Information on Accessibility pursuant to the Accessibility Strengthening Act (BFSG)

Hopf-Klinkmüller Capital Management GmbH & Co. KG offers fee-based subscriptions for price and market analyses via the website www.hkcm.com. The following information explains the accessibility of the website, the ordering and registration process as well as the protected customer area and describes the current status of implementation of the statutory accessibility requirements.

1. Provider and Scope of Application

The provider of the services offered via this website is:

HKCM GLOBAL GmbH & Co. KG

Turmstraße 30

CH - 6313 Steinhausen

E-mail: support@hkcmglobal.com

This information relates to the digital services offered at www.hkcmanagement.de. It covers in particular the publicly accessible pages of the website, the ordering and registration process, and the access-protected customer area.

2. Description of the Service

HKCM offers fee-based subscriptions for regularly updated price and market analyses. The analyses relate in particular to shares, indices, cryptocurrencies and commodities.

Users can select various analysis packages on the website, retrieve information on their content and term, and conclude a subscription online. To conclude and use a subscription, it is necessary to set up a customer account.

After the subscription has been concluded, the booked analyses can be retrieved via the personal customer area. In particular, chart analyses, written updates and, where part of the booked package, further analytical content are made available there.

3. Provision of the Service

The conclusion and use of a subscription generally takes place in the following steps:

1. Selection of an analysis package,

2. display of the key product and contract information,

3. adding the selected package to the shopping cart,

4. entry of the required customer and payment details,

5. completion of the ordering process,

6. confirmation of the conclusion of the contract by e-mail,

7. log-in to the personal customer area and

8. retrieval of the booked analytical content.

The customer area is accessible via log-in with e-mail address and password. If you have any questions regarding the order, the customer account or the use of the services, customer service is available by e-mail and telephone.

4. Accessibility Requirements

The accessibility requirements arise in particular from the Accessibility Strengthening Act and the Ordinance on the Accessibility Strengthening Act.

According to these, digital services must be designed in such a way that they can be found, accessed and used by persons with disabilities in the generally customary manner, without particular difficulty and in principle without external assistance.

To this end, the content and functions should in particular be designed to be:

· perceivable,

· operable,

· understandable and

· technically robust.

This particularly concerns the presentation of information, navigation, operation via keyboard, the labelling of input fields, the recognisability of controls, as well as use with assistive technologies such as screen readers.

5. Implementation of Accessibility Requirements

The website has been reviewed with regard to various requirements for digital accessibility. The review covered both the publicly accessible areas and the protected customer area.

No significant deficiencies in labelling were identified in the forms and input fields examined. The technical designation of the examined controls by names, roles and states was also largely unobjectionable.

However, the website is currently not yet fully accessible in all areas. In particular, there are still limitations in the following areas:

5.1. Alternative Texts for Images

Some of the images used on the website currently have no alternative text or no sufficiently meaningful alternative text. In particular, images from individual CMS modules are currently in some cases delivered without an ALT attribute. As a result, information contained in the images may not be, or may only be partially, perceivable for users of screen readers.

5.2. Colour Contrast

For some texts and controls, in particular in the publicly accessible area, colour contrasts are still not consistently sufficient. In the customer area, the required minimum contrasts are largely achieved; however, there is still some potential for improvement there as well.

5.3. Structure and Navigation

The heading and page structure has not yet been implemented uniformly on all pages. On some pages, in particular, consistent main headings (H1) have not yet been defined. In addition, some further structuring and navigation mechanisms are lacking which would facilitate quick orientation and efficient navigation using screen readers or the keyboard.

5.4. Keyboard Operability and Focus Management

Some content and functions cannot yet be operated entirely, or not with sufficient convenience, using the keyboard alone. The current implementation therefore only partially fulfils key requirements of WCAG 2.1 and 2.2.

This particularly concerns the logical order of keyboard navigation, the clear visibility of the currently focused element, the avoidance of hidden focus states, as well as the operation of certain dynamic elements, menus and extensive page areas.

5.5. Skip Links

Skip links that enable users to bypass recurring navigation areas and directly access the main page content are not yet consistently available. In particular, on pages with endless scroll or multi-element layouts, such skip links are in some cases not offered. As a result, keyboard users may have to move through a large number of controls before reaching the desired content.

6. Measures to Improve Accessibility

HKCM is working to gradually remedy the identified limitations and to further improve the accessibility of the website.

The accessibility information is reviewed and, where necessary, updated in line with the respective state of technical implementation.

7. Support and Contact

If barriers arise when using the website or the customer area, or if certain content is not accessible, customer service can be contacted at:

E-mail: support@hkcmglobal.com

Please describe as precisely as possible on which page or with which function the barrier occurred and which device, which browser or which assistive technology was used.

8. Competent Market Surveillance Authority

The competent market surveillance authority is:

Marktüberwachungsstelle der Länder für die Barrierefreiheit von Produkten und Dienstleistungen

Anstalt öffentlichen Rechts (MLBF AöR)

Carl-Miller-Straße 6

39112 Magdeburg

Phone: +49 391 289 230 23

E-mail: kontakt@mlbf-barrierefrei.de

9. Status of this Information

As of August 2026