INSTITUTIONAL AND LEGAL DECLARATION OF DIGITAL ACCESSIBILITY

At ORTHONET TECHNOLOGIES S.L., the managing entity of the Xortho platform, we conceive digital inclusion not as a mere regulatory formality, but as a core and ethical backbone of our corporate and commercial operations. We consider it a categorical imperative that all professionals in the clinical sector, orthodontic technicians, dental purchasing managers, and administrative staff of client clinics can access our extensive B2B catalog, navigate autonomously through the web architecture, process and review their electronic billing, and formalize their orders for instruments, without encountering or suffering from technological barriers derived from visual, auditory, motor, or cognitive disabilities, whether circumstantial or permanent.

This legal statement sets out in detail the current regulatory framework to which we are subject, the actual and audited degree of technical compliance of the corporate e-commerce portal https://xortho.es/ at the current date, and the formal and bidirectional communication mechanisms explicitly enabled to escalate any complaints or incidents related to deficiencies in the accessible user experience.

1. Corporate Commitment and Integration of the Applicable Regulatory Framework (Law 11/2023) ORTHONET TECHNOLOGIES S.L. assumes and formalizes the unavoidable legal commitment to guarantee the integral accessibility of its transactional website for every professional who requires it, in strict accordance with the mandatory requirements for economic operators in the private sector contemplatd in the higher national regulations: Law 11/2023, of May 8, regulating the transposition of European Union Directives on the accessibility of certain products and services, a regulatory corpus derived directly from the execution of the European Accessibility Act (Directive EU 2019/882).

This legislative guideline subordinates de facto and de jure our digital information and communication architecture to strict functional compliance with the guidelines established in the harmonized technical standard UNE-EN 301549:2022, as well as the demanding requirements outlined in the most recent iterations of the Web Content Accessibility Guidelines (WCAG 2.1 and WCAG 2.2) developed, maintained, and published by the World Wide Web Consortium (W3C). The fixed corporate and legal objective is to uninterruptedly consolidate, maintain, and defend at least a Level Double A (AA) Compliance in all critical phases of the conversion funnel and in the document management spaces.

2. Objective Technical Compliance Situation and Evaluation As a result of the exhaustive code audits carried out on the e-commerce platform https://xortho.es/, it is certified and declared that the software architecture of said domain is currently structured in such a way that it is partially compliant with the precepts of the aforementioned Law 11/2023 and the AA quality level standard of the WCAG 2.2 metrics. This legal classification of partial compliance derives exclusively from the isolated persistence of a limited number of structural non-conformities and the temporary exemptions relating to disproportionate burden analysis which are based on and listed in detail in the following section of this document.

3. Delimitation of Non-Accessible Content and Regulatory Exceptions The content and logical elements outlined in the subsequent points may not be fully and universally accessible to users' technical assistance systems for the following technological justifications and legal protections:

A. Technical non-conformities with the UNE-EN 301549 standard and the requirements of Law 11/2023 The matrix of detected accessibility failures, in an iterative remediation process by the engineering teams, includes the following operational factors: • Structural contrast adjustments in pop-up interfaces: There may coexist, in the depth of the web architecture, specific visual design failures where dynamic navigation flows (such as complex multi-hierarchy drop-down menus or modal windows intended for signature confirmation in the B2B electronic billing process) do not present or maintain the minimum color contrast ratio of 4.5:1 constantly required by the guidelines, which may temporarily hinder their readability for users affected by a degree of reduced vision or discromatopsia. • Loss of semantic focus management in mass B2B purchase processes: During the execution of certain processes for the massive addition of clinical consumables to the shopping cart, complex dynamic tables or 3D input matrices for product variations (sizes, thicknesses, curvatures of orthodontic wires) do not always correctly retain and release the flow of interactive focus when the professional user operates the system solely and exclusively through the tab keys or peripheral screen reader programs. This intermittent instability in the Document Object Model (DOM) logic may generate a momentary loss of transactional context. • Deficiencies in multimedia content supplied by third-party providers: A residual volume of instructional videos, biomedical application simulations, or manuals in animation format hosted within the enriched descriptions of the final product catalogs, and originating unaltered from external laboratories or manufacturers, lack advanced synchronous subtitling tracks for the deaf or technical alternatives for detailed textual transcription of the audio track at their source.

B. Legitimate Application of the Disproportionate Burden Exception Under the provisions of the relevant legislation to safeguard the viability of economic operators, ORTHONET TECHNOLOGIES SL invokes the temporary exemption for economic and organizational reasons regarding the following content vector: • Retrospective and mass adaptation of historical repositories (PDF documentation): The immediate, integral, and unconditional adaptation to the strict accessibility standard of almost the entire extensive historical catalog of complex office documents (such as heavy machinery installation manuals, exhaustive technical information sheets of alloys, chemical safety data sheets for resins, and medical device certifications imported in PDF format), historically supplied by third-party operators and entered into the system's databases with an antiquity prior to the year 2025, would mean imposing a disproportionate burden on the accounting and organizational structure of the entity, an exempting circumstance expressly and restrictively contemplated in the regulations for the protection of the productive sector. • Notwithstanding the above, The Company formally guarantees that the process of digitalization and creation of documents recently added to the Platform will be fully equipped with the necessary underlying structural tags and enriched textual alternatives required by modern screen readers, progressively minimizing the impact of this historical exemption.

C. Content outside the material scope of application of the current regulations By express limitation of the Directive, telematic content supplied and inserted through embedded code components from third-party mapping service providers, which are used occasionally on the Platform for the 3D graphical representation of the coordinates or geographic locations of our corporate logistics centers, are exempt from compliance. This exemption applies on the condition that the vital information regarding localization and logistical guidelines is expressed simultaneously and in parallel in a digital text format that is structured and fully accessible.

4. Battery of Continuous Technical Measures Integrated into the Platform To ensure the proactive accessibility of the experience and to iteratively and methodically reduce the architectural barriers documented in the preceding section, ORTHONET TECHNOLOGIES S.L. has implemented methodologies and protocols based on the programming philosophy known as Accessibility by Design. The preventive measures integrated into the continuous software deployment flow include: 1. The audit of the mandatory and systematic use, proceduralized and reviewed through algorithmic validation, of the alternative text (ALT) attribute of deep descriptive semantic value in all illustrative images of clinical instruments, heavy machinery, and orthodontic consumables incorporated into the catalog. 2. The widespread implementation of the ARIA (Accessible Rich Internet Applications) tag ontology, dynamically inserted in the modules of complex shopping carts, in the asynchronous entry processes of B2B corporate data, and in the XML voucher issuance portals, with the exclusive purpose of notifying voice synthesizing programs without latency of any silent alteration of the page state or any critical validation error detected in the logic of the fiscal forms of the Crea y Crece Law. 3. The implementation and compliance with a robust structure of header hierarchies and semantic markers in the base HTML5 language of the code directives, which greatly facilitates a clean and secure interpretive parsing process, ensuring total horizontal compatibility in any conceivable combination of commercial browsers and specialized hardware assistance agent software. 4. The execution of automated and recurring accessibility audit cycles on a monthly basis, taking advantage of deep integrations with certified syntactic analyzers and automated detection systems validated by the global accessibility consortium to evaluate regression or the introduction of new errors in the WCAG 2.2 architecture.

5. Preparation Criteria, Methodology, and Document Review of this Report The drafting of this binding institutional web accessibility statement was completed, updated, and formally approved for official publication on 02/25/2026. To carry out the technical and legislative viability appraisal on which the materiality of this legal text is based, a process of internal self-assessment and source code review fully coordinated by the systems and compliance departments of The Company has been used and verified. This scrutiny procedure has been systematically complemented and contrasted through the application of specialized external audit tools and independent syntactic validators designed to mass-check the algorithmic compliance of the infrastructure with the entire corpus of the AA level of the WCAG 2.2 metrics. The titular commercial entity hereby manifests the firm commitment to subject this legal document to dynamic review and update at least annually, or extraordinarily and immediately whenever the core development of the base software of the corporate content management system undergoes a severe restructuring that could substantially affect the navigability conditions in force at the time of drafting this report.

6. Official Procedures for Contact, Request for Adaptation of Information, and Channels for Escalation and Complaint In strict compliance with the stipulations of the sanctioning and transparency requirements of Law 11/2023, the commercial company deploys and maintains a fully operational, clear, identifiable, and traceable feedback structure for the community of professional users. A formal and explicit invitation is formulated so that any clinician or professional who finds digital architectural barriers or operational frustration in their experience on the platform proceeds without delay to use our institutional channels to effect any of the following regulatory actions: 1. To notify and report in detail the alleged non-compliance with legal technical accessibility requirements by components, specific sections, or purchase flows hosted within the domain or subdomains of the website. 2. To agilely transfer any class of operational concern, technical difficulty experienced when attempting to carry out a commercial transaction, or to issue an iterative suggestion on how to improve or expand the ergonomic functionalities of the user interface. 3. To formulate a formal, justified, and direct request or petition to obtain the provision or supply of information relative to any telematic contents hosted on the web that could temporarily be outside the urgent scope of the directives—for instance, complex technical manuals for heavy machinery drafted in legacy office formats that have not been previously tagged with semantics for the blind—demanding that said information be sent through private channels in a digitized alternative format that is fully processable and understandable for the support tools used by the requesting user.

All communications, operational blocking notifications, architectural suggestions, and formal legal and technical compliance complaints must be sent and processed directly through the Technical Compliance and Accessibility Officer of the commercial company, using the following direct and supervised channels: • Corporate Electronic and Technical Support Mailbox: CALIDAD@XORTHO.ES • Professional Telephone Assistance Line (B2B Customer Service): +34644297766

Once a notification of design deficiency or a request for adaptation in an accessible format is duly received and registered by the company's systems, The Company binds itself to issue a documented and confirmatory acknowledgment of receipt within a time limit that will never exceed two business days. Subsequently, the technical department will instruct the appropriate review measures and will issue, communicate, and execute a decision providing an operational solution, a reasoned explanation about the unfeasibility, or the provision of a functional alternative within a maximum and mandatory period of fifteen (15) business days, actively and diligently guaranteeing real inclusion and the preservation of the fundamental right of access under conditions of equity to the economic activities proper to B2B commerce.

In the undesirable event that the request for adaptation of information or the accessibility complaint filed with the company has been rejected unilaterally and in the opinion of the complainant in an unmotivated manner, or that the affected clinical professional does not share or show their acquiescence with the reasoning of the resolution course adopted by The Company, or in the event that the administrative silence on the part of the economic operator exceeds the thresholds of time periods expressly dictated by national regulations without offering a solution, the current legislation transposed in Law 11/2023 confers on the interested party the legitimate and inalienable power to initiate and process a formal protest or complaint file. Said higher-level administrative channel must be formally presented before the state and regional authorities that hold the superior power of supervision, market inspection, and punitive sanctioning capacity (such as the offices and institutions attached to the Ministry of Social Rights, Consumption, and Agenda 2030, or equivalent bodies in delegated competence in the Autonomous Communities competent in matters of social inclusion). The pursuit of this administrative action by the public authorities will have sufficient coercive and legal capacity to audit, sanction, and force the technological platform to the prompt and immediate functional restoration of the conditions of universality of the digital service required by the applicable current legal standard.