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NATEK DIVERSITY, EQUITY AND INCLUSION POLICY

PREAMBLE

Being present in 4 countries: Slovakia, Czech Republic, Bulgaria and Poland, with several branches, NATEK Group has been international and multicultural since first employee hired. At NATEK, we are committed to fostering a workplace that thrives on diversity, ensures equity and cultivates inclusion. Driven by values of Accountability, Partnership and Expertise, NATEK created and is constantly working on fostering diverse, inclusive and equal working environment.

1 SCOPE OF APPLICATION

This Policy applies to NATEK Group, ensuring that diversity, equity and inclusion are integral part of NATEK binding for every Staff member.

2 PURPOSE

The purpose of this Policy is to reflect NATEK commitment to create corporate culture where every individual feels valued, respected and empowered. We believe that embracing diversity and fostering equity and inclusion are essential to ensure operational efficiency and drive innovation, collaboration and growth. By committing to these principles, we aim to build a workplace culture that:

  • reflects the diverse communities we serve and those we create,
  • supports beyond the human rights, a well-being of all Staff Members,
  • aligns with our core values of partnership, accountability and expertise.

3 RESPONSIBILITY

This Policy applies to Staff Members on NATEK group level as well as NATEK as company, together with its Management Board and suppliers. Diversity, Equity and Inclusion is a collective responsibility. Everyone must work together to create and maintain an inclusive and equitable environment. Timely reporting and addressing of incidents not only resolve immediate issues but also strengthen the culture of respect and accountability across the organization.

4 DEFINITIONS

NATEK Group – a group of affiliated companies operating in CEE countries controlled by JJMLE Holdings s.r.o., acting under business name of "NATEK".

Staff Member - human resource performing for NATEK business goal (Employee, Intern, Contractor, Supplier) under a condition of valid contract or purchase order based on labour, civil or commercial code, assigned under any of NATEK legal entity, business line, business unit, type of service or function following company organizational chart.

Staff Group – any group Staff Member belongs based on type of contract (Consultant, Contractor) or department (Internal Staff) or any other classification in the company organizational structure.

5 DIVERSITY, EQUITY AND INCLUSION (DEI)

Diversity refers to the variety of identities, backgrounds and perspectives that individuals bring to an organization. It includes differences in race, gender, age, sexual orientation, abilities, socioeconomic status and more. Embracing diversity means valuing these differences as sources of strength and innovation. Inclusive and equal workplace is being part of NATEK DNA.

Inclusion is about creating an environment where everyone feels valued, respected and able to contribute. It ensures diverse voices are heard and integrated, fostering a sense of belonging and collaboration. NATEK continuously ensures to serve its Staff Members as much as to our clients. Equity ensures equal and fair treatment, access, and opportunities for all by addressing barriers and disparities. It recognizes that people have different needs and seeks to provide tailored support to help everyone succeed.

NATEK's DEI culture is observable on multiple layers and measures such as Staff Members age (age range starts from 19+ years), involvement of women on managerial positions with minimum of 50%. NATEK undertakes actions such as participation in events or conducting supportive programs dedicated to minority groups. Growing to 800+ Staff Members representing 21+ nationalities over decades in DEI has always been integral part of NATEK.

DEI principles are fundamental to our mission of empowering individuals to deliver high-quality services. We believe that by embracing our Staff Members, we strengthen our ability to serve our clients and achieve sustainable growth within great working culture. We are cultivating NATEK working culture to be non-discriminatory and free of any violence and harassment.

Discrimination refers to the unjust or prejudicial treatment of individuals or groups based on certain characteristics, known as "protected characteristics", in particular on the grounds of gender, age, disability, race, religion, nationality, political views, trade union membership, ethnic origin, belief, sexual orientation, as well as due to fixed-term or open-ended employment, or full-time or part-time work. Discrimination can take various types, which none of them is acceptable for NATEK:

  • Racial and National Discrimination - means treating someone unfavourably or unfairly because of their race, ethnicity, skin colour, cultural background or country of origin.
  • Gender and Gender Identity Discrimination - treating someone unfairly based on their gender, or gender expression. This can include discrimination against women, men, or individuals who identify as non-binary, transgender or who do not align with the sex they were assigned at birth.
  • Sexual Discrimination – is based on whether someone identifies as LGBTQIA+. 'LGBTIQA+' is an evolving acronym that stands for lesbian, gay, bisexual, transgender, queer/questioning, intersex, asexual and other terms (such as non-binary and pansexual) that people use to describe their experiences of their gender, sexuality and physiological sex characteristics.
  • Religious Discrimination – is treating someone unfairly due to their religious beliefs or practices, or lack of belief.
  • Age Discrimination – is treating someone unfavourably or unfairly based on their age.
  • Physical Appearance Discrimination – is discrimination against individuals due to body size, height, skin tone, or facial feature, or other physical traits.
  • Disability Discrimination – is treating someone unfairly due to their disability.
  • Pregnancy or Parental Status discrimination – is treating someone unfairly because they are pregnant, on parental leave, or have caregiving responsibilities.
  • Marital or Civil Partnership Status discrimination - favouring or excluding individuals based on whether they are single, married, divorced, or in a civil partnership.
      • Discrimination Based on Work-Related Factors
      • Employment Type: Treating part-time, temporary, or freelance employees differently than full-time employees.
      • Socioeconomic Background: Judging employees based on their education, upbringing, or financial background.

NATEK commits to zero tolerance to any forms of violence and harassment. In the context of the workplace, the phrases violence and harassment encompass a variety of inappropriate actions, behaviours, or threats, whether occurring once or repeatedly. These actions are intended to cause, or are likely to cause, harm of a physical, psychological, sexual, or economic nature. This definition also encompasses acts of gender-based violence and harassment as well as any nature of discrimination showed off in behaviours or by failure of act. Violence and harassment can also take subtle forms, such as exclusion, undermining, or spreading malicious rumours, which contribute to a hostile work environment.

Harassment refers to any unwanted behaviour, conduct, or communication that creates an intimidating, hostile, or offensive environment for an individual or group of individuals. It is typically repetitive in nature and is often directed at someone based on their race, colour, religion, sex, national origin, age, disability, sexual orientation, gender identity, or other protected characteristics. Harassment can manifest in various forms, including but not limited to verbal abuse, discriminatory jokes or comments, exclusion, threats, or physical intimidation.

Sexual harassment is defined as unwelcomed sexual advances, requests for sexual favours and other verbal or physical conduct of a sexual nature. Sexual harassment may include a range of subtle and not-so-subtle behaviours and may involve individuals of the same or different gender or using a position of power to exploit others sexually. Depending on the circumstances, these behaviours may include unwanted sexual advances or requests for sexual favours, sexual jokes, verbal abuse of a sexual nature, commentary about an individual's body and other physical, verbal, or visual conduct of a sexual nature.

NATEK protects its Staff Members against suffering from violence and harassment and ensures its community does not tolerate any violence that is considered to be any act of aggression or harm and covers a broad range of unacceptable actions and its types, in particular:

  • Physical Violence - any act of physical aggression or harm such as pushing, slapping, hitting, kicking, threatening gestures etc.;
  • Psychological Violence - included bullying, mobbing in the form of yelling, humiliating, insulting and threatening, isolating, excluding, marginalizing subordinate or colleague;
  • Verbal and Emotional Violence - aggressive or hostile verbal behaviour, such as shouting, yelling, or making threatening comments. Intimidation through abusive language, insults, or demeaning remarks. Emotional abuse, such as constant humiliation or manipulation;
  • Cyber Violence - threatening or abusive behaviours conducted through electronic means, such as emails, social media, or text messages. Cyberbullying, online hate speech or spreading harmful content about an individual or group of individuals online;
  • Workplace Domestic Violence - instances where domestic violence spills over into the workplace, leading to threatening, intimidating, or harmful behaviour directed at a Staff Member by an intimate partner or family member;
  • Economic Violence – behaviours that control a person's or company ability to acquire, use or maintain economic recourses, threatening their economic security and potential self-efficiency. It may consist of destroying things, breaking into a closed personal room, stealing, using things without permission, unauthorised handling and viewing documents or correspondence etc.

The current laws, within each country of NATEK Group presence, regarding violence, harassment and discrimination at work differ based on their respective regulatory frameworks. The terminology used varies across jurisdictions, which reflects unique national circumstances and practices. For the sake of order necessary for cultivating working culture based on DEI as well as implementation of this Policy, NATEK is implementing reasonable and general definitions of all these terms. The specific legal definitions may vary, but all forms of violence and harassment should be considered unacceptable and are prohibited by this Policy.

In the cases recognised as breach of this Policy rules under violence, harassment and discrimination at work, NATEK may refer on top to the definitions based in Policy to other, more appropriate legal terms.

6 NATEK DIVERSE, EQUITABLE AND INCLUSIVE COMPANY CULTURE RULES

NATEK Group commits to provide workplace that thrives on diversity, ensures equity and cultivates inclusion. These all are constituting equal treatment, that in frame of applicable laws and highest ethics is our utmost priority.

At NATEK Group all Staff Members are obliged to take care of diversity, equity and inclusion as well as cultivate such working environment.

Staff Members should be treated equally within its groups, in particular regarding:

  • entering into and terminating the employment/contractual relationship,
  • employment conditions,
  • promotions,
  • access to training aimed at enhancing professional qualifications,

in particular irrespective of gender, age, disability, race, religion, nationality, political views, trade union membership, ethnic origin, belief, sexual orientation, as well as regardless of fixed-term or open-ended employment, or full-time or part-time work.

Equal treatment shall mean non-discrimination in any way, directly or indirectly.

Direct discrimination occurs when Staff Member was, is, or could be treated in comparable situation for one or several characteristics less favourably than other Staff Member in group.

Indirect discrimination occurs when an apparently neutral provision, criterion or measure bring about disproportion with regard to the employment or contractual conditions that would disadvantage all or considerable number of Staff Members from one contractual group belonging to the group differentiated on one or several characteristics, unless the disproportion can be objectively justified by a legitimate aim.

Discrimination manifests itself within the meaning of this section also in:

  • the action consisting in encouraging another person to infringe the principle of equal treatment
  • the behaviour, the purpose or consequence of which is the violation of the dignity or the humiliation or abasement of the Staff Member (violence or harassment).

Discrimination also includes any unacceptable behaviour of a sexual nature or referring to the gender of a Staff Member, the purpose or consequence of which is the violation of the dignity, the humiliation or abasement of Staff Member; such behaviour can comprise physical, verbal or non-verbal elements (sexual harassment).

The infringement of the principle of equal treatment shall be deemed treating a Staff Member differently by an employer for one or several reasons, such as gender, age, disability, race, religion, nationality, political views, trade union membership, ethnic origin, belief, sexual orientation as well as due to fixed-term or indefinite employment, or full-time or part-time work, the consequence of which is in particular:

  • the refusal to enter into or terminate the employment or contractual relationship,
  • setting unfavourable remuneration schemes or other employment or contractual conditions or omission from promotion or granting benefits related to work,
  • omission from selection of the participants in trainings enhancing professional qualifications,

unless the employer's action was based on legitimate reasons or in relation to rights and obligations as resulted from Staff Member contract type (employment contract, contract agreement etc).

The principles of equal treatment shall not by violated by the actions consisting in standard actions in frame of employment/contract agreement and in:

  • not hiring an employee or engaging contractor on one or several characteristics provided that it can be justified by the type of work, working conditions or professional qualifications required from the Staff Members,
  • terminating the employment or contractual conditions regarding working hours, provided that it is justified by the reasons not referring to the Staff Members,
  • taking measures that differentiate the legal situation of a Staff Member due to the protection of parenthood, age or a Staff Member's disability,
  • setting the conditions of employment and dismissal of the employees, rules of remuneration and promotion as well as access to training aimed at enhancing professional qualifications – taking into account the criterion of seniority.

The actions undertaken for a definite period that are aimed at equalizing the chances of all or considerable number of Staff Members differentiated on one or more characteristics through reducing for the benefit of such Staff Members actual inequalities within the scope defined in this provision of time do not constitute the infringement of the principle of equal treatment.

Differentiation of the Staff Members on the grounds of their religion or belief shall not constitute the violation of the principle of the equal treatment in employment, if in connection with the type or character of the activity run within churches or other belief groups, as well as organisations whose purpose remains directly related to religion or belief, religion or belief makes relevant, justified and fair professional requirement.

Any violence or harassment shall be inadmissible and shall be subject to disciplinary, criminal or civil liability.

Any discrimination in employment or any other direct or indirect discrimination shall be inadmissible and shall be subject to disciplinary, criminal or civil liability.

7 INCIDENT MANAGEMENT PROCESS

7.1 Reporting process

All Staff Members who believe they have been victims of conduct described in this Policy, or who have witnessed such conduct, are required to report their concerns to their direct manager, indirect manager, or a representative of the Human Resources Department.

Whenever possible, individuals who believe they are experiencing inappropriate conduct should immediately inform the offender that the behaviour is unwelcome and request that it cease. This action alone may often resolve the issue.

Staff Members are also required to promptly report any incidents of discrimination, harassment, or retaliation, regardless of the offender's identity or position. Such reports should be made to their immediate supervisor or a representative of the Human Resources Department.

Managers and supervisors are obligated to report any complaints they receive or any harassment they witness to the Human Resources Department. Early reporting and intervention are crucial for resolving actual or perceived incidents of harassment effectively.

Such report can be made verbally or in written, anonymously or not, whatever the reporter finds more appropriate against implementation of rules under this Policy. HR Department will immediately apply internal investigation and solving process.

7.2 Investigation and solving process

Investigation process is responsibility of Human Resources Department. HR Representative responsible for handling the report or complaint never has direct involvement in the case.

In case report is being made directly on Chief of People and Culture, Chief of Legal and General Investment is overtaking such report immediately.

HR Representative managing the report of workplace incident possess the appropriate training and expertise to fulfil their duties. They exercise the required level of discretion to protect the dignity and confidentiality of the parties involved, without obstructing the investigation process. Maintaining fairness towards all parties is crucial, and individuals should receive unbiased treatment throughout the process.

Any reported allegations of harassment, discrimination or retaliation will be investigated promptly, thoroughly, and impartially. The investigation may include individual interviews with the parties involved and, where necessary, with individuals who may have observed the alleged conduct.

As the result of the investigation of workplace incident, NATEK is undertaking:

  • clarification of the situation and its appropriate classification
  • follow up actions with action plan adjusted to the type of misconduct, if confirmed,
  • actions and sanctions that are disciplinary, criminal or civil liability,
  • preventive measurements aimed at limiting probability of misconduct reoccurring in future,
  • supportive actions offering medical or counselling support and care, paid or unpaid leave, education and any other necessary actions,
  • continuous education and awareness initiatives, ensuring that Staff Members have tools and knowledge to understand and embody diversity, equity and inclusion principles as well as their role in shaping and cultivating NATEK working culture

8 PROTECTION AGAINST RETALIATION

One of the primary reasons why a victim hesitates to report instances of discrimination, violence and harassment is due to the fear of facing retaliation. It is imperative for NATEK to guarantee that victims or reporters do not suffer further harm or punishment, and to shield them, along with witnesses, from potential backlash. This involves maintaining the confidentiality of the complainant's identity and whole investigation process.

The Staff Member's submission to harassment or sexual harassment as well as actions taken by him/her against any harassment or sexual harassment must not cause any negative consequences to the Staff Member.

Staff Member's exercise of rights due to violation of the principle of equal treatment cannot be the basis of unfavourable treatment of the Staff Member and cannot cause any negative consequences towards the Staff Member, especially cannot be the reason justifying termination of contract by or its termination without notice. The above principle applies accordingly to a Staff Member who has provided support in any form to a Staff Member who exercises the rights due to violation of the principle of equal treatment.

9 FINAL CONCLUSIONS

Policy is the responsibility of HR Department.

NATEK Management Board is empowered to update/cancel this Policy at any time and for any reason.

All Staff Members are expected to uphold and respect the principles outlined in this Diversity, Equity, and Inclusion (DEI) policy. Compliance with the policy is essential, as it reflects our shared commitment to building a positive and collaborative environment.

Failure to comply with the rules outlined in this Policy will be considered a breach of work discipline and may lead to disciplinary actions, up to and including termination of employment or contract, in accordance with company procedures.

Familiarization of the document is set up as NATEK standard – any change of the Policy is announced to all Staff Members in the manner adopted by NATEK; current version is available on NATEK DMS (Sharepoint), it is responsibility of every Staff Member to check and abide the current version.

Current version cancels and replaces all previous versions of the policy and is available on NATEK DMS.

Policy is effective the date of the first version is issued. When a new version is issued, terms andand conditions of the previous version are no more applicable.