<Policy for equality>

Background

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CodeWin currently has more than 150 employees in different countries, and we know how important it is to adopt a socially responsible attitude in everything that surrounds us. This is why we created a Plan for Diversity, Equality and Inclusion where we are committed to contribute to the construction of a fairer, more balanced and more sustainable world.

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To carry out a comprehensive and correct assessment with regard to Equality at CodeWin, we have considered the guidelines and good practices of::

• Guide for drawing up plans for equality, published by CITE;
• Internal platform for managing objectives, targets and actions associated with SDGs 5 and 10;
• Continuous evaluation of the objectives and measures defined so that they are as appropriate as possible to the reality of the moment.

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Our Purpose

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The values of equality, diversity and inclusion have always been part of CodeWin genesis. Over time, we have made this issue one of our priorities within the scope of Corporate and Social Responsibility, but also among the leaders of different areas and departments.

CodeWin launched the Empower Voices program. Focused on diversity, equality and inclusion, it meets the requirements of Sustainable Development Goals 5 (Gender Equality) and 10 (Reduction of Inequalities). In this sense, a diagnosis of the company began with the aim of understanding which existing actions and measures would make sense to maintain, as well as an assessment of the company's current situation to assess which measures would make sense to implement. Specific objectives were defined with associated measures (some already implemented, others being implemented and others to be implemented).

Therefore, this plan for equality aims to guarantee the implementation and promotion of best practices, as well as publicly making CodeWin commitment to the topic and also constantly monitoring and improving the objectives and expected results. These values are clear in both the company's Code of Conduct and Internal Policy and this plan must be read in accordance with them.

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Commitments

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I. Recruitment and Hiring

Promoting equality starts from the moment of recruitment. At CodeWin we guarantee a fair process for all candidates across different topics.

- All recruitment advertisements are inclusive, making clear CodeWin guarantee that the only criteria for recruitment will be the ability and adaptability of each person to the position;

- The entire recruitment process is carried out with respect for each person's personal characteristics, ensuring that none of them has any influence on the process.

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II. Work Life Balance

CodeWin promotes a balance between work and personal life for each employee in different ways:

- In terms of scheduling vacations, the process is unilateral according to the employee's interests and needs, without placing the work of the team and in agreement with their superior;

- Employees' hours are flexible and work can be carried out taking into account the needs of each person, always without compromising the work to be carried out and in agreement with the hierarchical superior;

- The work model is hybrid, always in agreement with the hierarchical superior;

- Some of the events/trainings at CodeWin are open to family members in order to involve everyone within the company;

- Possibility for employees to accompany their child on the first day of school (up to the 12th year) as long as it is aligned and approved with the hierarchical superior;

- Offering a birth kit to encourage employees to experience motherhood/fatherhood freely.

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III. Training and Recognition

- Ensure and define procedures in which the promotion of an employee is based on their skills;

- Implement ways of working that ensure that everyone is encouraged to develop their potential and use their talent;

- Ensure that everyone feels respected and able to do their best;

- Ensure that training, development and progression opportunities are available to everyone.

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IV. Awareness and Participation

- Internal and external communications that reinforce CodeWin commitment to the topic and make the company's reality known;

- Offering specific training on Diversity, Equality and Inclusion in order to work in a reality free from prejudice and discrimination;

- Promotion of employee involvement in the implementation of this policy through internal and external initiatives;- Internal lectures within the themes where we invite employees to be speakers;

- Creation of internal debate groups where, every three months, employees discuss a different topic within diversity, equality and inclusion.

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V. Guarantee of Non-Discrimination

- Existence of codes of conduct and policies that condemn situations of moral and/or sexual harassment, as well as what should be done in these situations;

- Promotion of an internal culture in which the individual differences and contributions of all team members are recognized and valued, allowing fair participation in their work and respective activities;

- Defense of a work environment based on mutual respect and free from intimidation, harassment, victimization and discrimination, creating effective mechanisms to investigate complaints involving discriminatory practices in general;

- Possibility of anonymous reporting of irregularities so that employees can report specific situations;- Review practices and processes whenever necessary to ensure compliance with this policy.

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Monitoring and Communication

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Monitoring

The working group created within the scope of Corporate and Social Responsibility will be responsible for monitoring and implementing the equality plan, always with the approval and support of the CEO, as well as the directors associated with each one of the measures. In other words, the measures defined for each department will always be reviewed and analyzed by their directors. Reviews are carried out with the maximum frequency of one year and can be revised at any time that makes sense for the company. Furthermore, an internal platform was created that allows us to manage the actions that are being implemented, as well as the objectives that we are achieving.

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Communication

KCS IT’s equality plan is shared internally and externally. Through a set of communication measures (internal and external), it reinforces its commitment to the topic.

Therefore, it uses interviews and articles written by employees in order to express its position, as well as raise awareness of the topic.

At the same time, it uses digital channels to share information and content that keeps employees up to date with issues and raises awareness.

Furthermore, all employees will be aware of the existence of this plan through:

- Internal newsletter informing about the creation of the equality plan;

- Internal platform where it is available to be consulted whenever necessary;

- Furthermore, the plan will also be available on the company's website for consultation by both internal and external people.

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