Purpose

This Policy expresses TrueScreen’s formal commitment to promoting gender equality, preventing all forms of direct and indirect discrimination, and ensuring equal opportunities for access, professional growth, and recognition for all individuals working within the organization, regardless of gender.

TrueScreen recognizes diversity as a strategic asset for innovation and competitiveness in the cybersecurity and Information Technology sectors. This Policy serves as the ethical and strategic foundation of the Company’s Gender Equality Management System, defining the principles, objectives, and responsibilities that guide the organization in fostering a fair, inclusive, and respectful working environment, in accordance with UNI/PdR 125:2022.

Through this Policy, TrueScreen transparently reaffirms its commitment to achieving gender equality, valuing diversity, and supporting women’s empowerment across every stage of the employment lifecycle, including recruitment, career development, internal and external communication, as well as marketing and advertising activities.

Scope

This Policy applies to all personnel of TrueScreen, including permanent and fixed-term employees, contractors, consultants, interns, temporary workers, and any other individuals working on behalf of the Company. It also applies to external consultants, suppliers, commercial and technology partners, and any third party acting in the name of or on behalf of the organization.

The geographical scope of this Policy includes TrueScreen’s operational offices located at Via della Zecca 1, 40121 Bologna, 40122 Bologna, as well as all activities performed through remote working arrangements.

This Policy applies to all business processes in which gender equality is relevant, including human resources management, recruitment and selection, career development, pay equity, parental support, work-life balance, the prevention of harassment, and internal and external communication.

Regulatory References

This Policy is based on, and shall be interpreted in accordance with, the following regulations and standards:

• UNI/PdR 125:2022 – Guidelines on Gender Equality Management Systems.
• Italian Legislative Decree No. 198/2006 – Equal Opportunities Code between Women and Men.
• Italian Legislative Decree No. 151/2001 – Consolidated Act on the Protection and Support of Maternity and Paternity.
• Italian Law No. 162/2021 – Amendments to the Equal Opportunities Code and measures to promote gender equality in the workplace.
• Directive (EU) 2023/970 – Strengthening the application of the principle of equal pay for equal work or work of equal value through pay transparency and enforcement mechanisms.
• Regulation (EU) 2016/679 (General Data Protection Regulation – GDPR).

Terms and Definitions

Gender Equality: Equal opportunities, treatment, and access to resources for all individuals within the organization, regardless of gender.

Discrimination: Any unequal treatment or denial of equal opportunities resulting from judgments or classifications based on gender.

Women’s Empowerment: The process through which women acquire the skills, autonomy, and authority necessary to make strategic decisions in their personal, social, political, and economic lives.

Inclusion: The effective and sustainable integration of individuals into the organization in a way that promotes equal opportunities, prevents discrimination, and creates value for both people and the business.

Harassment: Any unwanted conduct that has the purpose or effect of creating an intimidating, hostile, degrading, humiliating, or offensive working environment.

Gender Stereotypes: Widely shared and socially transmitted beliefs about the roles, behaviors, occupations, characteristics, and physical appearance that are considered appropriate for individuals solely on the basis of their gender.

Key Performance Indicators (KPIs): Quantitative and qualitative metrics used to monitor the effectiveness of the Gender Equality Management System and measure progress toward the objectives established by the Gender Equality Policy.

Strategic Plan: A formal document defining the organization’s gender equality objectives, the resources allocated, responsibilities, implementation methods, and monitoring frequency.

Gender Equality Policy: The formal document through which the organization establishes its principles, strategic commitments, and objectives for promoting gender equality and equal opportunities.

Roles and Responsibilities

Top Management: Approves this Policy and the Gender Equality Strategic Plan, allocates the resources necessary for their implementation, and periodically reviews their effectiveness.

Chief Executive Officer (CEO): Promotes a culture of inclusion and gender equality at the strategic level, ensuring alignment between the Company’s business objectives and the commitments established by this Policy.

Chief Operating Officer (COO): Coordinates the implementation of operational measures related to work-life balance and parental support, ensuring that organizational processes are consistent with the principles set out in this Policy.

Chief Marketing Officer (Acting CMO): Ensures that all external communication, marketing, and advertising activities comply with the principles of inclusive language and avoid reinforcing gender stereotypes.

Gender Equality Management System Manager: Supports the documentation, implementation, monitoring, and continuous improvement of the Gender Equality Management System by tracking the relevant KPIs and preparing the information required for periodic management reviews.

Commitments and Objectives of the Gender Equality Management System 

TrueScreen adopts this Policy as a formal expression of its commitment to creating a working environment in which every individual can fully contribute to the Company’s success, without gender influencing opportunities for professional growth, compensation, or professional dignity.

People Management and Career Development

TrueScreen is committed to ensuring that recruitment, hiring, professional development, and career progression processes are based on objective, merit-based criteria and are free from any form of gender discrimination.

To achieve this objective, TrueScreen is committed to:

• Adopting inclusive recruitment practices, including the use of gender-neutral language in job advertisements, providing awareness on unconscious bias to those involved in recruitment activities, and monitoring gender equality indicators throughout the recruitment and hiring process, as defined in the Recruitment and Hiring Procedure.
• Ensuring pay equity between women and men performing equivalent roles with comparable responsibilities and competencies through the regular collection and analysis of compensation data and the implementation of corrective actions whenever unjustified disparities are identified, in accordance with the Pay Equity Procedure.
• Guaranteeing equal access to career development opportunities and positions of responsibility by applying transparent promotion criteria and providing professional development opportunities accessible to all employees, as established in the Career Management Procedure.

Work-Life Balance and Parental Support

TrueScreen recognizes work-life balance as a fundamental factor in employee well-being, engagement, and productivity.

The Company actively promotes:

• Flexible working arrangements, including flexible working hours, remote working, part-time employment, and the scheduling of meetings at times compatible with family responsibilities, as defined in the Work-Life Balance Procedure.
• Equal access to parental leave regardless of gender, flexible return-to-work arrangements, and initiatives aimed at raising awareness of shared parental responsibilities, in accordance with the Parental Support Procedure.
• Corporate welfare initiatives designed to improve the quality of life of employees and their families, as described in the Corporate Welfare Plan.

Prevention of Harassment and Protection of Personal Dignity

TrueScreen rejects all forms of harassment, violence, bullying, discrimination, retaliation, and abuse of authority in the workplace.

The Company is committed to maintaining confidential reporting channels, ensuring impartiality and timely handling of reported cases, and protecting individuals who report concerns in good faith from any form of retaliation, in accordance with the Workplace Harassment Prevention Procedure and the Anti-Harassment and Abuse Policy.

The Code of Ethics and the Code of Conduct represent the Company’s ethical framework and are binding on all personnel, who are expected to uphold the dignity, respect, and equal treatment of every individual.

Communication, Marketing, and Advertising

TrueScreen promotes internal and external communications that reflect the principles of inclusion, diversity, and gender equality.

The Company is committed to ensuring that all institutional communications, marketing initiatives, and advertising activities:

• use inclusive language and avoid reinforcing gender stereotypes;
• promote diversity as a core element of the Company’s identity and culture;
• communicate the Company’s commitments and achievements in the field of gender equality, contributing to the promotion of an inclusive culture among employees, customers, partners, suppliers, and all other stakeholders.

The operational requirements governing corporate communications are defined in the Communication Management Procedure.

Monitoring and Continual Improvement

TrueScreen is committed to periodically measuring the effectiveness of its Gender Equality Management System through the Key Performance Indicators (KPIs) established in the Gender Equality Strategic Plan.

The Management System is reviewed at least annually, in accordance with the Periodic Review of the Gender Equality Management System Procedure.

The results of monitoring activities are used as input for Management Review and continuous improvement initiatives, ensuring that the commitments set out in this Policy are translated into measurable and sustainable progress over time.

Document Retention and Review

This Policy is maintained in digital format within TrueScreen’s document management system and is communicated to all internal stakeholders upon its adoption and whenever significant updates are made. The current version is also made available to external stakeholders through the Company’s official communication channels.

Top Management reviews this Policy at least annually as part of the Gender Equality Management System Management Review, or whenever significant regulatory, organizational, or strategic changes occur.

Any approved revisions are promptly communicated to all employees and relevant stakeholders. Previous versions of the Policy are retained for traceability, version control, and audit purposes.