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Gender Equality

This Company Gender Equality Policy defines the principles, commitments, and operational guidelines adopted by the Company to ensure equal rights, equal opportunities, and equal economic and professional treatment for all individuals, in line with national and European regulatory frameworks on non-discrimination and equal opportunities.

The organization promotes women's empowerment, understood as strengthening the role, autonomy, and participation of women at all company levels, ensuring equal opportunities for growth, leadership, and professional recognition.

The Company's commitment is rooted in the principles of formal and substantive equality enshrined in Article 3 of the Constitution and the principle of equal rights and equal pay for equal work as per Article 37 of the Constitution. These principles are further reinforced by European Union law, which prohibits all forms of discrimination based on sex (Article 21 of the Charter of Fundamental Rights of the EU) and promotes equality between men and women in all areas, including employment and remuneration (Article 23 of the Charter; Article 157 TFEU).

The Company aligns its organization with the principles established by Directive 2006/54/EC on equal treatment in employment, Directive (EU) 2019/1158 on work-life balance for parents and caregivers, and Directive (EU) 2023/970 on pay transparency (currently being transposed), as well as the provisions of Legislative Decree 198/2006 (Code of Equal Opportunities between Men and Women), Legislative Decree 151/2001 on the protection of parenthood, and the general obligation to protect the physical and moral integrity of workers as per Article 2087 of the Civil Code.

Within this framework, this Policy is an integral part of the company's labor law compliance system and aims to prevent the risk of direct and indirect discrimination, harassment, and unequal treatment, as well as the risk of litigation and employer liability.

Scope of Application

The Policy applies to all Company personnel, as well as collaborators, suppliers, and partners who operate, for any reason, within the scope of the company's activities.

General Principles

The Company is committed to:

  • ensuring equal opportunities for employment, professional development, and economic treatment;
  • preventing and combating all forms of direct or indirect discrimination related to gender;
  • promoting a work environment that respects human dignity;
  • fostering a fair balance between professional and private life;
  • ensuring transparency, traceability, and verifiability of human resources decision-making processes.

Operational Guidelines

1. Recruitment, Selection, and Access to Employment

The Company adopts selection processes based on objective, transparent, and verifiable criteria, in accordance with Articles 25 et seq. of Legislative Decree 198/2006.
Operational Guidelines:

  • use of inclusive and neutral language in job advertisements;
  • prior definition of required professional qualifications;
  • traceability of selection phases and reasons for choices;
  • prohibition of questions or evaluations related to maternity, paternity, or family choices.

2. Job Classification, Career Development, and Leadership Roles

The Company promotes professional growth paths based on objective and measurable criteria to avoid indirect discriminatory effects.
Operational Guidelines:

  • formalization of performance evaluation criteria;
  • transparent and accessible promotion procedures;
  • skill development and talent enhancement programs;
  • periodic monitoring of gender representation in leadership roles.

3. Equal Pay and Pay Transparency

In implementation of Article 37 of the Constitution and Article 157 TFEU, the Company guarantees equal pay for equal work or work of equal value.
Operational Guidelines:

  • periodic pay audits;
  • job classification systems based on objective criteria;
  • identification and correction of any unjustified pay differentials;
  • progressive adaptation to transparency obligations provided by Directive (EU) 2023/970.

4. Work-Life Balance and Protection of Parenthood

The Company adopts work-life balance measures in accordance with Directive (EU) 2019/1158 and Legislative Decree 151/2001.
Operational Guidelines:

  • promotion, where compatible with work organization, of flexible working hours and smart working;
  • protection of professional continuity upon return from maternity and paternity leave;
  • promotion of parental leave usage by all genders;
  • prohibition of career penalties related to the exercise of work-life balance rights.

5. Prevention of Discrimination, Harassment, and Protection of Dignity

The Company adopts a zero-tolerance policy towards harassment and sexual harassment, qualified as forms of discrimination by Article 26 of Legislative Decree 198/2006, in implementation of the protection obligation referred to in Article 2087 of the Civil Code.
Operational Guidelines:

  • adoption of a Code of Conduct against harassment and discrimination;
  • establishment of confidential and protective reporting channels;
  • internal procedures for managing reports;
  • periodic staff training on topics of respect, equality, and unconscious bias.

Governance, Responsibility, and Monitoring

The Company identifies an internal function responsible for overseeing gender equality policies and monitoring the measures adopted.
The policies are subject to periodic review, also through reporting tools provided by current legislation, including the report on the situation of male and female personnel referred to in Article 46 of Legislative Decree 198/2006, where applicable.
In coherence with Law No. 162/2021, the Company evaluates the adoption of gender equality certification as a tool for continuous improvement and strengthening of its inclusion policies.

Update and Continuous Improvement

This Policy is subject to periodic review to ensure it is updated with regulatory developments, including the transposition of Directive (EU) 2023/970, and best practices in equal opportunities.

Conclusion

The Company Gender Equality Policy and its operational guidelines are an integral part of the Company's labor law risk management system and aim to ensure compliance with current legislation, protection of individuals' rights, and promotion of a fair, inclusive, and respectful work environment for everyone.