01 January 2023

  1. Purpose
  2. Scope of Application
  3. Main Principles of Conduct in connection with Equal Opportunity
  4. Main Principles of Conduct in connection with Diversity and the Promotion of Inclusion
  5. Instruments

The Board of Directors of NAC PRIVACY GLOBAL, GmbH (the “Company”) has the power to design, assess and continuously revise the Governance and Sustainability System, and specifically to approve and update the corporate policies, which contain the guidelines governing the conduct of the Company.

In fulfilling these responsibilities, aware of its commitment to the workforce as its main strategic asset and the key to its business success, and in accordance with the provisions of the People Management Policy, the Board of Directors hereby approves this Equality, Diversity and Inclusion Policy (the “Policy”).

  1. Purpose

This Policy seeks to create a good environment that facilitates and strengthens equal opportunity, non-discrimination, diversity and the inclusion of the professionals of the Company, thus adopting a people management model committed to professional excellence and quality of life, all in accordance with applicable law in each country and following best international practices, including the provisions of the Sustainable Development Goals (SDGs) approved by the United Nations (UN) in these areas.

Equal opportunity constitutes one of the basic pillars of professional progress, and the development thereof entails equitable treatment to promote the personal and professional progress of the workforce of the Company.

Diversity covers the set of characteristics that make people unique and singular, that is, the richness that each person contributes thanks to their variety, including visible and non-visible traits.

Inclusion, on the other hand, refers to how differences between individuals are valued and opportunities are generated so that everyone can realize their full potential. In other words, a conscious strategy that focuses on developing the structures, systems, processes and culture that generate respect for the individual characteristics of all people within the organization, while also promoting a sense of belonging that makes them feel valued and part of a group or community.

  1. Scope of Application

This Policy applies to the Company and all its members.

  1. Main Principles of Conduct in connection with Equal Opportunity

To achieve the aforementioned objectives and commitments in the area of equal opportunity, the following main principles of conduct that must govern the labor relations of the Company are adopted and promoted:

  1. Guarantee the quality of employment as a fundamental means to promote equal opportunity and non-discrimination, fostering the maintenance of stable and high-quality jobs, with fair salaries and occupational contents that guarantee a continuous improvement in the abilities and skills of professionals.
  2. Implement the principle of equal opportunity in the workplace, the observance of which is one of the basic pillars of professional development, and which entails the commitment to provide and show equitable treatment that promotes the personal and professional progress of the workforce of the Company in the following fields:
  • Promotion, professional development and remuneration: value such knowledge and skills as are required to perform a job, through the evaluation of goals and performance.

In particular, both when making individual proposals for goals and in the assessment of performance and of any salary increases, standards of equal opportunity, non-discrimination and respect for diversity shall be taken into account. Along these lines, equal treatment shall be promoted to encourage the personal and professional progress of the workforce of the Company in a way that recognizes the knowledge and skills required for each job, the contribution of professionals to the creation of value, as well as dedication and responsibility in the performance of their duties.

  • Selection: choose the best professionals by means of selection tools and systems based on the knowledge and abilities of the candidates.
  • Hiring: not establish discriminatory salary differences and ensure appropriate integration of professionals within the Company, workgroup and position.
  • Training: ensure the education and training of all professionals in the knowledge and skills required for the proper performance of their work.
  • Support for professionals with disabilities, promoting their effective employment.
  • Promotion of transparent communication, encouraging innovation and providing professionals the independence they need in the performance of their duties.
  • Elimination of any actions contrary to equal opportunity.
  1. Promote gender equality within the boundary of the Company, complying with applicable law in each country and following the best international practices, as well as the provisions in this regard of goal five of the Sustainable Development Goals (SDGs) approved by the United Nations (UN), particularly as regards access to employment, professional training and promotion, and working conditions, and for these purposes:
  • Reinforce the commitment of the Company to gender equality both within the organization and in society, and raise awareness on this topic in both spheres.
  • Guarantee the principle of equal opportunity in professional development, removing any obstacles that may hamper or limit a professional career by reason of gender.
  • Propose affirmative action measures to correct inequalities that appear and to promote access by the less represented gender to positions of responsibility in areas in which it is underrepresented or not present.
  • Strengthen mechanisms and procedures for selection and professional development that facilitate the presence of the less represented gender with the required qualifications in all areas of the organization in which it is underrepresented. This includes, among other things, through the implementation of specific training and professional development monitoring programs for women that promote the Company having a significant number of female senior managers.
  • Strive to achieve a balanced representation within the various decision-making bodies and levels, guaranteeing participation in all consultative and decision-making areas of the Company on the basis of equal opportunity.
  • Promote the organization of working conditions with a gender perspective, allowing for the reconciliation between personal and working life of all professionals employed by the Company to favor gender equality, ensuring the elimination of all gender-based discrimination;
  • Protect pregnancy, childbirth, and post-delivery as specific situations of the female professional group, avoiding negative repercussions thereof on their professional career.
  • Protect pre-adoption and adoption, avoiding negative repercussions thereof on their professional career.
  • Promote programs of collaboration with educational institutions to encourage the presence of the less represented gender in careers and training programs relating to the businesses carried out by the Company in which the presence of one of the genders is substantially lower than that of the other; and
  • Collaborate in the fight against gender violence through the establishment of specific programs that include measures of protection, support and information, in order to accompany and protect the victims of gender violence.
  1. Standardize working conditions and the benefits received by part-time and full-time professionals.
  2. In the establishment of working conditions, respect the principle of equal working conditions for jobs that involve the same demands and have the same value.
  3. Exclude prejudices that may exist with respect to persons whose social, cultural or educational status does not correspond to models traditionally considered to be standard or customary, and which may unduly inhibit professional progress based on the merit and ability of people.

  4. Main Principles of Conduct in connection with Diversity and the Promotion of Inclusion

To achieve the aforesaid objectives and commitments relating to diversity and the promotion of inclusion, the following main principles of conduct that must govern the Company’s labor relations are adopted and promoted at the Company level:

  1. Ensure non-discrimination among its professionals and positioning against any conduct or practice associated with prejudice on grounds of nationality, ethnic origin, skin color, marital status, family responsibilities, religion, age, disability, social status, health, gender, sexual orientation, gender identity and expression, or any other condition or characteristic of a person that is not related to the requirements to perform their job.
  2. Promote the contribution of the knowledge, experiences and abilities of all professionals of the Company, regardless of any personal or social conditions or circumstances.
  3. Foster a sense of inclusion within the Company that seeks to ensure that all professionals are considered part of the business enterprise and of its role in the local, national and international community. It is thus sought that the Company’s values, principles and objectives are assumed as their own by the workforce of the Company and that their contribution to them is perceived as an essential component of not only professional but also personal development.
  4. Recognize the coexistence of different generations as a source of continuous enrichment, due to their diverse skills and approaches, for both professionals and for the various businesses and corporate areas, and as a decisive contribution to the adaptation of the services provided by the Company to the needs of the communities in which it does business.
  5. Take into consideration that certain physical or intellectual disabilities that might be an obstacle for performing some tasks in fact represent significant added value in other duties. In any case, not identify such circumstances in advance and without justification as obstacles to proper integration in the workplace.
  6. Recognize that the international character of the Company and the contribution made thereto by people of different origins, races or ethnicities represents a permanent and decisive source of enrichment at the Company level, which is preserved and encouraged.
  7. Promote information and communication with the various communities in which the Company does business so that it is thought of as an ideal place for professional development of the various groups of which they are comprised from the viewpoint of their commitment to diversity and inclusion.
  8. Ensure that selection and hiring processes are based on neutral and objective standards of merit and ability, while establishing specific actions to promote the inclusion of groups with less easy access to the labor market.
  9. Address with due measures of integration, among others, the situations of single, married, domestically partnered, divorced, separated, widowed and plurally cohabiting persons, with or without children, and with other particular family and emotional circumstances, including the specific bond arising with animal companions, as living sentient beings.
  10. Ensure that decisions on professional promotion and professional development are based on equitable criteria, eliminating from all business decisions in this regard reasons, grounds or consequences detrimental to diversity, promoting the proper inclusion of all groups of professionals.
  11. Ensure that, in the training of each professional, regardless of the group to which the professional belongs, the professional is provided with sufficient knowledge, aptitudes and skills for the appropriate performance of the professional’s work, while providing for specific actions in such training from the perspective of accepting diversity and rejecting discrimination.
  12. Encourage the use of inclusive language in all types of internal and external corporate communications, and in any case eradicate the use of discriminatory language.
  13. Maintain an environment that is free from workplace violence, intimidation and harassment in all its forms, including sexual and gender-based harassment, ensuring the establishment of agile and effective reporting channels and attention to alleged victims.
  14. Constantly develop awareness-raising policies for the professionals within the Company, especially those with management responsibilities, so that they value and promote the contribution that diversity represents for the Company.
  15. Include within leadership programs behaviors that encourage better decision-making and a diversity-based culture, as well as an internal communications strategy that can convey plurality and inclusiveness.
  16. Facilitate internal mobility and interaction within the organization to create networks of contacts and teams that take advantage of multiculturalism, and constantly monitor and update management processes and procedures so that contacts and teamwork enhancing diversity and inclusion take place.
  17. In line with the Policy on Respect for Human Rights, guarantee the internationally established rights of freedom of association in order to preserve the choice of each person in their relationship with trade unions and the conduct of these organizations in the defense of their legitimate interests.
  18. Endeavour to ensure that the design of the processes in which artificial intelligence is used, and especially the algorithms used, do not suffer from biases that violate Company´s objectives and commitments regarding diversity and the promotion of diversity due to their design or the actual results of their implementation, or prevent the verification thereof due to limitations on transparency or tracking of results.
  1. Instruments

In order to achieve the objectives, set out in this Policy, the Company is responsible for implementing, monitoring and verifying compliance with this Policy.