United States of America v. Ahold USA, Inc. and Peapod, LLC - Settlement Agreement

EXHIBIT A

Peapod Website and Mobile Application Accessibility Policy for http://www.peapod.com/

General Policy. It is Peapod's policy to ensure that persons with disabilities have a full and equal opportunity to benefit from the goods, services, facilities, privileges, advantages, and accommodations offered by Peapod through the www.peapod.com website, and through its mobile applications (collectively referred to in this Policy as "www.peapod.com"). Peapod provides effective communication with persons with disabilities, and ensures that individuals with disabilities are not excluded from use of www.peapod.com and its online services. Peapod shall take the necessary steps to ensure that individuals with disabilities are not excluded, denied services, segregated, or otherwise treated differently because of the absence of auxiliary aids and services, unless Peapod can demonstrate that taking those steps would fundamentally alter the nature of the goods, services, facilities, privileges, advantages, or accommodations being offered or would result in an undue burden.

Website Accessibility. Peapod's policy is to ensure http://www.peapod.com/ is accessible to individuals with disabilities as follows:

• No later than March 31, 2015 for mobile applications and September 30, 2015 for www.peapod.com, all new web pages, web applications, and web content published to www.peapod.com for public use (excluding advertisements) shall conform to the Level A and Level AA Success Criteria and Conformance Requirements of the Web Content Accessibility Guidelines 2.0 (Dec. 11, 2008) ("WCAG 2.0 Level AA"), published by the World Wide Web Consortium ("W3C"), Web Accessibility Initiative ("WAI"), available at www.w3.org/TR/WCAG/.

• Peapod provides a notice, prominently and directly linked from the www.peapod.com homepage that provides a toll-free telephone number that customers with disabilities can call to obtain technical assistance on how to use www.peapod.com and the Peapod mobile applications. The notice also solicits feedback from visitors to www.peapod.com on how accessibility can be improved and provides contact information for customer service representatives knowledgeable about this Policy.

• Peapod annually distributes this Policy to all employees and contractors that have responsibility for the content and format of www.peapod.com ("Website Content Personnel") as well as all customer service representatives for www.peapod.com.

• Peapod has designated [insert name of Website Accessibility Coordinator] as Website Accessibility Coordinator for www.peapod.com, who is knowledgeable concerning the WCAG 2.0 and website accessibility generally and is available as a resource to all Website Content Personnel and customer service representatives for www.peapod.com to ensure compliance with this Policy.

• Peapod provides mandatory annual training on website accessibility to Website Content Personnel.

• Peapod annually assesses and reviews the delivery of content via www.peapod.com to ensure accessibility to persons with disabilities, including, among others, persons who:

• Use screen readers or voice interactive software;

• Only or predominately use keyboards to input data and to navigate websites;

• Use Braille output devices;

• Use on-screen keyboards;

• Use text magnification software;

• Require the ability to adjust font size and/or color to view web pages;

• Require audio description to access video content; and

• Require captions to access audio and visual materials.

• Beginning no later than March 31, 2015 for mobile applications and September 30, 2015 for www.peapod.com, Peapod regularly conducts automated tests of and annually enlists individuals with a variety of disabilities to test www.peapod.com and its mobile applications for accessibility. In addition, Peapod includes individuals with disabilities to test any proposed substantial changes to www.peapod.com whenever such changes are Beta tested.

• Peapod has retained a Website Accessibility Consultant to annually evaluate www.peapod.com and its mobile applications for conformance with WCAG 2.0 Level AA. Each year, the Website Accessibility Consultant prepares a written report based on the evaluation, which identifies any barriers and provides recommendations to enhance the accessibility of www.peapod.com.

• Peapod prioritizes bug fixes to eliminate bugs that create accessibility barriers to people with disabilities.

Compliance with the Policy. Peapod requires employees and contractors to comply with this policy. Failure to comply with this policy may result in disciplinary action.