VR ASSET MANAGEMENT, a VR CORPORATENEXT S.r.l. firm, including its future subsidiaries, actual branches, and ramifications, affirms its unwavering commitment to ensuring that the platforms, services and activities deployed via VR systems, all associated digital applications, and customer services are accessible, usable, and inclusive for every individual regardless of disability, age, cognitive ability, technological literacy, or geographic location.

 

Accessibility is not treated as an afterthought or optional add-on but as a foundational principle that informs every aspect of our service and advisory design, development and governance. This commitment reflects both a legal duty and an ethical responsibility to uphold the rights of persons with disabilities as articulated under the Convention on the Rights of Persons with Disabilities (UN CRPD), global accessibility laws, and our corporate mission to make emotional intelligence technology universally available and empowering.

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 GLOBAL LEGAL FRAMEWORK AND COMPLIANCE OBLIGATION. 

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VR ASSET MANAGEMENT, a VR CORPORATENEXT S.r.l. firm, recognises the European Accessibility Act, established by Directive (EU) 2019/882, as a central component of its accessibility compliance framework. The Directive introduces harmonised accessibility requirements for specified products and services made available within the European Union, with the objective of improving the functioning of the internal market while strengthening accessibility for persons with disabilities.

VR assesses the applicability of the EAA to its products, services, and business activities and seeks to ensure that all relevant accessibility obligations are identified, implemented, documented, and periodically reviewed. Where applicable, this includes consideration of accessibility requirements relating to user interfaces, digital information, electronic commerce, customer support, identification and authentication processes, and other relevant service components.

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VR ASSET MANAGEMENT, a VR CORPORATENEXT S.r.l. firm, is committed to incorporating accessibility requirements throughout the design, development, testing, deployment, and maintenance lifecycle. This includes identifying potential accessibility barriers, implementing appropriate technical and organizational measures, and maintaining documentation demonstrating the accessibility measures adopted.

VR also recognizes that compliance with the EAA depends on the specific nature of the product or service, the applicable legal classification, the relevant economic operator's role, and any applicable exemptions or transitional provisions. Accordingly, compliance assessments are conducted with reference to the requirements applicable to the relevant activities and jurisdictions.

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INTERNATIONAL ACCESSIBILITY STANDARDS AND TECHNICAL GUIDELINES.

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To support a consistent and measurable approach to accessibility, VR ASSET MANAGEMENT, a VR CORPORATENEXT S.r.l. firm, considers internationally recognised standards and technical guidelines, including the Web Content Accessibility Guidelines (WCAG), published by the World Wide Web Consortium (W3C).

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Where applicable to the relevant digital products and services, VR ASSET MANAGEMENT, a VR CORPORATENEXT S.r.l. firm, uses WCAG 2.2 Level AA as a technical reference for evaluating and improving digital accessibility. This approach supports the implementation of the four fundamental accessibility principles:

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• Perceivable: Information and user interface components must be presented in ways that users can perceive, including through appropriate text alternatives, captions, contrast, and adaptable content.

• Operable: Interfaces and navigation mechanisms must be usable through different interaction methods, including keyboard navigation and assistive technologies.

• Understandable: Information, instructions, and interface behaviour should be clear, consistent, and predictable.

• Robust: Digital content should be compatible with a range of browsers, devices, assistive technologies, and relevant accessibility-supporting technologies.

 

VR may also consider applicable European harmonised standards and technical specifications, including EN 301 549, where relevant to the products, services, or procurement requirements under assessment. The applicable version and any associated legal presumption of conformity are determined by reference to the relevant regulatory framework, according to:
 

• WCAG 2.2 Level AA: the Company's stated technical target, covering applicable Level A and Level AA success criteria.

• EU and Italian Compliance: determined separately by the legislation applicable to the specific service. WCAG 2.2 AA alone does not establish compliance with every requirement of EN 301 549 or the European Accessibility Act.

• Third-Party content: Article 1(5)(d) of Italian Legislative Decree No. 82/2022 contains a specific exclusion for certain third-party website and app content that is neither funded nor developed by, nor under the control of, the relevant economic operator. Its application depends on the facts and the statutory scope.

• Technical standards: AgID's 2026 guidance on services under the European Accessibility Act should also be considered where the Company falls within the relevant framework.

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NATIONAL AND REGIONAL LEGAL REQUIREMENTS.

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In addition to European Union requirements, VR ASSET MANAGEMENT, a VR CORPORATENEXT S.r.l. firm, considers relevant national legislation and regulatory obligations in the markets in which it operates or makes its products and services available.

This may include applicable national accessibility laws, disability rights legislation, anti-discrimination requirements, public-sector digital accessibility rules, consumer protection obligations, and regulations governing electronic communications or digital services.

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Where the VR's activities fall within the scope of Italian accessibility legislation, the applicable provisions are assessed in conjunction with the relevant European requirements. VR recognises that the precise obligations may vary according to the type of service, the intended users, the organisational role of the provider, and the applicable statutory conditions. For operations involving other jurisdictions, VR evaluates relevant local requirements and incorporates additional controls where necessary to address jurisdiction-specific obligations.

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GOVERNANCE, ACCOUNTABILITY AND RISK MANAGEMENT.

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VR ASSET MANAGEMENT, a VR CORPORATENEXT S.r.l. firm, establishes Accessibility Governance as an integral component of its corporate Governance, compliance, and responsible technology management framework. VR's approach is designed to ensure that accessibility considerations are incorporated into strategic decision-making, operational processes, product development, service delivery, and ongoing Risk Assessment.

Accessibility Governance is overseen by a designated Accessibility Officer, working in coordination with the Data Protection Officer (DPO), where appointed, and the Executive Board. This Governance structure supports cross-functional accountability, promotes consistent implementation of accessibility requirements, and facilitates the identification and resolution of accessibility-related risks across VR's operations.

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The Accessibility Officer is responsible for coordinating accessibility initiatives, monitoring the implementation of applicable accessibility requirements, facilitating assessments and audits, and reporting material findings to the relevant Governance bodies. The role also supports developing internal accessibility policies, technical guidance, remediation plans, and awareness initiatives for relevant personnel.

The DPO contributes within the scope of the role's responsibilities, particularly where accessibility intersects with personal data protection, assistive technologies, user profiling, sensitive user information, or the processing of data collected through accessibility-related features.

 

Accessibility Governance and Data Protection Governance remain complementary but distinct disciplines, each subject to its respective legal and organisational requirements.

The Executive Board retains oversight of strategic priorities, material compliance exposures, resource allocation, and significant risks associated with accessibility. It ensures accessibility receives appropriate consideration within corporate objectives, business planning, and VR ASSET MANAGEMENT, a VR CORPORATENEXT S.r.l. firm, broader Risk Management processes.

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DISASTER RECOVERY AND ACCESSIBILITY CONTINUITY.

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VR ASSET MANAGEMENT, a VR CORPORATENEXT S.r.l. firm, recognises accessibility continuity as an essential component of its business continuity, disaster recovery, operational resilience, and service availability framework. VR acknowledges that system outages, infrastructure failures, cybersecurity incidents, telecommunications disruptions, natural disasters, and other emergency situations may disproportionately affect individuals with disabilities if accessible services and alternative communication channels are not maintained.

Accordingly, the VR's disaster recovery and business continuity planning incorporates accessibility requirements to support continued, equitable access to essential information, services, and communication mechanisms during periods of disruption. VR ASSET MANAGEMENT, a VR CORPORATENEXT S.r.l. firm, considers accessibility continuity throughout emergency preparedness, incident response, recovery, and post-incident review.

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The objective is to ensure that emergency measures do not introduce unnecessary barriers, compromise the accessibility of critical information, or prevent users with disabilities or impairments from accessing essential services and support.

These arrangements are designed to complement VR's applicable legal obligations, contractual commitments, service-level agreements, and documented business continuity and disaster recovery procedures.

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THIRD-PARTY CONTENT AND LIABILITY.

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VR ASSET MANAGEMENT, a VR CORPORATENEXT S.r.l. firm, endeavours to ensure that its digital services, platforms, integrations and content are accessible to persons with disabilities, in accordance with the accessibility requirements applicable to VR and its services under applicable European Union and Italian law, including, where applicable, Legislative Decree No. 82 of 27 May 2022, Directive (EU) 2019/882 and other applicable accessibility legislation.

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Certain third-party integrations, externally supplied content, legacy materials or user-generated content may contain accessibility barriers or may not fully conform to applicable accessibility requirements. Where such barriers are identified or brought to VR's attention, VR will assess them and, to the extent required by applicable law and reasonably within its control, take appropriate measures to provide accessible alternatives, reasonable accommodations where legally required, or alternative means of accessing the relevant information or functionality. VR ASSET MANAGEMENT, a VR CORPORATENEXT S.r.l. firm, will also take appropriate steps to address the barriers, including by engaging with the relevant third-party provider, implementing available workarounds or replacing or modifying the affected component where appropriate.

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VR will use reasonable efforts to select and monitor relevant third-party providers, address accessibility issues within its control, and progressively remediate identified barriers in accordance with applicable legal requirements. Where the VR ASSET MANAGEMENT, a VR CORPORATENEXT S.r.l. firm, is legally responsible for the relevant service or content, the use of third-party technology, services or materials shall not, in itself, relieve VR of its statutory obligations.

Nothing in this clause shall exclude or limit any liability, duty or remedy to the extent that such exclusion or limitation is prohibited by applicable law, including mandatory accessibility requirements, applicable consumer-protection provisions and Art. 1229 of the Italian Civil Code. Any exemption or limitation relating to a specific accessibility requirement may be relied upon only where expressly permitted by applicable law and where all applicable conditions, assessments, documentation and notification requirements have been satisfied.

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Users who encounter an accessibility barrier may contact VR through its designated accessibility contact channel, describing the affected service or content and, where possible, the barrier encountered and the alternative access method required. VR will review such reports and take appropriate follow-up action in accordance with applicable law.

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UPDATES AND PUBLIC ACCOUNTABILITY.

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This Accessibility Statement is reviewed annually and updated whenever regulations, technologies, or organisational practices change in a material way. Updates are communicated through the VR ASSET MANAGEMENT, a VR CORPORATENEXT S.r.l. firm, website and published in transparency reports.

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VR ASSET MANAGEMENT, a VR CORPORATENEXT S.r.l. firm, monitors accessibility not only internally but also publicly. A public accessibility dashboard displays metrics such as compliance rates, resolved issues, pending complaints, and independent audit outcomes, holding VR ASSET MANAGEMENT, a VR CORPORATENEXT S.r.l. firm, accountable to users and regulators.

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