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  • Procedures
    • GP-001 Control of documents
    • GP-002 Quality planning
    • GP-003 Audits
    • GP-004 Vigilance system
    • GP-005 Human Resources and Training
    • GP-006 Non-conformity, Corrective and Preventive actions
    • GP-007 Post-market surveillance
    • GP-009 Sales
    • GP-010 Purchases and suppliers evaluation
    • GP-011 Provision of service
    • GP-012 Design, redesign and development
    • GP-013 Risk management
    • GP-014 Feedback and complaints
    • GP-015 Clinical evaluation
    • GP-016 Traceability and identification
    • GP-017 Technical assistance service
    • GP-018 Infrastructure and facilities
    • GP-019 Non-product software validation
    • GP-020 QMS Data analysis
    • GP-021 Communications
    • GP-022 Document translation
    • GP-023 Change control management
    • GP-024 Predetermined Change Control Plan
    • GP-025 Usability and Human Factors Engineering
    • GP-026 Market-specific product requirements
    • GP-027 Corporate Governance
    • GP-028 AI Development
    • GP-029 Software Delivery and Commissioning
    • GP-030 Cyber Security Management
    • GP-031 Training Data Governance
    • GP-050 Data Protection
    • GP-051 Security violations
    • GP-052 Data Privacy Impact Assessment (DPIA)
    • GP-100 Business Continuity (BCP) and Disaster Recovery plans (DRP)
    • GP-101 Information security
    • GP-110 Esquema Nacional de Seguridad
    • GP-200 Remote Data Acquisition in Clinical Investigations
    • GP-600 Equality Planning
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  • GP-600 Equality Planning

GP-600 Equality Planning

Purpose​

Define the methodology for developing, implementing, monitoring, and reviewing the Equality Plan as required by Spanish legislation (Ley Orgánica 3/2007 and Real Decreto 901/2020). This procedure ensures:

  • Equal treatment and opportunities for all team members regardless of sex
  • Prevention and elimination of discrimination in all areas of employment
  • Compliance with applicable equality legislation
  • Establishment of measures to promote a balanced and inclusive workplace

Scope​

All team members and all areas of employment practices, including recruitment, promotion, classification, compensation, training, work-life balance, communication, and workplace health.

Responsibilities​

JD-001​

  • Approve the Equality Plan
  • Ensure management commitment to equality principles
  • Allocate resources for the implementation of equality measures

JD-006​

  • Author and coordinate the Equality Plan
  • Lead the Equality Commission
  • Conduct diagnostic assessments of equality across the organisation
  • Monitor and report on the implementation of equality measures
  • Maintain equality-related records

JD-004​

  • Review the Equality Plan for QMS and regulatory alignment

JD-003​

  • Review the Equality Plan

All team members​

  • Participate in equality initiatives and training
  • Report any instances of discrimination or harassment through the established channels

Inputs​

  • Spanish legal requirements (Ley Orgánica 3/2007, Real Decreto 901/2020, Real Decreto 902/2020, Real Decreto 1026/2024)
  • Workforce data and composition statistics from FactorialHR
  • Diagnostic assessments of equality across all areas of employment
  • Salary audit (auditoría retributiva) per Real Decreto 902/2020
  • Feedback from team members and the Equality Commission
  • Previous evaluation and monitoring results

Outputs​

  • R-600-001 Equality Plan
  • Equality Commission meeting minutes
  • Diagnostic reports
  • Monitoring and follow-up reports

Development​

Legal framework​

The Equality Plan is required by the following Spanish legislation:

  • Ley Orgánica 3/2007 (LOI): Establishes the obligation for companies to develop and implement equality plans to ensure effective equal treatment and opportunities between women and men
  • Real Decreto 901/2020: Regulates equality plans, their mandatory contents (Art. 8), diagnostic assessment (Art. 7), registration requirements (Art. 11), and validity (Art. 9)
  • Real Decreto 902/2020: Establishes requirements for equal pay between women and men, including salary audits (auditoría retributiva) and pay registers (registro retributivo)
  • Real Decreto 1026/2024: Requires companies with 50+ employees to implement LGTBI equality measures and a specific anti-harassment protocol for LGTBI-based harassment

Equality Commission​

The Equality Commission (Comisión Permanente de Igualdad) is the body responsible for overseeing the development, implementation, monitoring, and evaluation of the Equality Plan.

Composition​

Per Real Decreto 901/2020 Art. 5, the negotiating commission must have parity representation (equal number of management and worker representatives), with a maximum of 6 members per side:

  • Management representatives (including JD-001)
  • Workers' representative(s) in equal number
  • External advisors may be consulted as needed but have no vote

Responsibilities​

  • Analyse diagnostic data and propose improvements
  • Contribute initiatives and measures for the Equality Plan
  • Monitor, control, and evaluate the implementation of planned measures
  • Assess the effects of the plan by comparing current status against the initial diagnostic
  • Address queries and complaints from team members
  • Promote awareness and training on equality matters

Meeting frequency​

  • At least two ordinary meetings per year (one in Q1, one in Q4)
  • Extraordinary meetings may be convened as needed

Diagnostic assessment​

Before developing or renewing the Equality Plan, a diagnostic assessment (diagnóstico de situación) must be conducted per Real Decreto 901/2020 Art. 7. The diagnostic must:

  • Be negotiated within the Equality Commission (not prepared unilaterally)
  • Use quantitative and qualitative indicators disaggregated by sex
  • Cover all positions and work centres
  • Extend across all nine mandatory areas per Art. 46.2 of Ley Orgánica 3/2007

The nine mandatory areas are:

  1. Access to employment (selection and hiring processes)
  2. Professional classification
  3. Training
  4. Professional promotion
  5. Working conditions, including the salary audit (auditoría retributiva)
  6. Co-responsible exercise of personal, family, and work-life balance rights
  7. Female underrepresentation (infrarrepresentación femenina)
  8. Compensation (retribuciones)
  9. Prevention of sexual harassment and harassment on the grounds of sex

The diagnostic provides the baseline data against which the effectiveness of planned measures will be evaluated.

Salary audit​

Per Real Decreto 902/2020 Art. 7–8, the Equality Plan must include a salary audit (auditoría retributiva) containing:

  1. Compensation diagnosis: Job position evaluation (nature of functions, educational requirements, professional conditions, working conditions), assessment of factors causing pay differences, and analysis of work-life balance measure deficiencies
  2. Action plan: Objectives, concrete actions, timeline, and responsible parties for correcting any pay inequalities, with a monitoring system

Additionally, a pay register (registro retributivo) must be maintained per Art. 5–6 of RD 902/2020, including arithmetic means and medians of total compensation disaggregated by sex and professional classification. When the average compensation of one sex exceeds the other by 25% or more, a justification must be included.

REGCON registration​

Per Real Decreto 901/2020 Art. 11, the Equality Plan must be registered in REGCON (Registro de Convenios y Acuerdos Colectivos de Trabajo y Planes de Igualdad) within 15 days of signing. JD-006 is responsible for submitting the registration electronically.

Plan development and approval​

Areas of action​

The Equality Plan must address the following nine mandatory areas per Art. 46.2 of Ley Orgánica 3/2007, with specific actions, objectives, monitoring mechanisms, responsible personnel, and timelines for each:

  1. Access to employment: Ensure gender-neutral recruitment processes, inclusive language in job postings, candidate tracking disaggregated by sex
  2. Professional classification: Design classification criteria that are neutral and objective, free from sex-based discrimination
  3. Training: Provide equality training to all personnel, with emphasis on management, verify satisfaction with gender perspective
  4. Professional promotion: Guarantee equitable access to promotion opportunities, audit internal promotion processes
  5. Working conditions: Conduct salary audit (auditoría retributiva), ensure equal pay for work of equal value, review working conditions with a gender perspective
  6. Work-life balance: Survey team members on work-life balance measures, communicate legal rights, promote co-responsibility
  7. Female underrepresentation: Analyse and address underrepresentation of women across professional groups, especially in technical roles
  8. Compensation: Conduct annual pay studies disaggregated by sex, maintain the pay register (registro retributivo)
  9. Prevention of harassment: Maintain and update the anti-harassment protocol, evaluate risks with a gender perspective, provide awareness training

Monitoring and evaluation​

The Equality Commission conducts biannual evaluations of the plan's implementation:

  • First evaluation: During Q1 of each year
  • Second evaluation: During Q4 of each year

Each evaluation covers:

  • Status of each planned measure (implemented, in progress, pending)
  • Degree of objective achievement
  • Identification of barriers or obstacles
  • Analysis of changes in the organisation
  • Corrective actions if needed

Results are documented using the monitoring form template (Annex IV of the Equality Plan).

Anti-harassment protocol​

The Equality Plan includes an anti-harassment protocol (Annex II of R-600-001) that establishes:

  • Definitions of moral/psychological harassment, sexual harassment, and harassment by reason of sex
  • Procedures for reporting and investigating complaints
  • Composition and responsibilities of the Investigation Commission
  • Phases of the procedure (initiation, investigation, conclusion)
  • Measures and actions based on investigation outcomes
  • Dissemination, monitoring, and review mechanisms

Complaints can be submitted via the designated email channels or directly to any member of the Equality Commission.

LGTBI equality measures​

Per Real Decreto 1026/2024 (effective 10 January 2025), companies with 50 or more employees must implement:

  • Planned measures for the equality and non-discrimination of LGTBI persons in the workplace
  • A specific anti-harassment protocol for LGTBI-based harassment
  • Training and awareness actions on LGTBI diversity
  • Inclusive language in internal and external communications

These measures must be negotiated through collective bargaining and are maintained alongside the Equality Plan.

Validity and renewal​

Per Real Decreto 901/2020 Art. 9:

  • The Equality Plan has a maximum validity of four years
  • The plan must include periodic assessments per its own schedule, plus mandatory interim and final evaluations
  • Mandatory review must occur when:
    • Monitoring results require it
    • The plan proves insufficient
    • Substantial changes affect staffing, work methods, or compensation systems
    • A court ruling determines discrimination or plan inadequacy
    • A relevant labour inspection or circumstance arises
  • Negotiation of a new plan must begin at least one year before the current plan expires
  • If no new plan is signed by the expiry date, the current plan is automatically extended

Modification procedure​

Per Real Decreto 901/2020 Art. 8.2, the Equality Plan must include a procedure for modifications:

  1. Any member of the Equality Commission may propose modifications in writing
  2. The Commission shall evaluate the proposal at its next meeting (or convene an extraordinary meeting if urgent)
  3. Modifications require agreement by both management and worker representatives
  4. Approved modifications shall be documented, communicated to all team members, and registered in REGCON if they affect the plan's essential content
  5. Discrepancies that cannot be resolved within the Commission shall be addressed through the applicable collective bargaining dispute resolution procedures

Associated Documents​

  • R-600-001 Equality Plan

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 Human Resources Manager
  • Reviewer: JD-003 Design & Development Manager, JD-004 Quality Manager & PRRC
  • Approver: JD-001 General Manager
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Records
  • Purpose
  • Scope
  • Responsibilities
    • JD-001
    • JD-006
    • JD-004
    • JD-003
    • All team members
  • Inputs
  • Outputs
  • Development
    • Legal framework
    • Equality Commission
      • Composition
      • Responsibilities
      • Meeting frequency
    • Diagnostic assessment
    • Salary audit
    • REGCON registration
    • Plan development and approval
    • Areas of action
    • Monitoring and evaluation
    • Anti-harassment protocol
    • LGTBI equality measures
    • Validity and renewal
    • Modification procedure
  • Associated Documents
All the information contained in this QMS is confidential. The recipient agrees not to transmit or reproduce the information, neither by himself nor by third parties, through whichever means, without obtaining the prior written permission of Legit.Health (AI Labs Group S.L.)