Gender Equality Policy and Related Policies (p-pdg)

Rev. 0-14.07.2025

The core principles underlying KARMA's Gender Equality Policy are:

IMPARTIALITY AND INCLUSIVITY:
KARMA ensures that its directors, employees, and collaborators operate with behaviors inspired by objectivity, impartiality, and care towards all the organizations to which it provides its services.

• KARMA is committed to promoting fair treatment of its staff and to fostering a working environment free from discrimination based on race, religion, sex, age, political opinions and physical disabilities.

FAIRNESS AND TRANSPARENCY:
KARMA is committed to ensuring that its staff always conduct themselves ethically, with dignity and respect. All activities are carried out with commitment and integrity, in compliance with applicable regulations and internal operating procedures.

• KARMA is committed to operating in a clear and transparent manner without favoring any special interest group or individual.

STAFF DEVELOPMENT:

• Human resources management is based on respect for people and equal opportunities, in a context of equal treatment, loyalty, and trust.
• KARMA opposes any discrimination based on race, gender, nationality and origin, religion, language, disability, political orientation, sexual orientation and any other cultural or personal characteristic.

PROTECTION OF THE PERSON:

• KARMA carries out its activities in accordance with current legislation protecting working conditions.
• Relationships between employees are based on the principles of civil coexistence and are conducted with mutual respect for the rights and freedoms of individuals, to maintain a working environment with mutual respect for the dignity and reputation of each individual.

ANTI-ALL FORMS OF VIOLENCE AND DISCRIMINATION:

• KARMA ensures that in internal and external work relationships, no form of intimidation, threat, verbal or physical behavior or offense, or request for personal favors that could hinder the peaceful and normal performance of one's duties, occurs.
• Anyone who, while carrying out their work on behalf of or for the benefit of KARMA, believes they are being harassed or discriminated against for any reason has the right to report the incident using the methods indicated in the Harassment Regulations.

KARMA's commitment to ensuring that its Gender Equality Management System (SGPG) meets the requirements specified in UNI/PdR 125:2022 is inspired by the European Union's 2020-2025 Gender Equality Strategy, which aims to achieve the following objectives:

• increasing women's participation in the labor market
• Reducing the pay and pension gap between men and women, also to combat female poverty
• promoting equality between men and women in the decision-making process
• combating stereotypes, gender-based violence, and protecting and supporting victims

THE MANAGEMENT'S COMMITMENT

To promote the achievement of the principles and objectives set forth, KARMA's Senior Management, in coordination with the Steering Committee, believes the continued adoption of the SGPG is essential in order to develop an organizational model that promotes gender equality and enhances equity and inclusiveness.

KARMA is committed to:

• to adopt tools to prevent any form of gender discrimination and to combat any act that is harmful to the dignity of staff, regardless of their role and level of responsibility
• to enhance diversity in every company process: from the search and selection of human resources to access to training, from the definition of remuneration policies to performance evaluation and the attribution of reward systems, from the selection of suppliers to the provision of services/supply of products
• to support the family welfare of its employees through working arrangements (part time) that encourage the conciliation between professional activity and private life
• to promote information, awareness-raising and staff involvement on issues of equal opportunities and women's emancipation, avoiding stereotypes and promoting the visibility of women's contributions
• to promote communication, including through marketing and advertising activities, that transparently declares the desire to achieve gender equality, enhance diversity, and support women's emancipation

SPECIFIC POLICIES ON GENDER EQUALITY

KARMA has adopted more specific policies on gender equality that provide the necessary input to formulate the Strategic Plan for Gender Equality and to identify, develop and implement procedures specifically dedicated to gender equality, based on the organization's reference context.

KARMA has developed the following specific policies:

• Selection and hiring (recruitment)
• Career Management
• Pay equity
• Parenting, care
• Work-life balance
• Prevention of all forms of physical, verbal, and digital abuse (harassment) in the workplace

SELECTION AND RECRUITMENT POLICY

Our organization, in the selection and hiring of personnel for business activities, respects the following principles with a view to improvement:

• The selection of the candidate is carried out in a gender-neutral manner.
• The selection criteria take into account requirements aimed at personal qualities such as professionalism, competence, specialization, and experience.
• The selection does not include questions relating to marriage, pregnancy and family responsibilities.
• The selection process takes into account the presence of women and men in the workforce in a non-discriminatory manner with respect to the total number of people present.
• Roles relating to managers, department heads, top management reporting, and budget delegation are distributed equally.
• The job position, as defined during the hiring process, provides a salary related to the duties and responsibilities and is not influenced by gender.
• The selection process takes into account the percentages of women and men whose contracts provide for variable, non-discriminatory remuneration.

CAREER MANAGEMENT POLICY

Our organization recognizes that financial results also depend on its human resources, and intends to base all career development opportunities solely on individual results and merit, regardless of gender. With a view to continuous improvement, our organization manages the careers of its internal staff in accordance with the following principles:

• The assignment of roles and duties is carried out in a non-discriminatory manner.
• Career path design and presentation are gender-neutral.
• Staff career paths are accessible to all who can transparently verify that gender equality is being maintained.
• The work environment in which most of the day is spent ensures the technological and physical opportunity for everyone to express themselves and well-being is seen as safety and comfort.
• Skills and awareness training is a key process to address career challenges and is conducted in a gender-neutral manner.
• Considering the career progression associated with the Board of Directors, at least 1/3 of our Board of Directors must be represented by women.
• Promotions always take into account gender balance at the functional level.

COMMUNICATION POLICY

The organization recognizes the importance of internal corporate communication as a tool for sharing corporate information and motivating staff. Internal communication pursues the following objectives:

• create a communication model and style aimed at generating a constant flow of information for employees
• ensure constant attention to the language used, promoting communication that is as kind and neutral as possible
• promote the use of behaviors and language that ensure an inclusive and gender-diverse work environment
• prepare and disseminate to its stakeholders a communication plan relating to its commitment to gender equality issues
• base internal and external communications (marketing, advertising, etc.) on responsibility, avoiding gender stereotypes in advertising, committing to spreading a positive image of women and girls, using language that respects gender differences
• facilitate understanding of the strategies adopted
• spread the company's identity and values

PAY EQUITY POLICY

Our organization strives to ensure equal pay, regardless of gender, when hiring and throughout its staff's career. The organization does not consider the costs of compensating people of different genders unequally. In determining, paying, and adjusting pay, the organization adheres to the following principles:

• Individuals' remuneration is recognized in relation to their role and responsibilities, and any additional benefits or bonuses to such remuneration are considered to be based exclusively on the results produced and recognized.
• For transparency, compensation, bonuses, and benefits are documented and accessible to all staff.
• Compensation, rewards, and benefits are documented and accessible to all staff.
• Any member of staff has the right to report any discrepancies.

PARENTING AND CARE POLICY

Our organization aims to avoid creating any obstacle to parenthood, supporting motherhood and fatherhood through activities designed to meet the needs of those who, due to their parental status, must balance their work commitments with emerging needs. The organization supports this intention based on the following principles:

• Maternity and paternity are supported by training, information and reintegration programmes.
• Maternity is supported before, during and after birth.
• Paternity leave must be promoted so that all potential beneficiaries can take advantage of it for the entire period provided by law.
• Returns from leave are supported by specific reorientation initiatives.
• The organization takes an active role in supporting caregiver activities (taking care of the unborn child) with concrete initiatives.

WORK-LIFE BALANCE POLICY

Our organization aims to provide its staff with the ability to manage their time between work and life through a balanced approach that takes into account both the company's business objectives and the employee's psychological and physical well-being, resulting from greater freedom of self-determination. The principles underlying work-life balance are the following:

• Work-life balance measures are aimed at all staff regardless of gender.
• The organization adopts part-time work.

ABUSE AND HARASSMENT PREVENTION POLICY

Our organization rejects all forms of abuse and harassment. Therefore, it pursues zero-tolerance prevention and repression. The organization implements its prevention efforts through concrete actions, the principles of which include:

• That risks relating to abuse and harassment are identified.
• That the organization plans preventive actions in relation to this risk.
• The ability to report suspicions and/or incidents relating to abuse and harassment.
• The organization's absolute protection of the reporting individuals from any subsequent retaliation.
• That the organization analyzes and understands any incidents of abuse and harassment.
• Developing gentle, gender-neutral communication.

Salerno, July 14, 2025

The CEO:
Carlo De Luca