R-600-001 Equality Plan

• Governed by GP-600 Equality Planning

Introduction

The principle of equality is recognised both at the international level and in Spanish legislation. Equality between men and women is a universal legal principle enshrined in various international human rights instruments and is likewise a fundamental principle of the European Union. Specifically, Article 14 of the Spanish Constitution proclaims the right to equality and non-discrimination on the grounds of sex.

Ley Orgánica 3/2007, of 22 March, on the effective equality of women and men (hereinafter, the LOI), aims to make effective the right to equal treatment and equal opportunities between women and men, particularly through the elimination of discrimination against women in any sphere of life.

The most significant aspect of this law lies in the prevention of discriminatory conduct and the provision of active policies to give effect to the principle of equality. This necessarily involves the application of the equality principle across the various spheres of social, cultural, and artistic life in which inequality may arise or be perpetuated — hence the consideration of the cross-cutting dimension of equality, a hallmark of modern anti-discrimination law.

In the employment sphere, the LOI establishes the duty of companies to respect the principle of equality, requiring them to adopt measures aimed at preventing any form of discrimination between women and men. Specifically, it refers to the development and implementation of an equality plan as an ordered set of measures adopted following a diagnostic assessment, including the strategies and practices needed, as well as a system for monitoring and evaluating their implementation.

To contribute effectively to the application of the principle of non-discrimination and its development — under the concepts of equal conditions for work of equal value — it is necessary to develop positive action, particularly in matters of hiring, pay, training, and working conditions in general. In this way, where candidates are equally qualified, preference shall be given to persons of the less-represented gender in the relevant professional group.

In view of the foregoing, we declare our commitment to implementing measures aimed at maintaining equal treatment and equal opportunities between men and women, in accordance with the requirements of the applicable legislation.

The company was incorporated in 2020 by a team of researchers from the UPV/EHU who began working together in 2017 on a research project applying artificial intelligence and computer vision algorithms to the early detection of skin cancer.

Our mission is to develop and commercialise computer algorithms to assist dermatologists through artificial intelligence in diagnosing conditions, monitoring lesions, measuring treatment effectiveness, and supporting primary care. This mission is especially significant considering that, according to the WHO (World Health Organisation), skin diseases are among the most common of all human health afflictions, affecting nearly 900 million people worldwide at any given time — meaning that 15% of the world's population could potentially benefit from the device, in addition to healthcare professionals themselves.

Recognising the importance of establishing an Equality Plan, we are committed to implementing the necessary measures through this plan, with due diligence and dedication, and with the firm objective of preventing any form of employment discrimination between women and men, and achieving a balanced situation between both sexes — aligning with European policies aimed at eradicating all forms of discrimination in the workplace.

The purpose of this document is to regulate and give effect to the principle of equality between women and men within the company, establishing general principles, determining the basic actions to be implemented, and embedding the principle of equal opportunities within the organisational structure.

As of the date of this Plan's approval, the workforce comprises 26 people, of whom 16 are men and 10 are women, meaning that 61.5% of the workforce is male and 38.5% is female. A detailed breakdown is provided in Section 3 (Diagnostic Assessment).

General Provisions

Applicable legislation

International standards

• Convention on the Elimination of All Forms of Discrimination against Women
• European Convention for the Protection of Human Rights and Fundamental Freedoms
• Treaty Establishing the European Community
• Charter of Fundamental Rights of the European Union
• World Conference on Women held in Beijing in 1995
• World Declaration on Women in Local Government

European Union

• Directive 2006/54/EC of the European Parliament and of the Council of 5 July 2006, on the implementation of the principle of equal opportunities and equal treatment of men and women in matters of employment and occupation. This Directive contains provisions to implement the principle of equal treatment regarding access to employment (including promotion and vocational training), working conditions (including pay), and occupational social security schemes.
• Directive 2002/73/EC of the European Parliament and of the Council, of 23 September 2002, amending Council Directive 76/207/EEC on the implementation of the principle of equal treatment for men and women as regards access to employment, vocational training and promotion, and working conditions.
• Directive 96/97/EC of the Council of 20 December 1996, amending Directive 86/378/EEC on the implementation of the principle of equal treatment for men and women in occupational social security schemes.
• Directive 86/613/EEC of the Council of 11 December 1986, on the application of the principle of equal treatment between men and women engaged in an activity (including agriculture) in a self-employed capacity, and on the protection of self-employed women during pregnancy and motherhood.
• Council Directive 2004/113/EC of 13 December 2004, implementing the principle of equal treatment between men and women in the access to and supply of goods and services.

Spanish legislation

• Constitución Española of 1978, Articles 9.2 and 14
• Ley 30/2003, of 13 October, on measures to incorporate gender impact assessment in regulatory provisions prepared by the Government
• Ley 15/2022, of 12 July, on the Guarantee of Equal Treatment and Non-Discrimination
• Ley Orgánica 10/2022, of 6 September, on the Comprehensive Guarantee of Sexual Freedom (reform of the Penal Code regarding harassment and discrimination)
• Ley 4/2023, of 28 February, for the real and effective equality of trans persons and for the guarantee of the rights of LGBTI persons
• Ley Orgánica 3/2007, of 22 March, on the effective equality of women and men (LOIEMH)
• Real Decreto-ley 6/2019, of 1 March, on urgent measures to guarantee equal treatment and opportunities between women and men in employment and occupation
• Real Decreto 901/2020, of 13 October, regulating equality plans and their registration, amending Real Decreto 713/2010 on the registration and deposit of collective agreements
• Real Decreto 902/2020, of 13 October, on equal pay between women and men

Basque Country legislation

• Decreto Legislativo 1/2023, of 17 January, consolidating and updating previous provisions on equality and prevention of gender-based violence in the Basque Country

Management commitment

Management declares its commitment to establishing and developing policies that integrate equal treatment and equal opportunities between women and men, without direct or indirect discrimination on the grounds of sex, as well as to promoting and fostering measures to achieve real equality within the organisation. Equal opportunities between women and men is established as a strategic principle of our corporate and human resources policy, in accordance with the definition of that principle set out in Ley Orgánica 3/2007.

In each and every area in which our organisation operates — from recruitment to promotion, including pay policy, training, working conditions and employment, occupational health, time management, and work-life balance — we adopt the principle of equal opportunities between women and men, with particular attention to indirect discrimination, understood as "a situation in which an apparently neutral provision, criterion or practice puts persons of one sex at a particular disadvantage compared with persons of the other sex".

Regarding both internal and external communication, we project an image consistent with this principle of equal opportunities. The principles set out above shall be put into practice through the promotion of equality measures and, in particular, through the implementation of this Equality Plan, with corresponding monitoring systems, with the aim of advancing towards real equality between women and men in the company and, by extension, in society as a whole.

To achieve this purpose, the participation of all team members shall be sought — not only in the drafting process, as established by the LOI, but throughout the entire process of development and evaluation of the Equality Plan, through the Equality Commission, which shall be constituted for this purpose.

This Equality Plan, together with the Occupational Risk Prevention Plan, shall lay the foundations for compliance with legal requirements in their respective areas, embedding values within the company and promoting a culture based on equal opportunities and equal treatment as an element of quality and a strategic value for progress, with the sole objective of achieving professional excellence in all its dimensions.

Equality Commission

The Equality Commission (Comisión Permanente de Igualdad) was constituted on 10/11/2021 and its composition updated upon the approval of this Plan. Per Real Decreto 901/2020 Art. 5, the negotiating commission must have parity representation, with a maximum of 6 members per side. The current composition is:

Management representation

• JD-001 (acting as President for the purposes of this plan)
• JD-006 (acting as Secretary for the purposes of this plan)

Workers' representation

• JD-003 (workers' representative)
• JD-012 (workers' representative)

The Commission is responsible for driving the implementation of actions, as well as monitoring, evaluating, and controlling this Equality Plan, as set out in Annex III "Rules of Procedure for the Equality Commission".

Subscribing parties

This Equality Plan has been subscribed by the following members of the organisation:

• Representing Management and the HR Department: JD-001 and JD-006
• Representing the workers for the Equality Plan: JD-003 and JD-012

The commitment to establishing the Equality Plan is agreed upon according to the following general principles:

1. Maintain equal treatment and equal opportunities between women and men in the company (Art. 46.1 LOIEMH)
2. Prevent and eliminate, if any exist, any circumstance or practice that generates or may generate discrimination on the grounds of sex (Art. 46.1 LOIEMH), whether direct or indirect (Art. 6 LOIEMH) — especially those arising from maternity, the assumption of family obligations, and marital status (Art. 3 and 8 LOIEMH)
3. Specific positive action measures in favour of women shall be adopted to correct evident situations of de facto inequality with respect to men, should any exist. Such measures, which shall be applied as long as such situations persist, must be reasonable and proportionate in relation to the objective pursued in each case (Art. 11 LOIEMH)
4. The participation and access of the members of the Equality Commission to all data and information relating to each phase of the Equality Plan development is guaranteed, provided that Ley Orgánica 3/2018 on Personal Data Protection and Regulation (EU) 2016/679 (GDPR) are not breached

The information and data received are confidential, with a firm commitment from all participants to their non-use for any purpose.

General objective

The main objective of the Equality Plan is to guarantee due respect for the principle of equal treatment and equal opportunities between women and men within the company.

The specific objectives of the Plan are set out in Section 3 of this document.

Scope and validity

In accordance with Article 46.3 of the LOI, the Plan applies to the entirety of the company — meaning all workers providing their services at all current and future work centres in the national territory. Notwithstanding the foregoing, where necessary, specific actions may be established to address the specific needs of particular work centres, areas, or departments.

The provisions of the Equality Plan are mandatory and generally applicable to all company personnel, regardless of their contractual modality or position held. Its content is variable and dynamic, and its measures shall adhere to principles of proportionality and be adjusted to the actual situation of the company at each point in time.

As an ordered set of measures oriented towards achieving the objectives specified herein — understanding that some objectives may be achieved before others, that the entry into force of specific measures may differ and be progressive, and that the special nature of positive actions means they apply only as long as the situations they aim to correct persist — this Plan is linked to the achievement of objectives, though the parties understand that its content must be updated after two years from its signing.

To this end, this Plan has a validity period of two years, extending from 10 March 2025 (the date of its signing and entry into force) to 10 March 2027.

Until a new Plan is agreed upon, the content of this document shall remain in force.

Negotiation of the next Plan must necessarily begin within three months following the expiry of this Plan's validity period.

Upon the indicated end date, a new Plan shall be approved, adjusted to the evolution experienced in the company. Should a new Plan not have been signed by that date, this Equality Plan shall be automatically extended for a period of four years.

For the purposes of prioritising and scheduling the implementation of the various measures provided for in the Plan, an action calendar is attached as Annex I.

Evaluation and monitoring system

To guarantee the effectiveness of the Equality Plan and the achievement of its objectives, the Equality Commission — designated for the purpose of negotiating and subscribing this Plan — shall be responsible for its evaluation and monitoring.

This monitoring shall be carried out through periodic meetings, which must be held at least twice per year.

To this end, two meetings per year are agreed upon to supervise the effective monitoring and control of the measures to be applied, as well as to address any issues that may arise regarding equality between men and women or discrimination on the grounds of sex. The first shall take place during the first quarter of the year, and the second during the last quarter.

As a result of the evaluation, the Commission shall complete monitoring forms (Annex IV), which include the following data:

1. Date of implementation and completion of the measure
2. Description of the measure
3. Objective to be achieved
4. Target personnel
5. Personnel responsible for implementation and execution
6. Resources applied
7. Monitoring and evaluation mechanisms
8. Degree of measure implementation
9. Degree of objective achievement
10. Any other noteworthy circumstances

The evaluation and monitoring objectives include:

• Control over measures effectively applied and those pending
• Identification of barriers or obstacles to implementation, for strategy correction or modification
• Enabling adequate analysis of changes within the company
• Facilitating information on the Plan's implementation
• Presenting the corresponding results evaluation report to the competent body, as required by applicable legislation

Right of access

Access to information on the content of the Plan and measures related to the achievement of its objectives is guaranteed to all company personnel. All documentation relating to this Equality Plan and its activities is deposited in the digital repository accessible to all workers, and updates are communicated via internal email to each employee.

Anti-harassment protocol

In accordance with Article 48 of the LOI, the company shall promote working conditions that prevent sexual harassment, harassment on the grounds of sex, and psychological harassment, through the application of a specific protocol.

This protocol, attached to this Plan as Annex II, aims to promote the prevention of harassment and to establish a channel for complaints or claims regarding such situations.

All team members shall contribute to preventing potential harassment situations through personnel awareness-raising and by informing the HR function of any conduct or behaviour they become aware of that could give rise to such situations.

Budget

No grants have been applied for or received for the implementation of this Plan. The company shall allocate the necessary resources to implement, monitor, and evaluate each measure. Training agreed in the Equality Plan shall be carried out primarily using the training subsidy credit established by the State Foundation for Employment Training (Fundación Estatal para la Formación y el Empleo).

Modification procedure

Per Real Decreto 901/2020 Art. 8.2, this Plan may be modified as follows:

1. Any member of the Equality Commission may propose modifications in writing, specifying the reasons and the proposed changes
2. The Commission shall evaluate the proposal at its next ordinary meeting, or convene an extraordinary meeting if the matter is urgent
3. Modifications require agreement by both management and worker representatives within the Commission
4. Approved modifications shall be documented in writing, 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

LGTBI equality measures

Per Real Decreto 1026/2024 (effective 10 January 2025), the company implements the following measures for the equality and non-discrimination of LGTBI persons:

• Training and awareness actions on LGTBI diversity, integrated into the general equality training programme
• Use of inclusive language in all internal and external communications, avoiding assumptions about gender identity or sexual orientation
• Extension of all family-related benefits (parental leave, work-life balance measures) equally to diverse families
• Specific protections for trans workers, including respect for chosen name and gender identity in all internal systems and communications
• An anti-harassment protocol specifically addressing LGTBI-based harassment, integrated into the general anti-harassment protocol (Annex II)

REGCON registration

Per Real Decreto 901/2020 Art. 11, this 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 through the REGCON platform.

Diagnostic Assessment

Per Real Decreto 901/2020 Art. 7 and Art. 46.2 of Ley Orgánica 3/2007, the following diagnostic assessment has been conducted using data from FactorialHR, disaggregated by sex. The data reflects the workforce composition as of the date of this Plan's approval.

Workforce composition

	Women	Men	Total
Headcount	10	16	26
Percentage	38.5%	61.5%	100%

The overall gender ratio is 38.5% women / 61.5% men. While close to the general workforce balance, this indicates a moderate underrepresentation of women.

Distribution by professional group

Professional group	Women	Men	% Women
Management (JD-001, JD-002, JD-005, JD-007)	1	3	25%
Technical — Software & Data (JD-009, JD-010, JD-014, JD-017)	0	5	0%
Operations & Quality (JD-004, JD-006, JD-012, JD-023)	4	0	100%
Business & Commercial (JD-002, JD-016, JD-019, JD-022, JD-025, JD-027)	3	5	37.5%
Clinical & Research (JD-018)	0	1	0%
Pending assignment	2	2	50%

Key findings

• Technical roles (Data Science, ML Ops, Frontend Development) are 100% male — this is the most significant area of gender segregation
• Operations, Quality, HR, and Administrative roles are 100% female — inverse segregation
• Management positions (excluding JD-001 General Manager, held by a woman) are predominantly male
• Business and Commercial roles show a more balanced distribution (37.5% women)

Age distribution

Age range	Women	Men
25-29	1	3
30-34	4	6
35-39	3	2
40-44	1	1

Average age: Women 34.3 years, Men 31.9 years. The age distribution is broadly similar between sexes.

Seniority and tenure

Tenure range	Women	Men
< 1 year	3	3
1-2 years	5	5
2-3 years	1	4
3-5 years	1	0
5+ years	0	4

Average tenure: Women 1.7 years, Men 2.5 years. Men have significantly longer average tenure, primarily because the founders and early employees (all male) have been with the company since its incorporation.

Turnover analysis: Historical data shows a higher turnover rate among women than men. This pattern warrants further investigation to determine whether there are systemic factors contributing to female attrition.

Contract types

Contract type	Women	Men
Indefinido (permanent)	6	12
Pending formalisation	4	2

All active contracts with defined terms are permanent (indefinido). No active temporal contracts exist. All employees work 40 hours per week (full-time).

Compensation analysis

Pay by professional group

The following table expresses average female compensation as a ratio to average male compensation within the same professional group (1.00 = equal pay).

Professional group	Women : Men ratio	Sample
Management	1.14 : 1	n=1 women, n=3 men
Operations & Quality	—	No men in group
Business & Commercial	1.10 : 1	n=3 women, n=4 men
Technical — Software & Data	—	No women in group

note

A meaningful like-for-like pay gap analysis is not possible for most professional groups because there are no mixed-gender groups holding the same role. The only role with both men and women is JD-019 Business Development, where the difference reflects seniority rather than unequal pay.

The absence of a gender pay gap in comparable roles does not eliminate the risk of structural inequality — particularly the concentration of women in lower-paying administrative roles and their absence from higher-paying technical roles.

Overall compensation summary

Metric	Women : Men ratio
Mean salary	1.06 : 1
Median salary	1.08 : 1

Overall mean and median favour women.

Training

No formal training records exist in FactorialHR at the time of this diagnostic. Training tracking is managed through the QMS (GP-005 Human Resources and Training). No gender-disaggregated training data is available for analysis.

Improvement area: Progressively establish tracking of training hours and type disaggregated by sex.

Work-life balance

In the 2025-2026 period, 5 employees (both men and women) have taken parental leave, with an average duration of approximately 13 weeks. Both sexes have made use of parental leave entitlements, which is a positive indicator of co-responsibility. Male employees have taken substantial parental leave periods, suggesting the company culture supports this.

Diagnostic conclusions

1. Occupational segregation is the primary equality challenge: technical roles are exclusively male, while administrative/support roles are exclusively female
2. No gender pay gap exists for comparable roles — pay differences are driven by occupational segregation, not unequal treatment
3. Female turnover is significantly higher than male turnover — root causes should be investigated
4. Work-life balance measures are used equitably by both sexes
5. Training data is not tracked by sex — this gap should be addressed progressively
6. Female underrepresentation in technical roles and long-tenure positions is the most actionable finding

Areas of Action

Access to employment

Actions

• Implement measures to gradually increase the presence of women and/or men, on equal merit and conditions, in under-represented areas
• Use inclusive images and language in published job postings
• Ensure that job postings are equally accessible to men and women
• Maintain a register of candidates for selection processes
• Conduct internal audits annually of the selection system, using a form to be completed by both the evaluating personnel and the interviewee, for more efficient and objective auditing
• Verify the maintenance of a gender perspective in the personnel selection system, noting that equal opportunities cannot be to the detriment of the company's technical interests, needs, and strategies — equal opportunities are based on equal merit

Objectives

• Balance the workforce in masculinised or feminised departments or sections

Monitoring and evaluation mechanisms

• An annual report shall be submitted to the Equality Commission
• Identify the percentage of women and men who applied and met the profile requirements for each position, and cross-reference with those finally selected, to verify that no sex-based discrimination occurred
• Communication to the Equality Commission of job postings
• Communication to the Equality Commission of the men and women who applied, were selected, had contracts converted, as well as any incidents and solutions provided

Target personnel

Management and HR

Responsible personnel

Management and HR

Execution timeline

Throughout the validity of the Plan

Promotion

Actions

• Implement measures to gradually increase the presence of the under-represented gender in senior positions
• Use non-sexist language and images in promotion postings
• Update the internal promotion process procedure
• Verify the maintenance of a gender perspective in internal promotion processes
• Review internal promotion processes periodically to ensure equal access

Objectives

• Enable equal access to promotion opportunities for men and women
• Establish a system agreed with workers' representatives that guarantees equitable promotion and eliminates any discriminatory element
• Communication to the Equality Commission of job postings

Monitoring and evaluation mechanisms

• Annual compilation of internal promotion announcements and presentation to the Equality Commission
• Periodic review and preparation of pertinent reports

Target personnel

All staff. Management, HR, and the Equality Commission

Responsible personnel

Management and HR

Execution timeline

Throughout the validity of the Plan

Professional classification

Actions

• Design professional classification and promotions using neutral and objective criteria, eliminating any discrimination on the grounds of sex, age, marital status, or social circumstances
  • An annual report shall be established as a monitoring mechanism to define all content that the relevant documentation must contain
• Establish a joint communication and participation protocol with the Equality Commission
• Provide the results of personnel applying for professional reclassification processes, disaggregated by sex

Objectives

• Inform the Equality Commission of the results obtained and ensure that no sex-based discrimination occurs

Monitoring and evaluation mechanisms

• Annual report to the Equality Commission

Target personnel

Area managers and their direct reports

Responsible personnel

Area managers, Management, and HR

Execution timeline

Throughout the validity of the Plan

Compensation

Actions

• Prepare an annual pay study
• Maintain compliance with the applicable collective agreement, ensuring no differences exist between workers performing the same professional category or on the basis of gender

Objectives

• Guarantee that the company's pay system is not discriminatory on the grounds of sex
• Maintain equitable compensation practices within the company's objectives and possibilities

Monitoring and evaluation mechanisms

• The Equality Commission shall receive annually a pay study disaggregated by sex

Target personnel

All staff

Responsible personnel

Management and HR

Execution timeline

Throughout the validity of the Plan

Training

Actions

• Provide gender equality training courses to all company personnel, with emphasis on senior and middle management, as they are directly responsible for any action contrary to this Equality Plan
• Verify workforce satisfaction regarding training assignment criteria from a gender perspective
• To verify workforce satisfaction, an annual survey shall be established, useful for monitoring indicators and for correcting training planning in a timely manner
• Survey questions on training satisfaction must be drafted to allow assessment of training assignment criteria with a gender perspective

Objectives

• Raise awareness on equality among the personnel selection team
• Raise awareness among the workforce on equality, diversity, and harassment prevention
• Build capacity for resolving situations or conflicts related to gender equality

Monitoring and evaluation mechanisms

• Records of attendance signatures and certificates obtained
• Report issued by the training provider on the level of knowledge gained by participants

Target personnel

All staff

Responsible personnel

HR and Innovation Management

Execution timeline

Throughout the validity of the Plan

Work-life balance

Actions

• Include questions about work-life balance measures in workplace climate surveys, applicable to all personnel
• Establish a communication channel to inform about the employment rights established by current labour legislation for the reconciliation of family and working life, as well as any agreements the company may establish as improvements to said legislation
• Unpaid leave to accompany family members or dependants to medical appointments
• Paid leave to attend childbirth preparation classes
• Reserve of a pool of hours or holiday period for medical treatment or surgical intervention of a child
• One-month leave of absence with job reservation in the event of the death of a parent with children under 10 years of age

Objectives

• Assess the workforce's perception of existing work-life balance measures
• Effectively ensure that these rights are enjoyed by all workers
• Consolidate in a single document all work-life balance measures and social benefits existing in the company, as well as those mandated by law, to facilitate knowledge of the measures and encourage their use

Monitoring and evaluation mechanisms

• Results obtained from the survey on work-life balance questions and the actions implemented as a result
• Company communication channels to promote participation (internal newsletter, bulletin boards, intranet, cascade communication, etc.)
• Annual report to the Equality Commission on applications submitted, monitoring, and evaluation

Target personnel

All staff

Responsible personnel

Equality Commission

Execution timeline

Throughout the validity of the Plan

Communication and inclusive language

The company has maintained inclusive communication practices since its inception. The actions below reflect ongoing practices that are continuously maintained and improved.

Actions

• Maintain an internal communication channel ensuring immediacy between the Equality Commission and all personnel, guaranteeing communications on this matter through the designated email addresses
• Maintain protocols for handling complaints, grievances, or suggestions that guarantee the privacy of the interested party
• Include news related to equal opportunities in corporate social media profiles
• Include news related to the Equality Plan in the company's internal newsletter
• Communicate equality-related actions and developments to all staff
• Apply inclusive language practices in all types of communication, including collective figures (e.g., "the staff", "the team") or abstract references (e.g., "management", "the technical area"), while respecting grammatical gender usage as defined by the RAE

Objectives

• Publicise the company's equality policy to society at large
• Maintain effective internal communication, enabling responses to all issues raised by personnel

Monitoring and evaluation mechanisms

• Annual review of communication practices by the Equality Commission
• Communication content may be supported by paper (minutes, notices) or digital format (emails)

Target personnel

All staff

Responsible personnel

Business Development and Marketing and Communications area

Execution timeline

Ongoing since company inception

Workplace health

Actions

• Study to detect needs related to occupational risks and workplace health, without prejudice to the occupational risk prevention assessments carried out in parallel with this Plan
• Specific risk assessment during pregnancy and breastfeeding
• Continuous training on occupational risks and workplace health
• Review and update the anti-harassment protocol text and its effectiveness
• Develop an internal procedure for cases where gender-based violence is detected or reported, or for cases where a victim of gender-based violence is employed

Objectives

• Maintain a low rate of workplace accidents through effective preventive measures
• Update the anti-harassment protocol to introduce improvements
• Develop a procedure covering the actions to follow in cases of gender-based violence victims who are company employees
• Verify that any voluntary departures are not due to sex-based discrimination
• Promote a safe and healthy working environment

Monitoring and evaluation mechanisms

• Annual report to the Equality Commission on applications submitted
• Collaboration agreements with various labour intermediation entities
• All related information shall be made available through the communication channels established in the company

Target personnel

All staff. Victims of gender-based violence

Responsible personnel

• Equality Commission
• Occupational Risk Prevention Officer

Female underrepresentation

The company has been actively working to address female underrepresentation since its early stages, including targeted sourcing of female candidates for technical roles and inclusive job descriptions. The actions below reflect the continuation and formalisation of these ongoing efforts.

Actions

• Analyse the distribution of women and men across all professional groups and categories annually, using FactorialHR data
• When hiring for technical roles, consider female candidates through available channels, including women-in-tech networks and specialised job boards
• Support women's career development through mentorship and professional development opportunities where feasible
• Review job descriptions for technical roles to ensure they use inclusive language and do not include unnecessary requirements that may disproportionately discourage female applicants

Objectives

• Progressively improve the proportion of women in technical roles
• Reduce occupational segregation where possible, taking into account the available applicant pool
• Monitor female turnover trends and address any systemic factors identified

Monitoring and evaluation mechanisms

• Annual report to the Equality Commission on gender distribution across professional groups
• Annual comparison of female representation against the previous year

Target personnel

All staff

Responsible personnel

Management, HR, and the Equality Commission

Execution timeline

Ongoing since company inception

Conclusions

• Include a gender perspective in the recruitment, selection, and hiring phases
  • Use non-sexist language and images in access to employment within the company
  • Apply a gender perspective to professional classification
• Promote a balanced presence of women and men across all professional groups and categories
• Include a gender perspective in professional promotion
• Inform, raise awareness, and provide training on equality between women and men to all management, middle management, and staff
• Promote and encourage co-responsibility and facilitate the reconciliation of work, family, and personal life
• Prevent or, where necessary, eradicate sexual, workplace, or moral harassment on the grounds of sex, through the review and analysis of the company's occupational risk assessment procedures — without prejudice to the workplace risk assessments conducted in parallel with this Plan
• Foster the use of non-sexist language and imagery

The actions and objectives in these areas shall coexist in content and be updated alongside the Occupational Risk Prevention guidelines and any subsequent legal documents the company may prepare in parallel with this Plan.

Signatures

Management representatives and workers' representatives, as subscribing parties to this Plan, sign below to formalise their commitment to the implementation of the measures contained herein.

Management representatives

Andy Aguilar	Alba Santacreu
President	Secretary

Workers' representatives

Constanza Majdalani	Taig Mac Carthy
Workers' representative	Workers' representative