guidelines and materials needed for the upcoming redesign of the Group platform.

2027 Annual Plan

The year 2027 marks a pivotal milestone in the implementation of the Group Banque Richelieu’s digital accessibility initiative, as part of its digital transformation program.

The planned actions are as follows:

• design, development, and implementation of the Group Banque Richelieu’s new digital platform, which consolidates the existing websites of the Group Banque Richelieu’s entities;
• Incorporation of RGAA requirements starting from the design phase of the new platform (“accessibility by design” approach);
• supporting project teams in implementing best practices for digital accessibility;
• conducting an RGAA 4.1.2 accessibility audit of the new single-group platform and the digital services within its scope;
• analysis of the audit results and development of a corrective action plan, if necessary;
• Updating the accessibility statements for the relevant services following the audit.