Accessibility

The Noble Group’s website provides information on the trade, significance and market mechanisms of technology metals and rare earths. The focus is on production-critical commodities such as gallium, indium, germanium as well as neodymium oxide, dysprosium oxide and scandium oxide. The aim is to make this specialized market understandable to a wider audience and at the same time open up access to investment opportunities for private customers and companies.

Noble BC GmbH is the first company in Europe to fully map trading activities with these commodities on blockchain technology. This offers a particularly high standard of security for storage and trading. Customers can track their commodity purchases transparently via a digital wallet.

The website offers information on individual metals, current market developments, security concepts, and the use of blockchain technology. The information provided is aimed equally at private and industrial clients.

The website offers:

• Information on technology metals and rare earths, including gallium, indium, germanium and selected rare earth oxides
• Explanations on trading processes, storage and security concepts
• Insights into the company, its orientation and its technological approaches
• Information on market developments and fields of application in industry and technology
• Overviews of the product portfolio and possible uses of the services offered
• Contact options for private customers and companies

Navigation is carried out via the main menu and the footer. Central content is generally accessible within a maximum of three clicks.

This accessibility statement applies to the website published under the domain www.noble-elements.de as well as to all associated subpages and subdomains (e.g. blog.domain.de, app.domain.de), provided they are assigned to the same provider. The assignment is usually made via a joint imprint or via the contractual and technical responsibility of the same organization.

Responsible:

• Noble Elements Metallhandelsgesellschaft mbH
• Gneisenaustraße 83, 10961 Berlin
• info@noble-elements.de
• +49 30 20898486-0

Today, accessibility is a basic feature of modern websites – it is a quality feature, enhances the user experience and ensures legal security. Enabling complete accessibility for all groups of people is in line with our corporate understanding of digital responsibility and social participation.

For us, this specifically means:

• Semantically correct frontend: Clean HTML structures, meaningful ARIA roles, consistent component logic.
• Conceptual accessibility: Focus management, logical tab order, keyboard operation, understandable interactions.
• Editorial clarity: Understandable language, readable typography, descriptive links, alt texts.
• Accessible media: Videos with transcripts and subtitles, high-contrast thumbnails, visual descriptions where applicable.
• Technical assistance friendliness: Support for prefers-reduced-motion and other system-based user preferences.
• Sustainable development: Regular audits, action plans, and continuous maintenance of digital accessibility.

Our website is based on the following legal and normative foundations:

• Barrier-free Information Technology Ordinance (BITV 2.0)
• Act on Equal Opportunities for Persons with Disabilities (BGG)
• Directive (EU) 2016/2102
• WCAG 2.1 – aimed at conformance level AA+

Status: This website is currently undergoing a comprehensive accessibility audit.
Target: Conformance level WCAG 2.1 AA
Planned completion: July 2025

Currently, all content and functions are evaluated according to the four principles of WCAG 2.1:

• Perceivability
• Operability
• Understandability
• Robustness

Upon completion, we will:

• Document the actual degree of fulfillment
• List existing barriers
• Publish a binding action plan with a timeline

Status: This website has been checked for accessibility.
Performed by: ALEKS & SHANTU GmbH
Period: April 2026
Compliance level: The website is currently not fully compliant with the requirements of WCAG 2.1 at compliance level AA.

Parts of the website contain existing content that was published before April 1, 2026. Pursuant to Section 2 (3) BFSG, these are subject to grandfathering, which means that there is no direct legal obligation to make them fully accessible.

Irrespective of this, the aim is to gradually remove existing barriers and also adapt protected content to the requirements of WCAG 2.1 AA in the long term – insofar as this is technically and economically feasible.

Optimization Strategy

Our optimization strategy is based on WCAG 2.1, conformance level AA, and – where technically and editorially sensible – also strives for individual requirements of level AAA (AA+).

The goal is to continuously improve accessibility without restricting system stability or user experience. In doing so:

• New content and functions are designed to be barrier-free,
• Existing components are revised for accessibility during every technical, functional, or design overhaul,
• Content maintenance and updates are carried out by an accessibility-aware editorial team,
• voluntary enhancements in accordance with selected criteria of WCAG 2.1 Level AAA, provided that their implementation is justifiable in technical, design and economic terms.

This component-based and ongoing customization process serves to sustainably improve digital accessibility in line with the BFSG – without compromising system stability or user experience.

An overview of identified optimization potentials as well as planned measures with time references is documented in the following section of this declaration.

Status: This website has been checked for accessibility.
Performed by: ALEKS & SHANTU GmbH
Period: [e.g. April 2025]
Degree of fulfillment:

The website largely meets the requirements of WCAG 2.1 at conformance level AA.

As part of a comprehensive relaunch or targeted optimization measures, the web content was aligned technically, creatively, and editorially for barrier-free accessibility. Implementation was carried out according to current standards and taking the following aspects into account:

• Semantically correct HTML structures
• Low-barrier interactions and focus management
• Sufficient contrasts and scalable typography
• Keyboard accessibility
• Screen reader compatibility
• Descriptive alternative texts and structured content

Special features of individual components

In some cases, individual solutions were deliberately implemented to improve accessibility. These partially deviate from common standard patterns, but demonstrably fulfill the functional requirements of accessibility.

The relevant components are listed individually in the Planned measures section and – if necessary – documented with a justification for the deviation.

This website is currently undergoing a complete overhaul. An accessibility-optimized relaunch is planned and is expected to be published in November 2025.

The current version of this website does not meet the accessibility requirements of WCAG 2.1 at conformance level AA. Due to the upcoming new development, a comprehensive audit of the existing site was not carried out.

Note on transitional arrangement:
For economic and organizational reasons, an accessible revision of the existing site is not planned. Instead, a new, technically and editorially accessible website will be provided with the planned relaunch.

The new version will:

• developed according to the requirements of WCAG 2.1 at level AA,
• include voluntary enhancements in the spirit of an AA+ standard where applicable,
• undergo a complete accessibility audit,
• be supplemented in this statement with compliance level and action plan once published.

Transparency notice:
Until the new website is published, no specific information can be provided on the current state of accessibility. This statement serves as advance information on the upcoming relaunch and to document the strategic decision in favor of a complete redevelopment.

Despite extensive conformity with level AA, the aim is to continuously develop the website further and – where appropriate – also incorporate the requirements of WCAG level AAA (AA+):

This component-based and continuous adaptation process serves to sustainably improve digital accessibility in the sense of the BFSG – without compromising system stability or user experience.

The review was carried out according to the following procedure:

1. Manual Tests

• Keyboard operation
• Screen readers (VoiceOver, NVDA, JAWS)
• Focus management and visual orientation

2. Automated Tools

• axe
• Lighthouse
• WAVE

3. Conceptual Analysis

• Structure, navigation, semantic markup logic
• Assistive technology compatibility

4. Editorial Review

• Language, alternative texts, ARIA attributes, comprehensibility

More information on the test procedure

[Individual table]

The aim is to reliably fulfill the legal requirements of WCAG 2.1, level AA and also to implement elements from the extended area of digital accessibility (partly WCAG 2.1 AAA) – insofar as this is appropriate and technically feasible in the project context.

Implementation takes place within the framework of re-audits, module-related updates, and project-related maintenance processes. All relevant measures, deadlines, and responsibilities are documented transparently.

This website is optimized for current browser generations (e.g. Chrome, Firefox, Safari, Edge) and supports adaptive technologies such as screen readers and zoom functions. System settings (e.g. reduced movements) are taken into account where technically possible.

This website is currently undergoing an audit for digital accessibility. Optimization potential and planned measures are listed above.

If accessibility problems are identified that are not listed here, or if there are suggestions for improvement, notification is requested.

In order to process feedback specifically, it is helpful to name the affected page or function.

Contact:

• accessibility+noble-elements@aleksundshantu.com
• +49 30 40045775
• Response time: Within 10 working days

Variant 2: Audit Completed

This website has been tested for accessibility. In addition, a comprehensive re-audit is conducted once a year.

If further barriers are identified during the visit to the website or if suggestions for improvement become apparent, informal feedback is requested.

Contact:

• barrierefreiheit+noble-bc@aleksundshantu.com
• +49 30 40045775
• Response time: Within 10 working days

If no satisfactory solution is reached after contact has been made, a mediation procedure can be initiated in accordance with § 16 of the Disability Equality Act (BGG). The BGG mediation office mediates in conflicts regarding digital accessibility between affected persons and the responsible party of the website.

Contact the BGG mediation office:

• 030 18527-2805
• info@schlichtungsstelle-bgg.de
• www.schlichtungsstelle-bgg.de

The procedure is free of charge. Legal representation is not required.

This declaration on digital accessibility is based on a template provided by ALEKS & SHANTU GmbH . Its use is expressly permitted for your own web projects, provided that content adjustments (e.g. to audits, measures or responsibilities) are made correctly and no misleading impression of direct involvement by ALEKS & SHANTU GmbH is created.

This template does not constitute legal advice. All information is provided to the best of our knowledge, but without guarantee of completeness or legal validity.

A visible reference with a link to www.aleksundshantu.com is desired.