Multi-Year Digital Accessibility Plan

Introduction

Air Liquide Group is committed to gradually improving the accessibility of its digital services in order to guarantee all users - employees, partners, customers and third parties - equitable access to digital content and services, including people with disabilities.

This approach is fully aligned with the Group's strategy, which aims to promote responsible innovation that is inclusive and sustainable. By embedding digital accessibility in its practices, Air Liquide strengthens its commitment to inclusion, service quality and sustainable performance, consistent with its CSR ambitions and its governance requirements.

This approach falls within the scope of the legal and regulatory obligations applicable to digital accessibility, arising from the transposition of European Directive 2016/2102, notably those set out in loi n° 2005-102 du 11 février 2005 (Law of February 11, 2005 on equal rights and opportunities), loi n° 2016-1321 du 7 octobre 2016 (Law of October 7, 2016 for a Digital Republic) and décret n° 2019-768 du 24 juillet 2019 (Decree of July 24, 2019 on the accessibility of online public communication services), as well as the European and national texts that progressively strengthen these requirements.

For Air Liquide Group, digital accessibility represents:

• a driver of inclusion and service quality;
• an asset for attracting and retaining talent;
• a regulatory compliance requirement;
• a means of controlling legal and reputational risks.

This Multi-Year Digital Accessibility Plan covers the 2026-2028 period. It builds on the progress already made and establishes the general framework as well as the step-by-step roadmap for structuring the digital accessibility approach across the Group. This initiative concerns primarily France, but also, where necessary, the other countries in which the Group operates.

Overall organization of the approach

Air Liquide Group's digital accessibility approach is organized around five structuring pillars:

• Steer accessibility through clear, shared governance;
• Inform users, employees and internal champions;
• Train the teams concerned;
• Equip the business units and project teams;
• Apply accessibility in digital projects and deliverables.

This organization is designed to embed digital accessibility in a progressive, cross-functional and sustainable logic, considering the diversity of the Group's business lines, uses and digital environments.

The Multi-Year Digital Accessibility Plan is supplemented each year by:

• an annual action plan, detailing the actions planned for each workstream;
• an implementation review, presenting the progress made and the results obtained.

These documents are published in accessible formats and updated regularly.

Scope covered

Air Liquide Group's Multi-Year Digital Accessibility Plan covers all digital services under the Group's responsibility, insofar as they are used by natural persons (employees, partners or third parties).

This includes in particular:

• websites and portals intended for the external public;
• intranets, internal portals and tools;
• web and mobile applications, whether internal or external;
• business tools, collaborative platforms and SaaS services;
• office documents required for user information or procedures (HR documents, communications, PDFs, etc.);
• multimedia content (audio, video) distributed through the Group's digital channels;
• forms and transactional services.

In accordance with the regulations, the scope considers the exemptions provided for by the applicable texts (archives, content predating certain dates, disproportionate burden, etc.), which may be documented and justified where appropriate, in particular regarding the notion of disproportionate burden.

The workstreams of the Multi-Year Digital Accessibility Plan

“Steer” workstream

Objective: To establish and sustain a clear, shared and lasting governance of digital accessibility across the Group.

The “Steer” workstream aims to provide Air Liquide Group with a governance framework enabling the organization, coordination and monitoring of the digital accessibility approach over time. Its purpose is to guarantee that accessibility issues are consistently considered in strategic and operational decisions, in line with the applicable regulatory obligations.

In this context, the main role of governance is to:

• Define and update the scope of the digital services concerned.
• Set priorities according to usage, service visibility and regulatory requirements.
• Define the overall trajectory for accessibility remediation.

To achieve these objectives, governance allocates the resources required for the actions to be undertaken.

It also monitors the commitments made by the Group and is responsible for arbitrating the actions to be carried out.

​This workstream forms the foundation of the digital accessibility approach. It feeds, guides and regularly reassesses the other workstreams of the Multi-Year Digital Accessibility Plan, to embed the approach in a progressive, structured and sustainable logic.

“Inform” workstream

Objective: To meet regulatory information obligations and facilitate the adoption of the digital accessibility approach by users and employees.

The “Inform” workstream aims to guarantee the availability of clear, accessible and up-to-date information on the digital accessibility of the Group's services. It covers both the regulatory transparency requirements and the information actions needed for internal and external stakeholders to understand the approach.

In this framework, Air Liquide Group undertakes to publish and keep up to date the required regulatory documents, notably the Multi-Year Digital Accessibility Plan, the accessibility statements for the services concerned, and the information enabling users to contact the organization to report an accessibility issue or request an accessible alternative. This information is made available in accessible formats and in clearly identified locations.​

In parallel, progressive internal communication is being rolled out to raise employee awareness of digital accessibility issues, present the approach undertaken by the Group and clarify each party's roles and responsibilities in its implementation. This communication, conducted jointly by the accessibility officer and the Communications Department, together with CSR and the Disability Unit, is intended to support the gradual increase in team maturity.

“Train” workstream

Objective: To support the progressive upskilling of the teams involved in the design, implementation and management of digital services.

The “Train” workstream aims to lay the foundations of a shared digital accessibility culture within Air Liquide Group, in a context where the approach is just beginning and maturity levels are uneven.

The first step is to raise awareness of the issues and regulatory obligations relating to digital accessibility, then to offer targeted training to the profiles most directly involved.

Progressively, this workstream also aims to foster the emergence of internal champions able to embed accessibility in their teams' day-to-day practices. These champions are supported over time, in coordination with the other workstreams of the Multi-Year Digital Accessibility Plan, to consolidate skills and disseminate good practices, without presuming a level of maturity that is still being built.

“Equip” workstream

Objective: To progressively make operational resources available that facilitate the consideration of digital accessibility in the teams' activities.

The “Equip” workstream aims to provide project, Digital & IT, communication, business and support-function teams with benchmarks and resources that facilitate the integration of digital accessibility into the design, delivery and maintenance of services. In a context where formalized tools and processes remain limited, the challenge is to structure an initial base of shared resources and then to develop it progressively according to the needs identified and the lessons learned.

This base relies notably on making available internal guides and reference frameworks, templates, checklists and good practices adapted to the main types of projects and content. It may be supplemented, progressively, by identifying or using tools that facilitate the evaluation and monitoring of accessibility within existing environments (office tools, CMS, communication platforms, etc.).

The workstream also gradually incorporates accessibility criteria into procurement and contracting processes, to better govern external services and the digital solutions acquired by the Group.

“Apply” workstream

Objective: To concretely and progressively integrate digital accessibility into projects and services, following a controlled compliance trajectory.

The “Apply” workstream aims to translate the commitments of the Multi-Year Digital Accessibility Plan into operational terms within the Group's digital services. It builds on the actions already carried out since 2022, notably RGAA and WCAG audits: audits of the site airliquide.com, full audits of several main sites, editorial audits of child sites and the launch of prioritized audit waves - in order to structure a progressive approach to addressing gaps and securing the most exposed services.

In this framework, accessibility is progressively integrated into digital projects, from the upstream phases where possible, in liaison with the departments concerned, in order to limit the appearance of new gaps. For existing services, the workstream is based on a risk analysis (visibility, usage, regulatory exposure) that makes it possible to identify the services falling within the regulatory scope and to plan remediation actions in successive waves, drawing in particular on the audits carried out and on reference sites such as airliquide.com.

The actions undertaken are monitored over time: planning of corrections, pooling and reuse of recommendations where relevant, and documentation of the decisions taken, including any exemptions provided for by the regulations. This workstream thus helps to embed accessibility remediation in a continuous improvement logic, in line with the other workstreams of the Multi-Year Digital Accessibility Plan.

Annual action plan

The annual action plan translates the commitments of this Plan into operational terms for each workstream. It is updated each year and published separately.

The action plan may be adjusted to consider the priorities, constraints and lessons learned identified during implementation.

2022-2025 review

An implementation review is carried out each year to monitor the progress of the approach.