GP-005 Human Resources and Training

Purpose

Define the methodology for our human resources (hereinafter, HR) activities. This procedure serves as a set of documented guidelines and protocols that our managers and employees can follow to handle HR matters effectively.

More specifically, we have procedures to achieve the following goals:

• Consistency: establish uniform processes and standards across our company. This consistency ensures that HR-related actions are handled fairly and equitably, reducing the likelihood of bias or discrimination.
• Compliance: guide how to meet legal requirements related to hiring, compensation, employee rights and workplace safety.
• Transparency: make it clear to employees and managers how HR processes work. This transparency fosters trust within the organization, as employees can understand their rights and expectations.
• Efficiency: streamline HR processes, making them more efficient. When employees and HR staff know the steps to follow, it reduces the time and effort required to resolve HR-related issues.
• Risk Mitigation: reduce the risk of legal disputes and lawsuits. Compliance with labour laws and regulations is essential for avoiding costly penalties and legal consequences.
• Employee satisfaction: include guidelines for addressing employee concerns and grievances. When employees know how their concerns will be handled, they are more likely to feel heard and valued.
• Recruitment and Onboarding: ensure that all candidates go through a consistent and thorough hiring process. This helps us select the right candidates and minimize the risk of biased hiring decisions.
• Performance management: include processes for setting expectations, conducting evaluations, and providing feedback. These procedures ensure that performance assessments are fair and objective.
• Training and development: procedures for training and development guide employees on how to access learning opportunities within the organization. This helps employees improve their skills and contribute more effectively to the company's success.
• Benefits administration: ensure that employees receive accurate information about their benefits and know how to enrol or make changes as needed.
• Termination: outline the steps to take to ensure a smooth transition and protect the company's interests, especially in cases of involuntary terminations.
• Confidentiality: emphasize the importance of maintaining the confidentiality of sensitive employee information, such as medical records, personal data, and disciplinary actions.
• Record keeping:include guidelines for maintaining accurate and organized HR records, which is essential for auditing, compliance, and historical reference.

In summary, maintaining order and compliance within our HR functions. Promote fairness, legal compliance, and operational efficiency, ultimately contributing to a positive workplace environment and the company's overall success.

Moreover, established protocols ensure that all personnel are aware of the relevance and importance of their activities and how they contribute to the good performance of the Quality Management System (QMS).

Scope

All our team members.

Responsibilities

JD-001

• Aapprove the requirement to incorporate new members into the team
• Approve the candidates selected for joining the company
• Together with the JD-002, JD-003, JD-005, JD-006and JD-007, to ensure that the training and development plan aligns with the organization's strategic objectives and that adequate resources are allocated for training.
• To evaluate the effectiveness of the training.

JD-004

• Together with the department managers and JD-006, the JD-004 is responsible for overseeing and coordinating the training and development plan.
• Ensure the training, onboarding and offboarding records and other Human resources-related processes are properly archived and maintained.

JD-006

• Identify the competencies and training needs of the personnel of our area.
• Ensure all the human resources procedures are followed and all the required records are properly archived.

Department managers

• Identify the training needs of their personnel and ensure that employees under their supervision receive the necessary training and development opportunities.
• Evaluate the effectiveness of the training.

All team members

• Request training from their supervisors and to attend such training.
• Suggest the need for hiring new personnel.

Inputs

• Personnel recruitment needs
• Personnel training needs.

Outputs

• Improvement of the competencies of the personnel and continuous improvement of its training.
• T-005-001 Job description
• Organisation chart
• T-005-002 Personnel card
• T-005-003 Training plan
• T-005-004 Training evaluation and record
• T-005-005 Certification that the onboarding training has been completed
• T-005-006 GDPR training
• T-005-007 Technical responsible designation
• T-005-008 PRRC designation
• T-005-009 QMS procedures training

Development

HR tools

FactorialHR

To manage most of our needs we use a service called FactorialHR, which we have validated as recorded at the corresponding R-002-007 Process validation card. It is a cloud-based HR and employee management software platform with access control and different permissions.

FactorialHR is designed to help businesses streamline their HR processes. It offers a range of features and tools that assist with various HR tasks, making it easier for organizations to manage their workforce effectively.

This tool allows the employee and the company to collect in the same space all the employee's personnel information. We use Factorial HR for:

• Employee data management: FactorialHR allows us to store and manage employee data in a centralized and secure system. This includes information such as employee profiles, contact details, and employment history.
• Attendance and time tracking: The platform provides tools for tracking employee attendance and working hours, making it easier to manage time-off requests, calculate leave balances, and ensure compliance with Spanish labour regulations.
• Leave management: FactorialHR includes features for managing employee leave requests, approvals and tracking accrued leave balances. This helps efficiently handle vacation, sick leave and other time-off requests.
• Document management: The platform enables the digital storage and management of important HR documents, such as contracts, payslips, work safety and compliance-related paperwork. Additionally, we have integrated into the platform a signature tool to guarantee compliance with the data preservation requirements established in agreement with GDPR.
• Performance management: FactorialHR may include performance management tools that help HR teams set goals, conduct performance reviews and track employee progress.
• Employee self-service: Employees can access the platform to view their personal information, request time off, and access company policies and documents.
• Compliance: FactorialHR may offer features to help businesses comply with labour laws and regulations, such as tracking overtime, managing legal documents, and ensuring data privacy.

Planka

Whenever a Kanban-style task manager is needed, we use Planka. Planka is a project management and collaboration tool that uses a visual card-based system to help individuals and teams organize tasks, projects, and workflows. Planka offers visual task management, customizable workflows, collaboration (enables collaboration among HR team members and even with other departments), due dates and reminders, data tracking and reporting, scalability, security and privacy.

We validated Planka as recorded at the corresponding R-002-007 Process validation card and we use it for HR task management, onboarding of new hires and coordination of projects between teams.

Slack

Slack is a cloud-based collaboration and messaging platform designed for teams and businesses. It was created to improve communication and productivity in workplaces, especially for remote and distributed teams. Slack provides us with a centralized hub for team communication, allowing members to send messages, share files, collaborate on projects, and integrate with various third-party applications and services, as we detailed in the corresponding R-002-007 Process validation card.

As a company that works remotely, Slack provides us with a platform for HR to support employees, address their needs, and ensure effective communication across the organization, regardless of physical location. Managers and employees can communicate with each other, answer questions, and address issues in real time, reducing the need for lengthy email exchanges or phone calls.

Record working hours

The procedure aims to establish clear guidelines for recording working hours in accordance with Spanish labor law, specifically to Real Decreto 8/2019, while promoting a culture that values work-life balance through the use of the FactorialHR platform for accurate tracking, the distinction between pauses and breaks, adherence to contractual hours, and ensuring the accurate recording and review of work hours to foster a transparent work environment and support the well-being and satisfaction of the team.

Working hours are recorded using the FactorialHR platform, which provides an intuitive interface for accurate and hassle-free recording of work hours. Effective working hours are those spent exclusively on assigned tasks, excluding personal breaks, rest periods, or non-work-related activities. It is mandatory to record these hours daily on the FactorialHR platform.

For part-time contracts exceeding 6 daily hours, a break of at least 15 minutes is required. For full-time contracts with 8 effective working hours, a minimum break of 30 minutes is mandatory. These breaks must also be recorded in FactorialHR.

A pause refers to a brief period used for personal matters or non-work-related activities, while a break is a longer period specifically for physical and mental recovery, as required by law.

It is crucial to adhere to the contractual hours and not exceed them weekly. If additional working hours are needed, prior approval from the direct manager is required.

Each employee is responsible for ensuring their hours are correctly recorded in FactorialHR. At the end of each month, the direct manager reviews and signs the records to certify their accuracy.

Recording working hours is essential for legal compliance and fostering a transparent work environment. Legit.health promotes flexible working arrangements to support work-life balance, contributing to the well-being and satisfaction of the team.

Job descriptions and organizational chart

Each position in the company has an assigned job description with a specific code that is detailed in education, experience, skills and responsibilities. You can find each job description in each person's area in FactorialHR, approved and signed by their direct manager and the person assigned to the job description.

The organization chart can also be found in our FactorialHR tool, with its corresponding code, position and level. It shows the hierarchic relationship between employees and the job positions together with the name of the current holder of each position.

However, in some cases, the current holder of a position may be unable to perform their tasks. When this happens, a substitute may perform tasks according to the authorization chart described within the Annex-4 Substitution table of the Quality Manual. There, we describe who is capable of acting as a substitute for each job position.

Within the functions and responsibilities defined for the job position, it must be included in the relevant job description the statutory roles required by the regulations and standards applicable to Legit.Health (ISO 13485:2016, Real Decreto 1591/2009, Real Decreto 192/2023, MDD 93/42/EEC, MDR 2017/745):

• Management representative according to clause 5.5.2 of ISO 13485:2016
• Technical responsible according to Real Decreto 1591/2009 (and its update: 192/2023)
• Person Responsible for Regulatory Compliance (PRRC) according to article 15 of MDR 2017/745.

The designation of the applicable statutory roles are formalized in T-005-007 Technical Responsible designation and in T-005-008 PRRC designation.

Recruitment and onboarding

Specific procedures for recruitment and onboarding ensure that all candidates go through a consistent and thorough hiring process. This helps the company select the right candidates and minimize the risk of biased hiring decisions. The main objective of onboarding is to provide the necessary information that a person needs when joining the company to be able to perform their job well.

Recruitment procedure

The recruitment process begins with identifying the need to bring in an individual and continues until the final candidate accepts the offer. The main owner of this process will be JD-006 and will collaborate jointly with JD-001, any involved manager and the direct responsible of the specific position.

1. Detection of the need to hire a new personnel.
2. Definition of job description: confirm education, experience, skills, responsibilities, salary and type of contract required for the new hire.
3. Reach an agreement regarding the process, its phases and timeline. Determine the necessary steps for candidates, such as passing a technical test, a practical assessment or engaging in pair programming. Identify the hiring manager for this position and specify the decision-making authority during the process.
4. Publish the job post on recruitment channels and share the new opening position with the Legit.health team.
5. First candidate screening from the resume/CV by JD-006.
   1. In case the profile matches the position we are looking for, we will save the resume in the corresponding folder in Google Drive (Human Resources > Hiring > Position name > CVs Candidates).
   2. In case the profile does not fit, we will send an email communicating the rejection.
6. First interview screening by JD-006 via video call or call . In this first contact we will explain the position in detail and we will make an introduction of Legit.health. We will assess: languages, remote vs on-site, reason for change and salary expectations. In case the manager needs any other killer questions to determine if the candidate is valid or not for the position, we will ask these questions in this first interview. We will inform the candidate about the process and timelines. We will write down all the answers in an excel file in the same folder in Google Drive (Human Resources > Hiring > Position name > Candidates | Position name). In case the profile does not fit, we will send an email communicating the rejection.
7. Give visibility to the hiring manager on the candidates' answers in the first filter. We will follow the phases agreed at the beginning of the process:
   1. In the case that it is necessary for the candidate to pass a technical test: the hiring manager will be responsible for elaborating it and sending it to HR. HR will be responsible for providing the test to the person via email and give the necessary instructions to solve the test.
   2. In case the profile does not pass the test, we will send an email communicating the rejection.
8. If we continue with the candidate in the process, HR will schedule an interview between the direct manager and the candidate. The main objective of this interview is to validate the candidate's ability to perform the job functions, hard skills, growth potential, values and social fit with the team. HR will be responsible for scheduling the interview, but the direct manager is responsible for keeping their agenda up to date. We will keep the direct manager in copy during all communication with the candidate by email. In case the candidate does not pass the interview with the direct manager, we will send an email communicating the rejection.
9. In case we have decided at the beginning of the process to involve more people from the team in the process (teammates, other peers, managers), we will invite them to the next interview with the candidate(s) who have reached this stage. In case the individual does not pass the interview with the teammates, we will send an email communicating the rejection.
10. When we have the final decision on the person we would like to have join the team, we will schedule a final interview between the finalist candidate and the JD-001.
11. After the final interview with the JD-001, all individuals involved in the process will come to a collective agreement regarding whether this is the profile we aim to incorporate into the team. JD-006 will be responsible for reaching out to the selected candidate to discuss the offer and its associated conditions. If there are any candidates remaining in the process whom we have not yet contacted, we will send an email informing them that they have been removed from consideration.

Onboarding procedure

The onboarding process begins from the moment the candidate accepts the offer to join the company and ends when the new hire is fully trained to perform their duties in the job position.

Here are the steps further detailed:

1. The JD-006 sends an email to the individual requesting their documentation. This information will be used to:
   1. Process the contract and enrollment in social security (through our accountant office).
   2. Create the employee file R-005-002 Personnel card in FactorialHR. The necessary information to request from the individual and to create the R-005-002 Personnel card will be:
      • Full name
      • DNI / NIE (and attach an image)
      • Date of birth
      • Social security number
      • Bank account number
      • Address
      • Emergency contact number
      • Titles
      • Updated and signed CV
2. Once we have this documentation from the individual, the JD-006 will provide it to the accountant office so that they can prepare the contract for us. It is necessary to complete this process with a minimum lead time of 48 hours before the start date.
3. The JD-006 will upload the contract to FactorialHR so that the interested individual and the JD-001 can sign it.
4. Additionally, the JD-006 must also upload the following files so that the individual reads, reviews, and signs to acknowledge their agreement with their content:
   • Occupational risk prevention folder: Information Delivery Record, Occupational Risk Prevention in VDT (Visual Display Terminal) and Telecommuting.
   • Company policies folder: Document outlining important matters in Legit.health, Expense Policy and Vacation Policy
   • Job description folder: We will find the job description of the person's position with its code, title, experience and requirements. It must be signed by the individual and their direct supervisor.
5. Before the start day, the JD-006 will create a customized onboarding board on Trello with all the materials and training required by the new joiner to get acquainted with the company, its product, the team, and their responsibilities. The content of this board will be as follows:
   • Introduction to the organization and its history: This section provides new employees with a comprehensive understanding of Legit.health, including its background, mission, and key milestones in its history.
   • Contract and paperwork: New hires will be guided through the essential contractual and administrative procedures, ensuring a smooth onboarding process.
   • FactorialHR and Time Tracking: Training on the utilization of FactorialHR and time tracking tools, which are crucial for managing HR-related tasks and tracking work hours effectively.
   • Google Workspace, Drive, Calendar, and Google Docs: An in-depth exploration of Google Workspace tools, such as Google Drive, Calendar, and Docs, to enhance collaboration and productivity.
   • Slack and proper communication: Familiarization with Slack and guidelines for effective communication within the organization, promoting efficient teamwork and information sharing.
   • Product: A detailed introduction to our products and services, ensuring employees have a strong understanding of what the company offers.
   • Our value proposition: Insight into the unique value that we bring to our customers and the market, highlighting the company's competitive advantages.
   • Branding guidelines: A comprehensive overview of our branding guidelines, ensuring consistency in all company communications and materials.
   • Cybersecurity: Education on cybersecurity practices and protocols to safeguard sensitive company and client data. This training will provide information on the correct use of Passbolt as a password manager and an introduction to GDPR. There is additional GDPR training within the training plan.
   • Project management: Training on the use of our project management tool that helps streamline tasks and projects within the organization.
   • Occupational risk prevention vourse: A mandatory course on occupational risk prevention to ensure the safety and well-being of all employees.
   • Get to Know Our Quality Management System (QMS): An introduction to our Quality Management System, which plays a vital role in maintaining high standards and quality control.
   • Traning on QMS procedures applicable to the specific job description: the training consists of reading and understanding the procedures. The evidence of the QMS procedures training is recorded in T-005-009 QMS procedures training.
   • Hubspot (for Business Development team): Training on Hubspot, a customer relationship management (CRM) platform, to empower employees in managing customer interactions and marketing efforts.
   • Stack Overflow (for Product Development team): Introduction to the use of StackOverflow as a valuable resource for technical problem-solving and knowledge sharing.
   • GDPR and Privacy: Current employees of the company with the competencies to perform the training will educate the new employees on GDPR and cybersecurity. When required, the new employee will receive additional external education on these topics.
6. JD-012 will be responsible for creating the new hire's corporate email and granting them access to all necessary groups and platforms. The day before their incorporation, the person will receive the company's corporate email.
7. JD-012 will be responsible for managing and sending the necessary equipment for the new hire, such as a computer, company phone, or any other items the individual may need. The shipment will take place on the same day or during the week of their onboarding.
8. The week before the onboarding, JD-006 will send an email to the individual explaining the onboarding process that we will follow through Trello, and asking if they have any questions.
9. On the start day, JD-006 will send an email early in the morning to the individual's corporate email, attaching the personalized onboarding board on Trello. The individual can then begin their personalized onboarding training. The onboarding training is estimated to take 20-24 hours. Once completed, the individual must sign the T-005-005-Certification that the Legit.health onboarding training has been completed.
10. With regard to occupational risk prevention, the individual will have the option to choose whether to undergo a medical examination or not (as we do not have positions that require mandatory medical exams when working with VDT). JD-006 will be responsible for managing the medical appointment.
11. The onboarding training includes meetings with team members. Upon completion of the onboarding, the individual will meet with their direct manager to begin discussing tasks and responsibilities. Additionally, the individual will also meet with JD-006 to provide feedback on the training process and discuss potential areas for improvement.

Training

Procedures for training and development guide employees on how to access learning opportunities within the organization. This helps employees improve their skills and contribute more effectively to the company's success.

Before starting to define the training procedure, we must take into account two clear concepts to differentiate them: training plan vs training program.

• A training plan is a comprehensive outline or document that defines the learning and development goals for employees within a specific timeframe. It is a high-level strategic document that provides an overview of our training and development needs and objectives. Our T-005-003 Training plan includes:
  • Training goals and objectives.
  • Target audience: identifies the specific group of employees who will be trained.
  • Training needs analysis.
  • Budget and resources.
  • Timeline.
  • Evaluation and measurement: criteria for assessing the effectiveness and impact of the training.
• A training program is a specific, detailed initiative within the broader training plan. It is a structured set of activities, courses, workshops or experiences designed to meet the defined objectives of the training plan. Each training program will be included within each T-005-004 Training evaluation and record and includes:
  • Title.
  • Learning methods: such as in-person training, e-learning, workshops or on-the-job training.
  • Trainers or facilitators: The individuals responsible for delivering the training content.
  • Assessment and feedback: Methods for evaluating the participants’ progress and providing feedback.
  • Duration and schedule.

As we have previously mentioned, there are basic training courses that all employees must complete upon joining us. The evidence of the knowledge acquired in this training and the content of the course can be found in detail in each employee's Factorial folder, signed by the employee and the direct manager: T-005-005 Certification that the onboarding training has been completed and T-005-009 QMS procedures training.

Additionally, there is a specific GDPR training that all employees undergo upon joining the company. The evidence of the knowledge acquired in this training and the content of this course is registered at the T-005-006 GDPR training and it can also be found in the HR tool.

All the training steps are described in the following flowchart:

Training plan

The term training refers to all activities (internal or external) carried out by staff to obtain the skills required to fulfil the assigned tasks and to be promoted.

These needs are analyzed from the time the staff signs and date their T-005-001 Job Description, from their incorporation into the company, and throughout their professional development in the company and new possible procedures that would be implemented, or as a result of regulatory changes and/or the new activities planned during the Annual Management Review,.

Training needs can be detected by our personnel or required by any area manager to achieve the objectives and the production plan. The JD-004 and JD-006, in consultation with department heads and supervisors, create an annual T-005-003 Training plan outlining the specific training and development activities required for each employee. The annual training plan will be accessible to all employees in the QMS and certification records will be stored in each employee's HR tool folder.

When someone identifies new training needs, if it is their personnel, it must be communicated to the area manager and the area manager should evaluate the needs and if this applies, they should request them to the JD-001.

• If the need is detected directly by the area manager, it must be communicated and requested to the JD-001.
• If the need is detected by other personnel, such as the person in charge of Human Resources, this must always be communicated to the area manager and the area manager to the JD-001.
• The area manager or the JD-006 determines the budget and resources needed for training, including materials, trainers and facilities. In addition, JD-006 is responsible for consulting if we have a training budget in Fundae and if the training can be subsidized.
• The JD-004 and the JD-006 are responsible for registering the training in the T-005-003 Training plan.
• The JD-001 then will decide to approve or reject the training proposed, previously to its development.
• The evidence of this approval is recorded in the T-005-003 Training plan.

Execution

Training sessions can be conducted through various methods, such as workshops, on-the-job training, e-learning, external courses, or seminars. Depending on the content of the training and the people or department to be trained, the training may be given by internal or external workers.

Trainers should be qualified and competent in the subject matter they are instructing.

Evaluation

The JD-004 coordinates the training actions registered in the T-005-003 Training plan. When the personnel finish the courses, they should be registered and evaluated using the T-005-004 Training evaluation and record, which includes the following information: training objectives, content, methods, schedule, responsible personnel for each training activity and evaluation of the training by the employee and the manager.

After some time (1 - 4 weeks), the area manager responsible for each training evaluates the use made by each participant of the training and the benefit for us, and records the results in the T-005-004 Training evaluation and record.

Effectiveness verification

Every year, during the Annual Management Review, the Training plan T-005-003 Training plan is reviewed and updated according to the needs detected, and the JD-001 inform the area managers about the training to perform arising from the new plan.

The employee T-005-004 Training evaluation and record for each training received, along with the external certificates (if there are any) for every training are collected in the corresponding HR tool employee folder.

HR objectives, appraisals and feedback

Once a year, each area manager maintains a meeting with our personnel to review the objectives established for the last period, to establish new ones for the next year, to evaluate the performance of the employee and obtain feedback from the employee to improve the following period.

CVs are updated, signed and dated yearly to ensure they cover all the new education received and the employee is still competent to perform our responsibilities and tasks.

Offboarding

Procedures for handling employee terminations and separations outline the steps to take to ensure a smooth transition and protect the company's interests, especially in cases of involuntary terminations.

The offboarding process is summarised in the following flowchart:

When an employee notifies their intention to leave the company, the offboarding procedure starts. This can be notified by email, letter or other means.

First of all the JD-006updates the T-005-002 Personnel card of the employee and then the Organization chart in Factorial.

Then the direct manager or JD-001evaluate the need for replacement for this employee.

• If the replacement is required the onboarding procedure starts
• If the replacement is not required or not possible, the direct manager reassigns the responsibilities and tasks belonging to the employee to another member/s of the company to ensure the execution of the activities.

Associated Documents

• T-005-001 Job description
• T-005-002 Personnel card
• T-005-003 Training plan
• T-005-004 Training evaluation and record
• T-005-005 Certification that the onboarding training has been completed
• T-005-006 GDPR training
• T-005-007 Technical Responsible designation
• T-005-008 PRRC designation
• T-005-009 QMS procedures training
• Annex-4 Substitution table

Signature meaning

The signatures for the approval process of this document can be found in the verified commits at the repository for the QMS. As a reference, the team members who are expected to participate in this document and their roles in the approval process, as defined in Annex I Responsibility Matrix of the GP-001, are:

• Author: JD-006
• Reviewer: JD-003, JD-004
• Approver: JD-001