1 PURPOSE AND MANAGEMENT COMMITMENT
This Gender Equality Plan (GEP) defines the commitments, governance, objectives, actions, indicators and review mechanisms through which Kolibree-Tech s.r.l.s promotes gender equality, non-discrimination, inclusion and a respectful working environment. The Plan covers the period 2026-2028 and is intended to support the Company in European tenders, grants, research, innovation and partnership activities where a formal GEP or equivalent equality strategy is requested or evaluated.
Kolibree-Tech adopts this Plan as a management policy and a practical implementation tool. It is aligned with the Company Code of Conduct and Human Rights Policy, which already commit the Company to respect internationally recognised human rights, prevent discrimination and harassment, promote a safe work environment, support flexible work styles and provide training and development opportunities.
Top Management is responsible for approving this Plan, allocating appropriate resources and ensuring that its objectives are integrated into relevant business processes. Managers and employees are expected to act consistently with this Plan and to raise concerns promptly through the available reporting channels.
This Gender Equality Plan is publicly accessible on the Company website. Evidence of management approval, controlled revisions and internal communication is retained in the Company’s document-control records.
2 SCOPE
This Plan applies to all Kolibree-Tech activities, including recruitment, contracting, onboarding, working conditions, career and skills development, project staffing, leadership, decision-making, communication, procurement, stakeholder engagement and technology or innovation activities where sex and/or gender may be relevant to users, customers, workers or communities.
- All officers and employees, including fixed-term, part-time and contract employees.
- Consultants, interns, trainees, temporary workers and collaborators when acting for or with the Company.
- Managers, project leaders and decision-makers involved in recruitment, evaluation, task assignment, promotion, remuneration and project governance.
- Business partners and suppliers, to the extent relevant to their relationship with Kolibree-Tech and consistent with contractual arrangements.
- External stakeholders in European projects, consortia, public tenders and procurement activities.
Where a measure must be adapted to the size of the Company or to privacy requirements, Kolibree-Tech will apply it proportionately while maintaining the purpose of the measure and retaining adequate evidence of implementation.
3 POLICY FRAMEWORK AND ALIGNMENT
This GEP forms part of the Company management system and complements the Code of Conduct, Human Rights Policy and applicable employment, privacy, health and safety and anti-discrimination rules. Kolibree-Tech adopts a voluntary Confidential Ethics Reporting & Grievance Mechanism under the Code of Conduct; this mechanism is distinct from the statutory whistleblowing channel regulated by D.Lgs. 24/2023. The Plan translates commitments to dignity, equal opportunities, safe conditions and continuous improvement into gender-equality measures.
For European project and tender purposes, the Plan is structured to cover the four mandatory process-related building blocks generally required for Gender Equality Plans in Horizon Europe and to address the five recommended thematic areas for research and innovation organisations: work-life balance and organisational culture; gender balance in leadership and decision-making; recruitment and career progression; integration of the gender dimension in research and innovation content; and measures against gender-based violence, including sexual harassment.
| Source / requirement | How this GEP addresses it |
|---|---|
| Company Code of Conduct | Integrates the commitments to human rights, non-discrimination, flexible work styles, health and safety, education, supplier responsibility and reporting of non-compliance. |
| Company Human Rights Policy | Reflects the commitments to prohibit discrimination and harassment, provide safe working conditions, implement governance and due diligence, operate grievance mechanisms and protect whistleblowers from retaliation. |
| European GEP process requirements | Includes public document statement, dedicated resources, data collection and monitoring, annual reporting, training and capacity-building actions. |
| European GEP thematic areas | Includes specific objectives and actions on work-life balance, leadership, recruitment and progression, gender dimension in innovation, and prevention of gender-based violence and sexual harassment. |
| Data protection and confidentiality | Requires aggregated reporting, confidentiality of individual cases and privacy safeguards when processing sensitive or small-number data. |
4 PRINCIPLES AND DEFINITIONS
Kolibree-Tech applies this Plan according to the following principles:
- Equal dignity and respect: every person must be treated with dignity and without discrimination.
- Equal opportunity: access to work, projects, training, career development, leadership and remuneration must be based on objective and transparent criteria.
- Intersectionality: gender equality measures should consider how gender may interact with age, disability, race or ethnic origin, nationality, religion or belief, sexual orientation, family status, health conditions or other protected characteristics.
- Evidence-based improvement: actions are informed by data, feedback, indicators, annual monitoring and corrective actions.
- Confidentiality and non-retaliation: concerns are handled confidentially and no one may suffer retaliation for reporting in good faith or participating in an investigation.
- Proportionality for SMEs: measures are implemented in a way that is practical for a small organisation, while still ensuring meaningful governance, resources, monitoring and accountability.
| Term | Definition for the purpose of this Plan |
|---|---|
| Sex | Biological characteristics that may be relevant in occupational health and safety, human-related testing, research, data analysis or product/service impacts. |
| Gender | Socially constructed roles, norms, behaviours, expectations, identities and relationships that may influence opportunities, participation, needs and impacts. |
| Gender equality | Equal rights, responsibilities, opportunities and treatment for all persons regardless of gender, including women, men and gender-diverse persons. |
| Gender balance | Balanced representation of genders in teams, leadership, decision-making, recruitment shortlists, panels and project roles, where feasible and consistent with merit-based selection. |
| Gender dimension | The integration of sex and/or gender analysis into research, innovation, design, data, testing, user requirements and impact assessment when relevant. |
| Harassment | Unwanted conduct related to gender or another protected characteristic that has the purpose or effect of violating a person’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment. |
| Sexual harassment | Any form of unwanted verbal, non-verbal or physical conduct of a sexual nature with the purpose or effect described above. |
| Gender-based violence | Violence or harmful conduct directed against a person because of gender, gender identity or perceived gender, or that disproportionately affects persons of a particular gender. |
5 GOVERNANCE, ROLES AND RESPONSIBILITIES
Gender equality is governed through the Company management system. Top Management retains final accountability. The GEP Coordinator supports implementation, monitoring and reporting. Managers and project leaders are responsible for applying the Plan in everyday decisions, project planning, recruitment, procurement and team management.
| Role | Responsibilities |
|---|---|
| Top Management | Approves the GEP; ensures publication and internal communication; assigns the GEP Coordinator; provides resources; reviews the annual report; decides corrective and improvement actions. |
| GEP Coordinator | Coordinates implementation; maintains the action plan and evidence register; supports data collection; organises training; prepares the annual GEP report; receives or supports handling of concerns where appropriate. |
| HR / Administration or delegated function | Supports recruitment, onboarding, training records, contract information, working-time and leave data, privacy safeguards and documentation. |
| Managers / Project Leaders | Apply transparent criteria in task assignment and leadership; consider gender balance in teams; integrate gender dimension screening in innovation activities; prevent and address inappropriate conduct. |
| Employees and collaborators | Respect the Plan, the Code of Conduct and the Human Rights Policy; participate in training; contribute to an inclusive workplace; report concerns or suspected violations promptly. |
| Suppliers and partners | Are expected to respect non-discrimination, harassment prevention and human rights principles in the context of their collaboration with Kolibree-Tech. |
5.1 Resources and expertise
Kolibree-Tech commits to provide appropriate resources for the implementation of this Plan. Resources may include working time of the GEP Coordinator and management, administrative support, access to gender equality guidance, training materials, external expertise when needed, and time for employees to attend training or provide feedback.
- At least one appointed person or function coordinates the GEP.
- The GEP Coordinator has access to Top Management for escalation, resources and decision-making.
- Training time is considered working time where feasible and relevant.
- External experts may be consulted for complex cases, annual review, legal updates, sensitive investigations or gender analysis in technical projects.
- Budget and time allocation are reviewed annually in proportion to the size, risks and project portfolio of the Company.
6 GEP BUILDING BLOCKS
This section sets out the minimum process elements of the Plan and the related internal controls used to demonstrate implementation to contracting authorities, project partners and auditors.
| Building block | Kolibree-Tech commitment | Evidence retained |
|---|---|---|
| Public document | The approved GEP is published as a version-controlled HTML policy and communicated internally. | Public policy URL, captured publication/version record, internal approval and communication evidence. |
| Dedicated resources | Top Management appoints responsible roles and provides time, expertise and support proportionate to the Company size and risks. | Appointment/email; role description; meeting minutes; training budget or time allocation. |
| Data collection and monitoring | The Company collects and reviews gender-disaggregated data and qualitative feedback annually, applying confidentiality safeguards for small numbers. | Annual dashboard; anonymised analysis; management review minutes; improvement actions. |
| Training and capacity building | The Company provides awareness raising and training on gender equality, bias, harassment prevention, reporting channels and gender dimension in innovation where relevant. | Training plan; materials; attendance records; onboarding evidence. |
6.1 Public document and communication
The approved GEP shall be published on the Kolibree-Tech website or otherwise made available to relevant contracting authorities, European project partners and stakeholders. The document must be communicated internally, for example through email, internal meetings, onboarding materials or the Company document repository.
The public version may omit personal contact details or sensitive internal information, but it must preserve the commitments, objectives, measures, responsibilities and monitoring principles of this Plan.
6.2 Dedicated resources
Resources are assigned according to the principle of proportionality. In a small organisation, resources may consist of formally allocated management time, GEP coordination time, access to external expertise, training time and documented management review. Where a European project requires additional gender expertise, the relevant project budget should include appropriate resources.
6.3 Data collection, monitoring and reporting
Kolibree-Tech will prepare an annual GEP monitoring dashboard using gender-disaggregated data on personnel and relevant organisational processes. Where numbers are small and individual identification may be possible, data shall be aggregated, suppressed or reported qualitatively.
- Data are collected only for legitimate equality monitoring and management improvement purposes.
- Individual-level data are handled confidentially and access is limited to authorised persons.
- Indicators are reviewed annually by Top Management and used to set corrective or improvement actions.
- The annual report may be shared externally in summary form when required by a tender, grant or partner request.
6.4 Training and capacity building
The GEP includes awareness raising and training actions for the organisation. Training is adapted to roles and may be delivered through internal briefings, e-learning, external webinars, project kick-off sessions or documented toolbox talks.
| Audience | Minimum content | Frequency / trigger | Evidence |
|---|---|---|---|
| All personnel | GEP principles, non-discrimination, respectful conduct, reporting channels, non-retaliation. | At onboarding and at least annually. | Attendance register, onboarding checklist, training material. |
| Managers and decision-makers | Unconscious bias, objective criteria, inclusive leadership, fair recruitment, task assignment and evaluation. | Annual or upon role assignment. | Training record, meeting minutes. |
| Recruitment / HR / Administration | Inclusive job adverts, structured interviews, data collection, privacy safeguards, equal treatment documentation. | Before recruitment campaigns and at least every two years. | Recruitment templates, checklist. |
| Project and technical teams | Gender dimension screening, inclusive design, data bias, user impact, testing and communication. | At project proposal or project kick-off when relevant. | Project gender screening checklist, project minutes. |
| Suppliers / partners where relevant | Code of Conduct expectations, non-discrimination and harassment-free collaboration. | At contracting, project onboarding or supplier review. | Contract clauses, supplier communication. |
7 BASELINE ASSESSMENT AND INDICATORS
The annual baseline assessment is used to identify priorities, monitor progress and provide evidence of GEP implementation. For the first reporting cycle, the baseline shall be completed using the most recent available data after adoption of this Plan. The internal annual GEP monitoring dashboard will be used as the reporting template.
| Area | Indicator | Data source | Frequency | Privacy note |
|---|---|---|---|---|
| Workforce composition | Headcount by gender, contract type, role family and seniority/project responsibility. | HR/admin records. | Annual. | Aggregate categories where fewer than 5 persons may be identifiable. |
| Recruitment | Applications, interview shortlists, offers and hires by gender where data is available and lawful. | Recruitment files. | Per campaign and annual. | Use voluntary data and aggregated reporting. |
| Career progression | Training participation, certifications, mentoring, role changes, salary review outcomes and project lead assignments by gender. | Training records, project records, admin data. | Annual. | Report qualitatively where numbers are small. |
| Leadership and decision-making | Gender representation in Top Management, project leadership, proposal leadership, technical decision groups and tender teams. | Organisational/project records. | Annual and at proposal stage. | Avoid individual-level external reporting. |
| Work-life balance | Use of flexible working arrangements, leave and workload indicators by gender where feasible. | Admin/work planning records. | Annual. | Do not publish sensitive leave details. |
| Pay and economic treatment | Review of remuneration or compensation practices for comparable roles and responsibilities. | Payroll/accounting data. | Annual. | Access limited to authorised persons only. |
| Harassment and grievances | Number and type of concerns received, response time, outcome and remediation, without personal data. | Grievance log. | Annual and case-by-case. | Anonymised reporting only. |
| Gender dimension in innovation | Share of relevant projects with completed gender dimension screening and actions where applicable. | Project files. | At project start and annual. | No personal data unless needed and lawful. |
7.1 Initial assessment method
Within three months of approval of the GEP, the GEP Coordinator shall prepare a baseline note covering workforce composition, recruitment practices, training records, work-life balance practices, decision-making roles, grievance mechanisms and gender dimension considerations in ongoing projects. The baseline note shall identify gaps, priority actions and data limitations.
7.2 Annual targets
Targets are reviewed annually. The initial targets for the 2026-2028 period are:
- 100% of personnel informed of the GEP and reporting channels within one month of approval or onboarding.
- At least 90% completion of annual gender equality and harassment prevention training, with reasonable catch-up for absences.
- 100% of recruitment campaigns use objective criteria, inclusive language and structured interview notes.
- 100% of relevant European project proposals and innovation projects complete a gender dimension relevance screening.
- Annual review of workforce, training, recruitment, leadership and grievance indicators by Top Management.
- All reports or concerns related to harassment, discrimination or retaliation are acknowledged, assessed and documented with appropriate remediation.
8 GENDER EQUALITY OBJECTIVES AND ACTION PLAN
The following action plan translates Kolibree-Tech commitments into operational measures. Actions are reviewed annually and may be updated as the Company grows, joins new consortia, recruits new personnel, changes project portfolio or receives feedback from employees and stakeholders.
8.1 Work-life balance and organisational culture
| Action | Responsible | Timing | KPI / Evidence |
|---|---|---|---|
| Confirm and communicate flexible working practices, including remote/hybrid work, flexible scheduling and reasonable accommodation of caring responsibilities where compatible with business needs and project commitments. | Top Management / GEP Coordinator | Q3 2026; ongoing | Policy communication; onboarding checklist; annual staff feedback. |
| Plan meetings, deadlines and travel with reasonable notice and avoid unnecessary scheduling outside normal working hours. | Managers / Project Leaders | Ongoing | Project meeting records; feedback; corrective actions if recurring issues arise. |
| Monitor work-life balance indicators and identify whether flexible arrangements are equally accessible and do not negatively affect career progression or project opportunities. | GEP Coordinator / HR | Annual | Annual dashboard; management review minutes. |
| Promote psychological safety, respectful communication and constructive dialogue between management and employees. | All personnel | Ongoing | Training records; feedback; grievance data. |
8.2 Leadership and decision-making
| Action | Responsible | Timing | KPI / Evidence |
|---|---|---|---|
| Define transparent criteria for assigning project leadership, task leadership, proposal leadership and decision-making responsibilities. | Top Management / Project Leaders | Q4 2026; annual review | Criteria documented; project assignment records. |
| Seek balanced representation of genders in project teams, tender teams, panels and decision groups where feasible; document the rationale when balance cannot be achieved due to size, availability or required expertise. | Managers / Project Leaders | At project/tender start | Project staffing notes; tender/proposal files. |
| Ensure that leadership opportunities, visibility in European projects and external representation are communicated fairly and allocated using objective criteria. | Top Management | Ongoing | Project role assignment records; annual review. |
| Include gender equality progress in management review and business planning. | Top Management / GEP Coordinator | Annual | Annual GEP report; action tracker. |
8.3 Recruitment, selection and career progression
| Action | Responsible | Timing | KPI / Evidence |
|---|---|---|---|
| Use inclusive and neutral language in job descriptions, avoiding unnecessary requirements and stereotypes; state the Company commitment to equal opportunity. | HR / Hiring Manager | Every recruitment | Job advert checklist; archived adverts. |
| Use structured selection criteria and interview notes to reduce bias and improve comparability between candidates. | Hiring Manager / Interviewers | Every recruitment | Interview template; selection matrix. |
| Where feasible, seek gender balance in candidate shortlists and interview panels, taking account of labour-market availability and Company size. | Hiring Manager | Every recruitment | Shortlist notes; rationale where not feasible. |
| Monitor recruitment funnel and hiring outcomes by gender when data are available and lawful, and review reasons for imbalances. | GEP Coordinator / HR | Annual | Annual recruitment indicator review. |
| Ensure transparent criteria for training, role changes, salary review, project visibility and progression opportunities. | Top Management / Managers | Annual | Criteria and review notes; training plan. |
8.4 Skills development, training and mentoring
| Action | Responsible | Timing | KPI / Evidence |
|---|---|---|---|
| Provide annual awareness training on gender equality, respectful conduct, unconscious bias, harassment prevention, reporting channels and non-retaliation. | GEP Coordinator | Annual; onboarding | Training material; attendance records; completion rate >= 90%. |
| Provide role-specific training for managers and decision-makers on inclusive leadership, structured recruitment, objective evaluations and gender-sensitive communication. | Top Management / GEP Coordinator | Annual or role assignment | Training records; updated templates. |
| Map training and certification opportunities and monitor access by gender, ensuring that project-critical training is available fairly. | Managers / HR | Annual | Training plan; participation dashboard. |
| Offer mentoring, peer learning or knowledge-sharing opportunities for employees taking on new technical, project or leadership responsibilities. | Managers / Project Leaders | Ongoing | Mentoring notes; project onboarding records. |
8.5 Gender dimension in research, innovation and technology
| Action | Responsible | Timing | KPI / Evidence |
|---|---|---|---|
| At proposal or project kick-off, assess whether sex and/or gender may influence needs, usage, safety, accessibility, data quality, bias, adoption or impact of the solution. | Project Leader / Technical Lead | Every relevant project | Gender dimension screening checklist. |
| Where relevant, integrate gender-sensitive requirements into user research, datasets, testing, validation, communication, risk assessment and impact analysis. | Project Team | Project lifecycle | Project documentation; test plans; data notes. |
| Consider intersectionality in design decisions, including age, disability, language, culture, socioeconomic context and digital access where relevant to users or beneficiaries. | Project Team | Project lifecycle | Requirements and risk registers. |
| Review external communication, marketing and dissemination materials to avoid stereotypes and promote inclusive language and imagery. | Communication / Project Team | Before publication | Communication review checklist. |
| When gender is not relevant to a project, document the reason briefly rather than leaving the issue unassessed. | Project Leader | At project start | Project screening record. |
8.6 Prevention of gender-based violence, harassment and discrimination
| Action | Responsible | Timing | KPI / Evidence |
|---|---|---|---|
| Maintain a zero-tolerance approach to discrimination, harassment, sexual harassment, gender-based violence, bullying and retaliation. | Top Management / All personnel | Ongoing | Policy communication; training records. |
| Ensure that reporting channels are known, accessible, confidential and include the possibility of escalation beyond the direct manager where appropriate. | Top Management / GEP Coordinator | Q3 2026; onboarding | Internal communication; onboarding checklist. |
| Acknowledge concerns promptly, assess risks, protect affected persons, investigate fairly and document corrective or remedial actions. | Top Management / Delegated investigator | Case-by-case | Confidential case file; anonymised grievance log. |
| Prohibit retaliation against any person who reports a concern in good faith, supports an investigation or participates as a witness. | Top Management / All personnel | Ongoing | Policy communication; disciplinary/corrective actions if needed. |
| Include harassment-free collaboration expectations in relevant project, supplier and partner communications. | Project Leaders / Procurement | At contracting/project start | Contract clauses; partner onboarding notes. |
8.7 Stakeholders, suppliers and external partnerships
| Action | Responsible | Timing | KPI / Evidence |
|---|---|---|---|
| Communicate Kolibree-Tech expectations on non-discrimination, human rights and harassment-free conduct to suppliers and business partners where relevant. | Procurement / Project Leaders | At supplier onboarding or contract renewal | Supplier communication; contract clauses. |
| Consider social responsibility practices, including the abolition of unfair discrimination, in supplier selection and project partner due diligence. | Procurement / Project Leaders | Supplier selection | Supplier assessment notes. |
| Promote balanced participation and inclusive conduct in European consortia, meetings, dissemination events and stakeholder engagement activities. | Project Leaders | Project lifecycle | Meeting records; dissemination planning. |
| Use stakeholder feedback, where available, to improve the GEP and identify adverse impacts or barriers affecting gender equality. | GEP Coordinator | Annual | Feedback summary; management review actions. |
9 GRIEVANCE MECHANISM, REMEDIATION AND NON-RETALIATION
Kolibree-Tech will apply the voluntary Confidential Ethics Reporting & Grievance Mechanism described in its Code of Conduct to concerns about gender-based discrimination, harassment, sexual harassment, violence, retaliation or breaches of this GEP. The CEO is the ordinary recipient; concerns involving the CEO or creating a conflict of interest are referred directly to the separately appointed Independent Ethics Reviewer via a channel to which the CEO has no access. Operational reporting details will be published on the Our Values website section when the primary and alternative channels have been activated and tested.
| Step | Minimum requirement |
|---|---|
| 1. Reporting | Employees, collaborators, suppliers, project partners and other stakeholders may raise concerns through the dedicated ethics reporting routes described in the Code of Conduct. Confidentiality applies; anonymity is supported only when technically available. |
| 2. Acknowledgement and triage | The CEO or, in conflict cases, the Independent Ethics Reviewer acknowledges where contact is possible; assesses urgency, security and conflicts of interest; and restricts access to the assigned handler. |
| 3. Assessment / investigation | The matter is assessed fairly, impartially and confidentially. External expertise may be used for complex or sensitive cases. |
| 4. Remediation and corrective action | If a violation is confirmed or risks are identified, Kolibree-Tech takes appropriate corrective and remedial action, which may include protection measures, training, disciplinary action, process changes or supplier/partner escalation. |
| 5. Closure and learning | Cases are documented confidentially; anonymised lessons learned are included in the annual GEP review where appropriate. |
Retaliation is strictly prohibited. Any adverse treatment against a person who reports a concern in good faith, supports another person, gives evidence or participates in an investigation shall be treated as a serious violation.
Reporting channels and instructions will be made available in the Our Values section once the voluntary primary and independent channels are operational.
Remediation shall be appropriate to the nature and severity of the impact and may include restoring a safe working environment, correcting decisions, providing support to affected persons, changing processes, training individuals or teams, or adopting disciplinary or contractual measures in accordance with applicable law.
10 COMMUNICATION, PUBLICATION AND RECORDS
The effectiveness of the GEP depends on active communication. Kolibree-Tech will ensure that the Plan and related procedures are accessible, understandable and integrated into onboarding, management review, project planning and relevant external communications.
| Record | Owner | Retention / location |
|---|---|---|
| Approved GEP and public HTML version | GEP Coordinator | Controlled source in Company repository; approved HTML page and publication evidence. |
| Top Management approval and appointment of responsibilities | Top Management / GEP Coordinator | Document control file; management review minutes. |
| Website publication evidence | GEP Coordinator / Communication | URL, screenshot or publication record. |
| Internal communication record | GEP Coordinator | Email, meeting minutes or onboarding checklist. |
| Training materials and attendance records | GEP Coordinator / HR | Training folder, employee file or project file as applicable. |
| Annual dashboard and management review | GEP Coordinator / Top Management | Annual GEP folder; confidential annex where needed. |
| Recruitment and project checklists | Hiring Manager / Project Leader | Recruitment/project files. |
| Grievance and remediation records | Top Management / authorised persons | Confidential case file with restricted access. |
Records are retained in accordance with applicable legal, contractual and privacy requirements. Sensitive or personal information must not be included in public versions or shared externally unless lawful, necessary and appropriately protected.
11 MONITORING, ANNUAL REVIEW AND CONTINUOUS IMPROVEMENT
The GEP is a living management tool. It is reviewed at least annually by Top Management using the annual dashboard, training records, recruitment and project evidence, grievances, stakeholder feedback and progress against the action plan. The review identifies achievements, gaps, corrective actions and priorities for the next period.
| Review input | Questions to address |
|---|---|
| Data dashboard | Are there gender gaps in workforce composition, recruitment, training, leadership, pay review, work-life balance or project opportunities? |
| Action plan progress | Which actions were completed, delayed or no longer relevant? What evidence exists? |
| Training and awareness | Was training completed? Did personnel understand the Plan and reporting channels? |
| Grievance and remediation | Were concerns handled promptly, confidentially and without retaliation? Are systemic improvements needed? |
| Projects and tenders | Were gender dimension screenings completed where relevant? Did tender or consortium requirements change? |
| Stakeholder feedback | Do employees, partners or other stakeholders identify barriers or improvement opportunities? |
| Resources | Are resources, expertise, time and responsibilities still adequate for the size and risk profile of the Company? |
The outcome of the annual review shall be documented and may lead to an updated version of the GEP, revised indicators, new actions, additional resources, targeted training or changes to procedures and templates.
12 IMPLEMENTATION ROADMAP 2026-2028
| Period | Milestone | Owner | Evidence |
|---|---|---|---|
| Q2 2026 | Review implementation of the GEP originally approved on 19 May 2025; verify role allocation, internal communication and progress towards publication of the controlled HTML version. | Top Management / GEP Coordinator | Original approval record; dated implementation status; responsibility assignment and HTML publication record when available. |
| Q3 2026 | Verify the status of baseline assessment, data sources, dashboard and first awareness session; identify any overdue actions and corrective dates. | GEP Coordinator / HR | Baseline note; dashboard; training records. |
| Q4 2026 | Embed recruitment checklist, project gender dimension screening and harassment prevention procedures into operational templates. | GEP Coordinator / Managers | Updated templates; project files. |
| 2027 | Implement full annual cycle: data collection, training, action plan review, management review and public/tender evidence update. | Top Management / GEP Coordinator | Annual GEP report; management review minutes. |
| 2028 | Evaluate effectiveness of measures, update objectives and prepare next GEP cycle. | Top Management / GEP Coordinator | Evaluation report; revised GEP or change log. |
Completion of the activities scheduled for 2026 must be confirmed against internal implementation evidence.
13 APPROVAL, REVIEW AND DOCUMENT CONTROL
This GEP enters into force upon approval by Top Management. It remains valid until replaced by a new revision or withdrawn by Top Management. The document shall be reviewed at least annually and after significant organisational or regulatory changes.
Changes to this Plan shall be recorded in the change log and communicated to affected personnel. Superseded versions shall be archived according to the Company document control rules.