Accessibility

WEBSITE AND APPLICATION ACCESSIBILITY POLICY

Purpose

POLLPAPA, INC., a Georgia corporation and its affiliates and business units (collectively, the “Company,” “we,” “us,” or “our“) are committed to the concept of website and mobile application accessibility for all persons. In support of our commitment, we have developed this policy to be transparent about our mission in this regard and the considerations that we value in pursuit of this goal. If you have any questions relating to this policy or our websites or applications, please contact our Data Protection Officer, as noted below.

Definitions

“Authoring Tool” means web page editing tools, content management tools, development tools for applets, scripts, or applications, non-text media (e.g. video, audio, images) editing tools, and social media content authoring tools (e.g. blogs, wikis, social networks).

“Authoring Tool Accessibility Guidelines (ATAG)“ means accessibility requirements for web authoring tools, including software and services that are used to produce web content, such as HTML editors, content management systems (CMS), and online forums. ATAG guidelines outline how to make the tools accessible and how the tools can be built to help create more accessible content.

“Internal Website” means a website developed or procured to meet an internal business need, such as project supervision, timesheet management and emergency response. Access to such sites is only available to the Company’s employees and staff, both permanent and temporary.

“Public Website” means a website developed to support or inform the Company’s customers and members of the public.

“User Agents” means browsers, media players, and applications that render web content. “User Agent Accessibility Guidelines (UAAG)” means accessibility requirements for web

browsers, media players, and some assistive technologies that process and present web content to users.

“Web Content” means electronic documents, websites, services, and applications delivered via the web or via a mobile device.

“Web Content Accessibility Guidelines (WCAG)” means accessibility requirements for web and mobile content, including text, images, audio-visual materials, and the code used for structure, style, and interactions; currently at Version 2.1.

“Website” means websites, services, and applications created using Open Web Platform technologies. Note this includes web applications developed for either office and/or mobile platform delivery capabilities.

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Policy Statement

This policy does not specify or rely on any particular technology or design approach or principles. The Company’s goal is to maximize the access to and use of the Company websites and mobile applications by people with disabilities.

All new and redesigned web content published by the Company after the effective date of this policy, both for public and internal websites and services, will conform to WCAG Level AA success criteria, current version 2.1.

All existing web content published by the Company prior to the effective date of this policy will either be archived or modified to conform to WCAG 2.1 Level AA success criteria.

All internal content management systems (CMS) and web content authoring tools will conform to ATAG Level AA success criteria. Where websites, services, or applications provide users with the opportunity to generate content, the interfaces provided will conform to ATAG Level AA.

All internal user agents will conform to UAAG Level AA success criteria. Where user agents are used as part of a website, service, or application, such as a media player, they will conform to UAAG Level AA success criteria.

Reasons for This Policy

The World Health Organization estimates that there are more than one billion people living with disabilities, with over 100 million persons having significant difficulties in functioning (for more information, see www.who.int/disabilities/en).

Many of these disabilities can affect access to information technologies. Additionally, the same individuals who run into barriers that impede access to information technologies could benefit most from using them.

Given the importance of the internet, accessibility to the web is of critical importance to people with disabilities around the world, including people with auditory, cognitive, physical, neurological, and visual disabilities. It is likewise important to those with accessibility needs due to aging.

Providing accessible web content can also benefit people who do not have disabilities but who are experiencing situational barriers. For example, when accessing the internet from devices with small screens or in low bandwidth situations, or when experiencing barriers due to language or literacy levels, accessibility solutions can also support improved access.

The Company is committed to ensuring equal access for people with disabilities. As potential customers and employees of the Company, they are important contributors to the Company’s business success and should not be excluded, but rather welcomed into the Company family.

Team Responsibilities

Data Protection Officer/Supervisor:

Consolidate periodic status reports for presentations to the board of directors at periodic review meetings.
Prepare and provide accessibility training and guidance programs.
Promote web accessibility awareness internally.

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Respond to user inquiries to the Company related to web accessibility.
Organize ongoing assessments of the accessibility of websites, content, services, and applications that are within the scope of this policy.

Web Project Managers:

Oversee and monitor compliance with this policy.
Prepare project accessibility reports at key project implementation stages: analysis, design, development, and quality assurance.
Ensure that user feedback mechanisms are included as part of project deliverables.
Ensure that all staff members receive appropriate and regular accessibility awareness training.

Information and Communication Technologies (ICT) Department and Webmasters:

Choose and implement tools that conform to this policy.
Provide tools to support automated accessibility checking.
Remedy identified accessibility barriers or difficulties. Web Content Management Teams:
Ensure that all staff receive appropriate and regular accessibility training.
Ensure that submitted content complies with this policy.
Address/repair identified accessibility issues in proposed web content.

Exclusions from Accessibility Requirements

Web content that has been archived is not subject to the standards referenced in this policy. In the event that the Company should receive a specific request for access to archived content by any person with a disability, the responsible persons should endeavor to make that content available in a suitable format within thirty (30) business days. Where it is not technically possible to make the content available within that timeframe, a suitable alternative should be identified and provided, if the individual agrees. The department or team responsible for the creation of the content is also responsible for making that content accessible.

Procurement and Implementation

This policy applies to all web content developed by or for the Company. This policy should be referenced within any contract of services or statements of work applicable to web content, websites, services, or applications relating back to the Company.

Any contract must include a provision for an independent statement of conformance stating that the work meets the required standards determined in accordance with this policy. This goal should form part of the deliverables approval process for all related statements of work.

Third-Party Content

Elements of the Company websites might include web content syndicated/linked to from other providers (for example, a social media stream or third-party website).

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When considering a syndication service for inclusion in any of the Company websites, any service review should include an evaluation of the accessibility of the service. Such evaluations must form a part of the service selection criteria.

Where a service is selected with known accessibility issues, the Company will develop or procure a solution that ensures the content delivered via the Company websites meets these policy standards.

Reporting

Each Company department with responsibility for web content, websites, services, or applications, respectively, must submit an periodic status report to the Data Protection Officer.

These status reports will summarize the efforts and progress towards the goals defined by this policy.

Policy Reviews

This policy shall be reviewed at least once a year by the Data Protection Officer. The review process should include input from ICT, Marketing, HR, and Legal, plus others as appropriate.

Contacts

The Company’s Data Protection Officer can be reached at support@pollpapa.com.

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