1st Class Cigar Humidors ("1st Class”) is committed to maintaining accessibility on its Website, Mobile Applications, and other technology platforms for all of its customers. 1st Class strives to comply with Americans with Disabilities Act Title III (“ADA”) and WCAG 2.0 (Levels A and AA) requirements to improve overall customer experience in a sustainable manner.

Oversight and Governance: 1st Class works with third-party accessibility consultants to assist1st Class and its Informational Technology (“IT”) team in remediating and maintaining the accessibility of its Website. The following departments are responsible for execution of the ADA policy as related to their particular area of the business:

Training: 1st Class employees, including its IT teams, actively participate in ongoing training to ensure understanding of accessibility and functionality of the Website.

Response and Prevention: The 1st Class team will assess the effectiveness and efficiency of the program on an ongoing basis. The 1st Class team will also ensure a systematic and sustainable approach is taken in any remediation efforts.