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Legal

Accessibility policy

Published on: August 7, 2026

1. Our commitment

Gen II Fund Services, LLC is committed to ensuring digital accessibility for everyone, including people with disabilities. We believe our website should be perceivable, operable, understandable, and robust for all users, regardless of the technology or assistive tools they rely on.

Accessibility is built into how we design and build our website rather than added afterwards. Accessible practices are embedded directly in our codebase and integrated into our day-to-day development workflow.

2. Conformance target and drivers

Our website is designed and tested to maintain our commitment to operating in substantial conformance with:

Web Content Accessibility Guidelines (WCAG) 2.1, Level AA - the internationally recognised technical standard for web accessibility, and the common reference point across the frameworks relevant to our business. We continuously update and review our website to ensure, to the best of our knowledge, substantial conformance with the most relevant accessibility guidelines.

As a fund administrator, our website primarily serves institutional and professional clients rather than the general public. We are committed to maintaining WCAG 2.1 Level AA conformance for the following reasons:

  • Client and contractual requirements. Our institutional clients - which may include pension plans, government-affiliated investors, universities, and banks - are frequently subject to their own accessibility obligations (such as ADA Title II, Section 508, state accessibility laws, or the European Accessibility Act) and may require their service providers to demonstrate accessibility conformance through contracts, requests for proposal, and due-diligence reviews. We hold WCAG 2.1 Level AA so that we can meet these requirements.
  • European Accessibility Act (EAA). Directive (EU) 2019/882. Where we provide services connected to the EU market, EAA-related obligations may apply to us directly or be passed to us by EU-based clients. EAA conformance is assessed against the harmonised European standard EN 301 549, which incorporates WCAG 2.1 Level AA for web content.
  • Employment (ADA Title I). Where our website supports recruitment or job applications, we maintain its accessibility so that applicants and employees with disabilities can use those functions, consistent with reasonable-accommodation obligations.
  • Inclusion. Independent of any specific legal requirement, we are committed to making our digital services usable by people with disabilities.

3. Conformance status

Our website is designed to be substantially conformant with WCAG 2.1 Level AA, meaning that to the best of our knowledge, it meets the standard except for any limited items identified in Section 6. Where content or a feature is found not to meet this standard, we treat it as a defect to be remediated in a timely manner.

4. Scope

This policy applies to all pages and interactive features of www.gen2fund.com, including forms, media, dynamic content, custom interactive components, and any secure client portal or recruitment functionality provided through the site. It applies to content produced by Gen II Fund Services, LLC and content managed through our content management system (CMS).

5. Measures we take

Accessibility is engineered into the website through measures to substantially comply with WCAG 2.1 Level AA standards. This includes the incorporation of features corresponding to criteria associated with the following principles of WCAG 2.1 Level AA:

  1. Perceivable: Information and user interface components must be presentable to users in ways they can perceive.
  2. Operable: User interface components and navigation must be operable.
  3. Understandable: Information and the operation of the user interface must be understandable.
  4. Robust: Content must be robust enough that it can be interpreted by a wide variety of user agents, including assistive technologies.

Each principle is maintained as a standing requirement, not a one-off effort. Key measures we take include:

  • All interactive elements are fully operable using a keyboard alone, without requiring a mouse or pointer.
  • The website is built to work with screen readers and other assistive technologies.
  • The underlying markup uses meaningful, semantic Hypertext Markup Language (HTML) so that content structure is communicated correctly to all users and technologies.
  • We respect user sensory preferences and provide alternatives for time-based media.
  • Content is designed to remain usable when visual presentation is adjusted.

Such features, to the best of our knowledge, are in substantial compliance with WCAG 2.1 level AA.

Testing in our workflow

Accessibility testing is integrated into our development process:

  • Component-level accessibility testing is conducted allowing individual UI components to be checked for accessibility as they are built and before they are combined into pages.
  • Accessibility testing of our website is conducted periodically to ensure our continued belief that the website maintains substantial compliance with WCAG 2.1 Level AA standards.

6. Known limitations

To the best of our knowledge, there are no known accessibility limitations at the time this policy was last reviewed.

7. Technical compatibility

Our website is designed to be compatible with current versions of major browsers and with commonly used assistive technologies, including screen readers and speech recognition software, on both desktop and mobile platforms. Accessibility relies on the availability of HTML, CSS, JavaScript, and WAI-ARIA in the user's browser.

8. Third-party content

While our website is designed to be substantially compliant with WCAG 2.1 Level AA standards, some content may be provided by third parties. While we make reasonable efforts to ensure that third-party content on our website meets WCAG 2.1 Level AA standards, we acknowledge that we may not have complete control over the accessibility of all third-party components.

We are committed to working with third parties to ensure their content provided on our website is accessible. If you encounter accessibility barriers in any third-party content on our website, please notify us using the contact information below, and we will work to address the issue.

9. Feedback and contact

We welcome your feedback on the accessibility of our website. If you encounter a barrier, need content in an alternative format, or wish to report an accessibility problem, please contact us:

  • Email: marketing@gen2fund.com
  • Phone: +1 212-408-0550
  • Postal address: Gen II Fund Services, LLC, 1675 Broadway, 4th Floor, New York, NY 10019, USA

We aim to acknowledge accessibility feedback within five (5) business days and to work with you to provide the information, service, or content you need through an accessible means within ten (10) business days.

10. Escalation

If you contact us about an accessibility barrier and are not satisfied with our response, you may escalate the matter to our Legal Department – Legal@gen2fund.com.

If you are located in the European Union, you may also escalate to the national enforcement authority responsible for the European Accessibility Act in your country. For Luxembourg, the competent authority is the Ministry of Family Affairs, which can be contacted on info@osaps.etat.lu).

11. Review

This policy is reviewed periodically and updated to reflect changes to our website, our development practices, and applicable standards, legislation, and client requirements. The date at the top of this page indicates the most recent review.