Accessibility statement of JTI Austria GmbH

1. Introduction

This declaration documents compliance with the accessibility requirements of the Accessibility Act (RIS - Accessibility Act - Federal Law Consolidated, version of June 30, 2025) for our services provided on the website www.nordicspirit.at ("Website"). This declaration was prepared in accordance with Section 14 Paragraph 1 of the Accessibility Act in conjunction with Section 4 Paragraph 3 of the Accessibility Act in conjunction with Annex 1, Section 3 and Section 4.

We always strive to consider the accessibility of our services when developing and offering new services, and we regularly review this.

2. Scope

This statement concerns the following services offered:

• Free Sampling: Option to order a free sample,
• Nordic Circle: Our customer loyalty program,
• Newsletter,
• Competitions / Challenges.

This does not include the following according to § 2 para. 3 no. 4 BaFG:
• The age verification service from iDenfy integrated into the website, which is third-party content over which we have no influence, as this service was neither developed by us nor is under our control.

3. General description of services

3.1 Free Sampling
The "Free Sample" service allows consumers to request a free sample of nicotine pouches via our website. To receive this free sample, users must register on the website by creating a user account and then completing age verification. This offer is exclusively for individuals who are at least 18 years old. Age verification can be initiated in the user account profile after registration. After creating such a user account and successfully completing age verification, a free sample of the product can be requested, which will then be sent to the specified address. This service is only available to consumers (for private use) and is subject to the Free Sample Terms and Conditions ("Free Sample Terms and Conditions").

3.2 Nordic Circle
The "Nordic Circle" customer loyalty program is a voluntary bonus program for registered users of the website. After successfully creating a user account and verifying their age (participation must be 18 or older), users can later opt into the Nordic Circle program by selecting the appropriate option ("tickbox") within their user account. Program members can collect "points" through various activities. These points can be redeemed – depending on the specific offer – for rewards such as merchandise ("goodies"), event tickets, or other items on the website.

Possible activities include: subscribing to the newsletter, participating in contests, quizzes, or surveys, reading blog articles, entering promotional codes (e.g., from product packaging or social media), inviting friends, purchasing products with bonus codes, or requesting a free sample. Participation is intended exclusively for consumers (for private use). By registering for the program, users accept the applicable Nordic Circle terms of use, which are available and can be saved on the website.

3.3 Newsletter
Our Nordic Spirit newsletter is a regular email service that keeps you informed about current offers, products, and news. You'll receive regular updates on special offers, VIP events, festival tickets, other services, and contests. To subscribe, you'll need to provide your email address and check a box to confirm your subscription.

3.4. Competitions / Challenges
From time to time, prize draws/challenges are also held via the website. Participation in these prize draws/challenges is voluntary, free of charge, and independent of the purchase of goods or services. The procedure for each prize draw/challenge is defined in separate terms and conditions. By participating in the prize draw/challenge, participants accept the applicable terms and conditions, which are available and storable on the website during the respective prize draw/challenge period. A privacy policy is also created for each prize draw/challenge, which is likewise available and storable on the website during the respective prize draw/challenge period. Section 4 describes the format of each prize draw/challenge available on the website.

4. Performance of services

Our services can be used as follows:
• Free Sampling
To request a free sample via our website, you first need to register by creating a user account and then successfully verifying your age. For this, you'll need a valid email address and a personal password. This is done by clicking on the text "Create Account". Next, you'll need to enter your first name, last name, email address, password, and date of birth, and then click the "Create" button. You will then receive an email confirming that your user account has been created and will be immediately redirected to your user profile to complete the age verification process. Clicking the "Verify Identity" button will take you to the age verification page, where you must prove that you are over 18 years old. After clicking this button, you will be asked to select the country that issued your identification document, either on your mobile device or your current device (e.g., computer). After selecting the country, you can choose between different types of identification documents. Here you can choose between "ID card", "passport", "residence permit", or "driver's license". After selecting your ID document, you will be asked to photograph it. The external service provider "iDenfy" will then perform an identity verification, which typically takes 1 to 5 minutes. During this process, the data you entered will be compared with your ID document. If the comparison is successful, the age verification is complete. If the comparison is unsuccessful, you will be asked to check or correct your data, or to cancel the age verification. Only after successful age verification will you be able to fully utilize the website's features, including requesting a free sample. After a one-time registration, you will only need to log in with these credentials in the future. Once logged in, click on the "Free Sample" menu item. This will open the product page, where you can select your desired free sample. Select the product and click the "Add to Cart" button. After clicking this button, you will be taken directly to the shopping cart, which will display your selected free sample. In the shopping cart, you will also be reminded to carefully read and accept our Terms and Conditions for Free Samples. Next, click the "Checkout" button to enter your shipping address. After entering your shipping address, click the "Proceed to Review Order" button, which will take you to the "Review Order" page. Clicking "Submit Order" will complete your order. You will receive an order confirmation via email after placing your order.

• Nordic Circle
You can participate in the Nordic Circle if you create a user account on nordicspirit.at and, after successful age verification, give your consent to participate by clicking the checkbox "Yes, I would like to participate in the Nordic Spirit customer loyalty program ('Nordic Circle') and agree that the personal data I have provided may be processed for the purpose of participation in and the execution of the Nordic Circle. I can revoke this consent at any time with effect for the future (e.g., by using the unsubscribe function directly in my user account). In this regard, I have read and agree to the Nordic Circle Terms of Use on this website." in your user account profile settings. You will find this checkbox within your profile settings after logging into your user account. Instructions on how to create such a user account are provided above under "Free Sampling."

You can collect points through activities such as the following:

• Subscribe to the newsletter
Regarding the type of use, we refer to the following point "Newsletter".

• Register your participation in the Nordic Circle
Regarding the type of use, we refer to the preceding point "Free Sampling".

• Birthday bonus
You will receive points by entering your date of birth in your profile. You can access this section via the "Nordic Circle" button in the bottom left corner of the screen, which is also labeled for screen readers.

• Referral to a friend (“Invite friends – Member get Member”)
If you are logged into your user account, you can invite friends and collect points via an input form. In the "Nordic Circle" section, you will find the "Invite and secure" button for referring friends. When you click this button, a one-time-use code will appear on the screen. You can then forward this code to your friends. When your friend clicks the link, the points will be credited to your account.

• Request a free sample
Regarding the type of use, we refer to the preceding point "Free Sampling".

• Purchase of a product with a special “code” on the packaging
You can enter the code in the designated input field within your user account on the website in the "Nordic Circle" section and redeem it by clicking the "Redeem" button, or enter it by scanning a QR code to receive points.

• Participation in customer surveys
If you have subscribed to the newsletter, you can receive invitations to surveys via email and participate in the survey by clicking on the corresponding "Participate in customer survey" button after being linked to our website.
Participation is voluntary and the forms are designed to be accessible. After answering the questions, you complete the customer survey by clicking the "Submit" button.

• Participation in a 1-2-1 activity
You can earn points for on-site activities (e.g., events) with promoters. To do this, you first need to create an account on our website. The points will then be automatically added to your account.

• Entry of codes that are distributed via social media platforms
You can also collect points by entering codes that are shared via our social media channels. Enter the code in the designated field within your user account on the website in the "Nordic Circle" section and redeem it by clicking the "Redeem" button. Your points will be credited to your account after the code has been entered correctly.

• Reading blog posts
You can earn points by reading certain blog posts.
Points are awarded for opening the post. Our blog articles are designed to be easily accessible with screen readers.

• Participation in quizzes or competitions
If you have subscribed to the newsletter, you may receive an email with the option to voluntarily participate in a quiz or competition by clicking the corresponding "Participate in the competition" button. Participation is voluntary, and the pages are accessible to everyone.

• Scanning points as part of “offline activations”
For on-site activities (e.g., events), you can scan QR codes and earn points. The points are credited automatically. The QR codes are conveniently located.

• Nordic Circle Anniversary (extra points on the anniversary of your registration) On each anniversary of your registration in the Nordic Circle, points will automatically be credited to your user account.

Once you have completed one of the listed activities, the corresponding points will be credited to your account. You can access your points via your profile settings by clicking on the Nordic Circle logo in the lower left corner of the screen.

• Newsletter
To receive the Nordic Spirit newsletter, you must subscribe. To subscribe, enter your email address at the bottom of the website (before the footer) under "Email address," check the box to confirm, and then click "Subscribe."
Your first name can be entered voluntarily under "First Name". After registering, you will receive an email at the provided email address asking you to confirm that you wish to receive the newsletter and invitations to customer surveys. After confirming your email, you will receive regular news and offers from us via email.

• Competitions / Challenges
The activities required for participation in a contest/challenge depend on the specific contest/challenge and its details. From October 15, 2025, until October 31, 2025, at 11:59 PM, the "Nordic Circle Member Get Member Challenge October 2025" will be offered on the website nordicspirit.at. This challenge is exclusively for individuals who are of legal age, reside in Austria, and are already registered in the Nordic Circle Loyalty Program at the start of the challenge or register during the challenge period. Participation in the challenge is possible in the following ways:
As a registered Nordic Circle Loyalty Member on nordicspirit.at, you can participate in the challenge by actively referring someone over 18 who is not yet registered in the Nordic Circle Loyalty program (sending a link you generate yourself as a Nordic Circle Member via a platform of your choice, e.g., email, WhatsApp, social media, etc.). A referral is considered successful if the referred person registers on the nordicspirit.at website within the challenge period, verifies their age, and signs up for the Nordic Circle Loyalty program (a detailed description of the individual required steps can be found above in the sub-points mentioned under point 4). The participant who achieves the most successful referrals during the challenge period wins the challenge. Your first successful referral automatically enters you into the challenge ranking. In addition to the chance to win according to the terms and conditions, you will receive 2000 Nordic Circle Member Points for each successful referral. Each person recruited will also receive 2,000 Nordic Circle Member Points for successfully registering for the Nordic Circle Loyalty Program during the challenge period. The Member Points earned will be automatically credited to your Nordic Circle account.

5. How we meet accessibility requirements

In particular, the accessibility requirements arising from Section 4 Paragraph 3 in conjunction with Annex 1, Section 3 lit b sublit aa) to gg) BaFG must be complied with.

The services listed above under points 3 and 4 meet these accessibility requirements as follows:

• Text-to-Speech (TTS)
  It has been ensured that users can also access and listen to the website's content via speech output. For example, the text on the website can be read aloud using both the browser's built-in screen reader and external screen readers. Furthermore, an Accessibility Assistant app integrated into our website (see item 4 of this accessibility statement for details) allows users to have selected text read aloud by accessing this tool and clicking on "Text Speech." Keyboard navigation and compatibility with assistive technologies: Our website ensures usability via the keyboard. The visibility of the focus point during navigation is guaranteed. The website has also been configured so that its content can be read by external screen readers, as mentioned above, and is compatible with them.

• Comprehensibility and readability
  In addition to translating the content into simple language, suitable font sizes and types were used to ensure perceptibility and readability. Line height and word/letter spacing were also chosen accordingly. The color contrast (generally 4.5:1 according to WCAG) is selected to guarantee adequate readability. Furthermore, the perceived perceptibility and readability of the website's text can be individually adjusted using our integrated Accessibility Assistant app. This allows users to adjust the font size, letter/word spacing, and color contrast to their specific needs, for example, by clicking the arrow buttons next to "Word Spacing." Additionally, alternative text is provided to ensure that users working with a mouse can see the alternative text when they hover the cursor over an image, as a tooltip displays the corresponding image text. Furthermore, the Accessibility Assistant app integrated on our website allows you to actively access any alternative text for the corresponding image by clicking on "Image Alt-Tooltip".
• Accessibility Assistant App
  In addition to the accessibility requirements implemented above, we also offer an Accessibility Assistant App.
  This can be accessed on the website via the following icon:

This app allows users to customize the website and its content to their individual needs using a widget-based user interface. For example, visual enhancements such as reading aids, highlighted headings and links, and contrast modes can be set to adjust visibility according to user requirements.

The following accessibility features can be actively controlled with the app:

• Keyboard navigation (WCAG 2.1 Success Criterion 2.1.1): Easy navigation through our website using keyboard commands for a seamless user experience.
• Large cursor: Improves cursor visibility by using a larger and more noticeable cursor for better navigation.
• Reading aid: Makes reading easier with a tool for better text comprehension.
• Text-to-speech: Activating a text-to-speech function to improve the accessibility of content.
• Hide images and videos: Hide images and videos to allow browsing without distractions.
• Contrast options (WCAG 2.1 success criterion 1.4.3): Color contrast adjustable with functions such as "Invert Colors", "Dark Contrast" and "Light Contrast".
• High saturation (WCAG 2.1 Success Criterion 1.4.3 - Contrast): Improves visibility by adjusting color saturation to individual preferences, thus promoting understanding of the content.
• Low saturation (WCAG 2.1 Success Criterion 1.4.3 - Contrast): Reduces color saturation to create a muted color palette that can make it easier for users with visual sensitivity to navigate the website.
• Desaturate: Reduces color saturation for better visibility.
• Larger text (WCAG 2.1 Success Criterion 1.4.4): Enlarges the text to improve readability.
• Highlight links (WCAG 2.1 Success Criterion 1.4.1): Highlighting links on the website to facilitate navigation.
• Line height: Spacing between lines of text can be adjusted to improve readability.
• Word spacing: Spacing between words can be adjusted to improve readability.
• Letter spacing: Spacing between letters can be adjusted to improve readability.
• Alignment (Center, Left, Right): Text alignment can be adjusted to ensure a more comfortable reading experience.
• Readable fonts (WCAG 2.1 Success Criterion 1.4.8 - Visual Presentation): Provides a range of fonts optimized for readability to ensure that the content is accessible and understandable to all users, regardless of visual impairment.
• Reading mask (WCAG 2.1 Success Criterion 1.4.10 - Reflow): Allows the user to focus on specific content by using a reading mask that enables a customized browsing experience.
• Highlight headings (WCAG 2.1 Success Criterion 2.4.10 - Section Headings): Highlight the headings throughout the website to facilitate navigation and understanding of the content hierarchy.
• Text Enhancer (WCAG 2.1 Success Criterion 1.4.4): Improves the readability of text with a text enhancer function.
• Image Alt Tooltip (WCAG 2.1 Success Criteria 1.1.1, 1.2.1): Provides descriptive tooltips for images to improve accessibility for users with visual impairments.
• Pause animation: Allows you to pause animations for a smoother browsing experience.

6. Accessibility of our content

Our services include:

• Fully accessible according to BaFG and in accordance with the WCAG 2.1 standard (Level AA)

6.1 Standards and testing procedures
The accessibility of our website has been tested and implemented according to WCAG standard 2.1 (conformance level AA).

The examination was carried out by:

• Internal self-assessment.

7. Feedback and Contact

Should you encounter any barriers when using our services, have questions about accessibility, or require assistance with the accessible use of our website, please contact:

JTI Austria GmbH / Marketing Department
Email: consumerservice@jti.com
Telephone: 0800 404808

Responsible for implementation: JTI Austria GmbH, Erdberger Lände 26a/71, 1030 Vienna

Please note that this accessibility statement is prepared in German and English, with the German version being authoritative in case of discrepancies between the German and English versions.
Accessibility statement created on: October 9, 2025.