Accessibility Policy

1. Commitment to Accessibility

BRRM DOO, Intelligent Systems GmbH and Triebwerk Automotive GmbH (hereinafter: The Companies) are committed to making all their digital products and services, including the Catch Photo App and related web services and platforms, accessible and usable by all users, including those with various types of disabilities or reduced functional abilities.

The Companies’ goal is to:

• ensure equal access and usability of applications, websites, and digital content for all individuals, including those with physical, sensory, cognitive, intellectual, or neurodivergent impairments;
• in accordance with the requirements of Directive (EU) 2019/882 (European Accessibility Act) and the relevant national legislation in EU member states (e.g., BGG and BITV in Germany and the Web-Zugänglichkeits-Gesetz in Austria), as well as the WCAG 2.1 Level AA guidelines, undertake all necessary technical, organizational, and procedural measures in the development, design, testing, and deployment of digital products and services to achieve a high level of accessibility and ensure continuous improvement in compliance with applicable laws and best practices;
• actively monitor, test, and improve the accessibility of its digital solutions;
• incorporate accessibility as an integral part of the development process and quality management at all stages: planning, design, implementation, testing, and deployment of digital products and services.

The Companies’ focus is to ensure:

• digital services that are operable, understandable, perceivable, and robust to technological changes,
• an equal level of user experience for all users, including those using assistive technologies (screen readers, keyboards, voice control systems, etc.),
• continuous improvement of accessibility through team education, regulatory monitoring, and collaboration with experts and end users.

2. Scope of Application

This Accessibility Policy applies to all digital products and services developed, distributed, sold, or maintained by the Companies, either independently or in cooperation with affiliated legal entities and partners, including, but not limited to:

• the mobile application Catch Photo App,
• associated cloud services, web portals, and administrative panels,
• website https://www.brrm.eu/
• all other current and future digital products and services intended for users in the territory of the Republic of Serbia, the European Union, and other international markets.

3. Accessibility Standards and Legal Framework

The Companies strive to achieve full compliance with applicable legal and technical requirements in the field of digital accessibility, including:

• the Web Content Accessibility Guidelines (WCAG) version 2.1, Level AA, as an internationally recognized standard for designing and developing accessible digital products and services;
• the relevant national accessibility legislation in the European Union member states where BRRM d.o.o. directly or through its affiliated legal entities and partners offers its services and products, including, but not limited to:
  • BGG and BITV in the Federal Republic of Germany,
  • the Web Accessibility Act (Web-Zugänglichkeits-Gesetz) in the Republic of Austria,
  • as well as all other regulations and guidelines arising from Directive (EU) 2019/882 (European Accessibility Act).

In order to achieve and maintain compliance with the aforementioned standards and regulations, the Companies will continuously monitor changes in the regulatory framework and technical guidelines, and will regularly adapt its internal policies, development processes, and product maintenance to ensure a high and lasting level of accessibility for all users.

4. Responsibilities

To achieve a high level of accessibility in all digital products and services, the Companies clearly define the internal allocation of responsibilities:

• The development team is responsible for planning and implementing accessible solutions in all stages of product and service development, including architecture, user interface design, front-end, and back-end functionalities, in accordance with applicable accessibility standards and guidelines.
• The QA team is responsible for conducting thorough accessibility testing before releasing any digital product into production, using a combination of automated tools and manual tests (including testing with assistive technologies such as screen readers, keyboard navigation, and others).
• The company management is responsible for providing the necessary resources, tools, and organizational conditions required to achieve accessibility, including planning and organizing regular employee training, as well as overseeing the implementation of the accessibility policy at the company level.

5. Processes and Tools

To achieve and maintain compliance with applicable accessibility standards, the Companies will introduce and apply the following processes and tools as part of its regular development cycle:

• Integration of accessibility testing into all stages of digital product development, including planning, design, implementation, and final testing, through the application of the so-called "shift-left" approach, which enables early detection and resolution of accessibility issues.
• Regular use of specialized tools for accessibility verification and validation, such as:
  1. axe (automated accessibility analysis in the browser),
  2. WAVE (Web Accessibility Evaluation Tool),
  3. Google Lighthouse (automated testing for web applications),
  4. as well as other tools and methods that prove relevant and effective in further developing accessibility practices.
• Consultation with external accessibility experts and inclusion of feedback from users with disabilities as needed, especially during major product upgrades or in phases of redesign and preparation of new versions of the application and web services.

6. Training and Awareness

The Companies recognize that continuous improvement of employees' knowledge and skills is a key factor for the successful implementation of accessibility principles. To this end:

• The Companies will organize and conduct formal training sessions and internal workshops at least once a year for all members of teams involved in the development, design, testing, and maintenance of digital products and services.
• The training will cover:
  • basic principles and requirements of accessibility,
  • specific techniques for implementing accessible solutions within design and development processes,
  • practical examples and the use of relevant tools for accessibility testing.
• In addition to the planned annual training, additional training will be organized as needed, in case of significant changes in the regulatory framework, technological innovations, or major product upgrades.

7. Monitoring and Revision

To ensure a consistent and sustainable level of accessibility, the Companies will conduct regular monitoring and revision of this Accessibility Policy and its practical implementation:

• The Accessibility Policy will be formally reviewed at least once a year, and more frequently if necessary, in the event of significant changes to the relevant legal or technical framework, new guideline versions (e.g., new versions of WCAG), or based on feedback from users and partners.
• Accessibility reports on the status of digital products will be prepared:
  • as needed, during regular product development and improvement cycles,
  • at the request of business partners, clients, or regulatory bodies,
  • as part of preparations for the release of new product versions containing significant changes in functionality or user interface.
• The reports will document: the current state of compliance, activities carried out, planned improvement measures, and any identified barriers.

Conclusion

The Companies are firmly committed to the principles of digital accessibility and equal access for all users of its products and services. This Accessibility Policy provides the basic framework for achieving this goal and defines the Companies’ course of action in accordance with applicable legislation and international best practices.

The Companies’ management recognizes the importance of the continuous improvement of accessibility and is committed to providing all necessary resources for the implementation of this policy.

The implementation and compliance with the provisions of this Policy is the responsibility of all the Companies’ employees involved in the development, design, testing, distribution, and support of digital products and services.

This Policy enters into force on the date of its adoption by the authorized person and will be published and made available to all employees and relevant parties.

This Policy was adopted on June 24, 2025, and is effective from the same date.