Copina Co. (the “Company”) is committed to ensuring full and equal access to the goods, services, facilities, privileges, advantages, and accommodations provided by and through its websites (“Websites”) and digital/mobile applications (“Mobile Applications”) through effective communication based on the Web Content Accessibility Guidelines 2.1 Level A and AA Success Criteria (the “WCAG 2.1”) from the Web Accessibility Initiative of the World Wide Web Consortium for all customers, potential customers, guests and their companions (collectively, “Customers”) with disabilities.

Maintenance of Policy.  The Company will review, update and maintain this Website Accessibility Policy on an annual basis or more frequently.

Version.  This Website Accessibility Policy is effective as of January 1, 2020 and supersedes all prior versions hereof.

Responsibility and Ownership of this Policy.The responsibility and ownership of this Website Accessibility Policy will be assigned to the Web Accessibility Coordinator.

Distribution of Policy.  The Company will, on an annual basis or more frequently, distribute this Website Accessibility Policy to all employees and contractors who have responsibilities for website content, mobile application content, technical support related to Company Websites or Mobile Applications.  This Website Accessibility Policy will be maintained and made available to affected Company employees and contractors in the same manner as similar policy documents affecting Company operations and Customer interaction.

Website and Mobile Application Accessibility Training. The Company will, on an annual basis or more frequently, provide training to website content personnel on how to achieve effective communication and conform website content and mobile applications with the WCAG 2.1.  Website content personnel shall also receive this training when they are hired into a position that includes such a role.

Web Accessibility Coordinator.  The Company will designate an employee as the Company’s Web Accessibility Coordinator:

• The Web Accessibility Coordinator will be knowledgeable with the requirements of Title III of the ADA, the WCAG 2.1, and website accessibility generally;
• The Web Accessibility Coordinator will hold the ultimate responsibility for ensuring the Company’s compliance with this Website Accessibility Policy;
• The Web Accessibility Coordinator will report directly to the Executive Owner;
• The Web Accessibility Coordinator will involve the appropriate Company departments in discussions and analyses regarding website and mobile content accessibility.
• The role, identity, existence and contact information for the Web Accessibility Coordinator will be publicized to employees, contractors and Customers in the ordinary channels relating to website access and use.

Automated Website and Mobile Application Accessibility Testing.  The Company will perform automated accessibility tests of its Websites and Mobile Applications at least once annually to identify any instances where its Websites and Mobile Applications are not in conformity with WCAG 2.1.  The results of this testing will be provided to the Web Accessibility Coordinator to be evaluated and addressed.

User Accessibility Testing.  The Company will perform, on an annual basis or more frequently, testing for usability of its Websites and Mobile Applications by individuals with different disabilities, including at a minimum individuals who are blind or have low vision, individuals who are deaf or hard of hearing and individuals who have physical disabilities affecting manual dexterity (such as those limiting the ability to use a mouse).  Testing shall include the use and access to the primary features of the Company’s Websites and Mobile Applications, such as the creation of an account, logging-in to an existing account, viewing goods, selecting items and placing them in the virtual shopping cart, checking out and paying for items in the virtual shopping cart, and scheduling delivery or pick-up.  The results of this testing will be provided to the Web Accessibility Coordinator to be evaluated and addressed.

Website Accessibility Consultant.  The Company shall retain an accessibility consultant which is knowledgeable about website and mobile content accessibility, development, structure and testing to serve as a resource for the Company’s existing development infrastructure.  The Website Accessibility Consultant will provide the Company advice on:

• Achieving WCAG 2.1 AA conformity for the Company’s Websites and mobile apps;
• Testing protocols, methodologies and result analysis;
• Internal Development Guideline best practices for ensuring the development, maintenance and updating of Website and Mobile Application content which conforms with WCAG 2.1 AA standards and achieves effective communication; and
• Company development team training to achieve conformity with WCAG 2.1 AA standards and effective communication.

Development Guidelines.  The Company shall create, maintain, and update Website and Mobile Application Development Guidelines that mandate effective communication through conformity with WCAG 2.1 AA standards where technically feasible.  The Development Guidelines shall treat the elimination of bugs that create accessibility barriers, including those that create nonconformance with WCAG 2.1 AA, with the same level of priority (e.g., speed, resources used to remediate) as any other equivalent loss of function for individuals without disabilities.

Complaint and Policy Modification Request Channel.  The Company shall provide an email and telephonic communication channel for its Customers to make complaints regarding the accessible features of the Websites or Mobile Applications, or to make a request for the Company to modify an existing policy. Complaints should be made to hello@copinaco.com and to 650515-9347. This complaint/modification request channel shall be prominently displayed and directly linked from the Websites’ homepages, with a statement of the Company’s policy to ensure that persons with disabilities have full and equal enjoyment of the goods, services, facilities, privileges, advantages, and accommodations of the Company through its Websites and its Mobile Applications.  The Websites homepages shall include an email address and a telephone number that customers with disabilities who are experiencing technical difficulties with the Websites or Mobile Applications can request assistance.  The Company will establish and maintain procedures to evaluate all disabled access-related requests for a new service or to modify an existing service to accommodate a Customer’s individual needs.  The Company will evaluate such requests on the basis of the Customer’s needs and disability and take action to fulfill such requests, propose an alternative or, if appropriate, deny the request.  Company agents will promptly communicate all website and mobile content complaints and policy modification requests to the Web Accessibility Coordinator, who will maintain and keep records of such requests.  The Web Accessibility Coordinator will review such requests to ensure that they are reasonably, promptly and effectively responded to.

Third Party Content.  If the Company uses or integrates third-party plug-ins or content in its Websites or Mobile Applications, then the Company shall obtain reasonable representations, warranties and assurances from such third-parties that the provided content conforms to WCAG 2.1 AA standards, and/or the Company shall undertake reasonable efforts to test and confirm that such content conforms to WCAG 2.1 AA standards.