Accessibility Policy

2.1 Web Content Accessibility Guidelines (WCAG)

PawPass targets conformance with the Web Content Accessibility Guidelines (WCAG) 2.1 at Level AA, as published by the World Wide Web Consortium (W3C) Web Accessibility Initiative (WAI). WCAG 2.1 Level AA is the internationally recognized benchmark for digital accessibility and is referenced by accessibility legislation in numerous jurisdictions worldwide. WCAG 2.1 is organized around four core principles, which state that web content must be:

• Perceivable: Information and user interface components must be presentable to users in ways they can perceive, including through assistive technologies such as screen readers.
• Operable: User interface components and navigation must be operable, meaning that all functionality must be accessible via keyboard and must not require interactions that users cannot perform.
• Understandable: Information and the operation of the user interface must be understandable to users of varying abilities and cognitive profiles.
• Robust: Content must be robust enough to be reliably interpreted by a wide variety of user agents, including assistive technologies, as technology evolves.

2.2 Applicable Legal and Regulatory Frameworks

PawPass's accessibility obligations and commitments are informed by the following legal and regulatory frameworks, among others: United States

• Section 508 of the Rehabilitation Act of 1973, as amended (29 U.S.C. § 794d), which requires federal agencies and certain recipients of federal funding to make electronic and information technology accessible to people with disabilities.
• Title III of the Americans with Disabilities Act of 1990 (ADA), which prohibits discrimination on the basis of disability in places of public accommodation. Courts and regulators in the United States have increasingly applied the ADA's non-discrimination obligations to websites and digital services.
• The 21st Century Communications and Video Accessibility Act (CVAA), where applicable to digital communications and video content.

European Union

• Directive (EU) 2016/2102 on the accessibility of websites and mobile applications of public sector bodies, and its implementing standards referencing EN 301 549.
• Directive (EU) 2019/882 on the accessibility requirements for products and services (European Accessibility Act / EAA), which applies to private sector entities providing services to consumers in the EU and will be progressively enforced from June 2025 onward.
• The European standard EN 301 549, which incorporates WCAG 2.1 Level AA as the baseline for digital accessibility.

United Kingdom

• The Equality Act 2010, which requires service providers to make reasonable adjustments for disabled persons to ensure they are not placed at a substantial disadvantage compared to non-disabled persons.
• The Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 (as applicable to public sector bodies operating in the UK).

Other Jurisdictions PawPass acknowledges that additional accessibility obligations may apply in other jurisdictions where users access the Platform, including Canada (Accessible Canada Act, AODA), Australia (Disability Discrimination Act 1992), and other national and regional frameworks. PawPass endeavors to meet a standard of accessibility that satisfies the requirements of the major jurisdictions in which it operates.

3.1 Conformance Status

PawPass is actively working toward full conformance with WCAG 2.1 Level AA across all Platform interfaces. As of the Effective Date of this Policy, the Platform partially conforms to WCAG 2.1 Level AA. "Partial conformance" means that some parts of the Platform do not fully meet the standard, and we are engaged in an ongoing program to identify and remediate accessibility barriers. PawPass conducts periodic accessibility audits and evaluations to assess the current state of accessibility on the Platform. The findings of these audits inform our remediation roadmap and prioritization of accessibility improvements.

3.2 Platform Features Assessed for Accessibility

The following Platform features and components have been assessed as part of our current accessibility evaluation:

• Homepage and primary navigation menus.
• User registration and login flows.
• Pet profile creation and management interface.
• Partner search and listing browsing.
• Service booking and checkout flows, including payment pages.
• Account settings and subscription management.
• E-booklet and pet health record interface.
• Blog and editorial content pages.
• Contact and support pages.
• Cookie consent and preference management interface.

3.3 Known Accessibility Limitations

PawPass acknowledges the following known accessibility limitations that are currently being addressed through our remediation program. Users who encounter these limitations are encouraged to contact us using the mechanism described in Section 7 of this Policy so that we can provide an accessible alternative or expedite remediation:

• Third-party payment widget: The Stripe Elements payment input widget is provided by Stripe, Inc. and operates within an iframe hosted on Stripe's domain. While Stripe implements accessibility features within its payment widget, PawPass has limited ability to directly modify Stripe's hosted UI components. Users who encounter accessibility barriers within the payment flow should contact us at office@pawpass.rs for alternative payment assistance.
• Partner-submitted listing images: Images submitted by Partners to their Listings may not always include descriptive alternative text, as this depends on Partners providing appropriate descriptions when uploading content. PawPass is implementing guidance and tooling to prompt Partners to add alternative text when uploading images.
• Older blog content: Some older editorial content published on the Platform's blog section may not fully meet current accessibility standards with respect to heading hierarchy, link text, or image alternative text. These pages are being reviewed and updated on a rolling basis.
• PDF documents: Any PDF documents linked from the Platform may not be fully accessible to screen reader users. Where PDFs are identified as inaccessible, accessible HTML versions or plain text alternatives will be made available upon request.
• Video content: Video content published on the Platform may not currently include closed captions or audio descriptions in all cases. PawPass is working to ensure that all new video content is published with captions and that existing video content is retrospectively captioned.
• Mobile application: The PawPass mobile application (where available) is undergoing an independent accessibility audit. Known accessibility improvements identified during the audit will be addressed in future application updates.

4.1 Visual Accessibility

PawPass has implemented or is working to implement the following visual accessibility features:

• Sufficient color contrast ratios between text and background colors to meet WCAG 2.1 Level AA minimum contrast requirements (4.5:1 for normal text, 3:1 for large text).
• Text content that can be resized up to 200 percent using standard browser zoom functionality without loss of content or functionality.
• The Platform does not rely solely on color as the means of conveying information, indicating an action, or distinguishing visual elements.
• Focus indicators visible when navigating the Platform using a keyboard, enabling users who do not use a mouse to identify the currently focused interactive element.
• No content that flashes more than three times per second, to reduce the risk of triggering photosensitive epileptic seizures.

4.2 Screen Reader Compatibility

PawPass is working toward compatibility with major screen reader software, including but not limited to:

• NVDA (NonVisual Desktop Access) with Mozilla Firefox on Windows.
• JAWS (Job Access With Speech) with Google Chrome and Microsoft Edge on Windows.
• VoiceOver with Safari on macOS and iOS.
• TalkBack with Google Chrome on Android.

Accessibility features implemented to support screen reader users include:

• Semantic HTML markup using appropriate heading levels (H1 through H6) to provide document structure that screen readers can navigate.
• Alternative text attributes (alt text) for informational images, to convey image content to screen reader users.
• ARIA (Accessible Rich Internet Applications) landmark roles, labels, and live regions applied to dynamic and interactive components where native HTML semantics are insufficient.
• Form fields labeled with associated label elements or ARIA label attributes to enable screen readers to announce field purposes.
• Error messages associated with the relevant form field via ARIA attributes and announced to screen reader users dynamically.
• Decorative images marked with empty alt attributes to prevent screen readers from announcing irrelevant content.

4.3 Keyboard Accessibility

PawPass aims to ensure that all Platform functionality is operable using a keyboard alone, without requiring a mouse or other pointing device. Keyboard accessibility features include:

• All interactive elements (links, buttons, form fields, dropdowns, modals) are focusable and operable using standard keyboard navigation (Tab, Shift+Tab, Enter, Space, and arrow keys as appropriate).
• A logical and predictable tab order that follows the visual layout of the page, enabling keyboard users to navigate efficiently.
• No keyboard traps that prevent keyboard users from navigating away from a component or section of the Platform.
• Skip navigation links provided at the top of each page to enable keyboard users to bypass repetitive navigation menus and proceed directly to main content.
• Modal dialogs that trap focus within the dialog while open and return focus to the triggering element upon closure.

4.4 Cognitive and Reading Accessibility

PawPass incorporates the following features to support users with cognitive disabilities, reading difficulties, or low literacy:

• Plain language principles applied to all primary user-facing content, instructions, and error messages, minimizing the use of jargon and complex sentence structures.
• Consistent navigation structure and page layout across the Platform to reduce cognitive load and enable users to predict where content and functionality will be found.
• Clear, descriptive link text that identifies the destination or purpose of each link, without reliance on non-descriptive phrases such as "click here" or "read more".
• Error messages that clearly identify the field in error and provide guidance on how to correct the input.
• Adequate time limits for completing forms and transactions, with the ability to extend time limits where technically feasible and where a time limit is not essential to the service.
• No content that starts automatically and cannot be paused, stopped, or hidden by the user.

4.5 Language and Internationalization

The Platform specifies the primary human language of each page in the HTML lang attribute, enabling screen readers to select the appropriate language-specific voice profile and pronunciation rules. Where pages contain content in multiple languages, the language of that content is identified using appropriate lang attributes. The Platform supports multiple languages, as indicated by the language selector in the navigation menu. Language-specific content is reviewed for accessibility in the primary supported languages. Users who experience accessibility issues in a specific language version of the Platform are encouraged to report them using the contact mechanism in Section 7.

4.6 Responsive and Mobile Accessibility

The Platform is designed to be responsive across a range of device types and screen sizes, including desktop computers, tablets, and mobile phones. Responsive design features include:

• Content that reflows to a single column when viewed on narrow screens without requiring horizontal scrolling, except for content that inherently requires two-dimensional layout.
• Touch targets of sufficient size and spacing to be operable by users with motor impairments using touch-screen devices.
• Support for both portrait and landscape orientations on mobile devices, without restricting content to a single orientation.
• Compatibility with mobile operating system accessibility features, including iOS Dynamic Type (text size adjustment) and Android font size settings.

6.1 Internal Accountability

PawPass has designated an internal point of contact responsible for overseeing accessibility compliance, managing the remediation roadmap, responding to user accessibility feedback, and coordinating accessibility testing and audit activities. Accessibility responsibilities are integrated into the Platform development process, with accessibility requirements included in design and development specifications for all new features and significant Platform updates.

6.2 Accessibility Testing Approach

PawPass employs the following methods to evaluate and improve the accessibility of the Platform:

• Automated accessibility scanning: Automated tools are used to perform initial scanning of Platform pages for common, detectable accessibility issues. Automated tools can identify a portion of WCAG 2.1 Level AA issues but cannot assess all accessibility criteria. Automated scanning results are used to prioritize manual testing efforts.
• Manual expert review: Qualified accessibility specialists conduct manual reviews of key user journeys and Platform components against WCAG 2.1 Level AA criteria. Manual review is necessary to assess accessibility dimensions that cannot be evaluated by automated tools, including logical focus order, meaningful link text, cognitive accessibility, and screen reader usability.
• Assistive technology testing: Platform components are tested with representative screen readers and other assistive technologies to verify real-world usability for users with disabilities.
• User feedback: Feedback submitted through the accessibility feedback mechanism described in Section 7 is reviewed and assessed to identify accessibility barriers that may not have been detected through internal testing.

6.3 Remediation Prioritization

Accessibility issues identified through audits, testing, and user feedback are prioritized for remediation based on the following criteria:

• Severity: Issues that prevent users with disabilities from completing critical tasks (such as registering, booking, or making a payment) are treated as highest priority.
• Breadth of impact: Issues affecting commonly used pages or features, or affecting a wide range of assistive technologies or disability types, are prioritized over issues affecting rarely used functionality.
• Legal risk: Issues implicated by specific legal requirements in applicable jurisdictions are prioritized in accordance with the applicable compliance timeline.
• Technical complexity: Where issues of equal severity and impact vary in technical complexity, simpler remediations may be implemented first to achieve early improvement in user experience.

PawPass maintains an internal accessibility remediation roadmap with target timelines for addressing identified issues. This roadmap is reviewed and updated on a quarterly basis.

6.4 Procurement and Third-Party Components

When procuring third-party software components, plugins, or services that become part of the Platform's user experience, PawPass includes accessibility requirements in its evaluation criteria and requests accessibility conformance information (such as a Voluntary Product Accessibility Template, or VPAT) from vendors. PawPass works with third-party vendors to address accessibility issues within their components and, where a vendor cannot remediate an issue within a reasonable timeframe, seeks alternative accessible solutions.

6.5 Staff Training

PawPass provides accessibility awareness training to personnel involved in designing, developing, and maintaining the Platform. Training covers the foundational principles of WCAG 2.1, common accessibility barriers and how to avoid them, use of assistive technologies to evaluate accessibility, and processes for responding to accessibility feedback and escalating issues for remediation.

7.1 How to Report an Accessibility Barrier

PawPass welcomes feedback from users who encounter accessibility barriers on the Platform. If you experience difficulty accessing any feature, page, or content on the Platform due to a disability or because the Platform is incompatible with your assistive technology, please contact us using the following details: Email: office@pawpass.rs Subject line: Accessibility Feedback Website: https://www.pawpass.rs/en When submitting accessibility feedback, it is helpful to include the following information, where possible:

• A description of the accessibility barrier you encountered.
• The URL of the page or the name of the feature where the barrier occurred.
• The assistive technology and browser or operating system you were using.
• A description of what you were trying to accomplish when you encountered the barrier.
• Your preferred contact method and any reasonable accommodation you are requesting.

You are not required to provide all of the above information to submit an accessibility report. We will accept and act upon any accessibility feedback received, regardless of the level of detail provided.

7.2 Response Commitment

PawPass is committed to acknowledging all accessibility feedback within five (5) Business Days of receipt. We will provide a substantive response describing our assessment of the reported issue and any planned or completed remediation steps within twenty (20) Business Days, except where the complexity of the issue requires a longer investigation period, in which case we will communicate an estimated timeline. Where an accessibility barrier prevents you from completing a critical task on the Platform, we will use commercially reasonable efforts to provide an accessible alternative means of completing that task (for example, completing a booking or processing a payment by email or telephone) while the barrier is being remediated.

7.3 Escalation and Formal Complaint

If you are not satisfied with PawPass's response to your accessibility feedback, or if you believe that PawPass's accessibility practices violate applicable law, you may escalate your complaint as follows: United States Complaints regarding ADA compliance may be submitted to the U.S. Department of Justice, Civil Rights Division, Disability Rights Section. Information on filing ADA complaints is available at https://www.ada.gov. European Union Complaints regarding compliance with the European Accessibility Act or Directive (EU) 2016/2102 may be submitted to the competent national market surveillance authority or enforcement body in the relevant EU member state. United Kingdom Complaints regarding compliance with the Equality Act 2010 may be submitted to the Equality and Human Rights Commission (EHRC). Information is available at https://www.equalityhumanrights.com. All Jurisdictions Users may also seek legal advice from a qualified attorney in their jurisdiction regarding their rights under applicable accessibility and disability discrimination law. PawPass cooperates fully with regulatory inquiries and formal complaints and is committed to resolving accessibility issues in good faith.