Workplace Non-Discrimination and Inclusion Policy

1. Executive Summary

Solapave is committed to fostering a diverse, equitable, and inclusive work environment that drives innovation, enhances employee engagement, and ultimately contributes to our competitive advantage in the global marketplace. This comprehensive policy outlines our strategic approach to non-discrimination and inclusion, aligning our talent management practices with our core business objectives and stakeholder expectations.

2. Purpose and Scope

i. Strategic Intent

This policy serves as a cornerstone of our human capital strategy, designed to:

• Attract and retain top talent from diverse backgrounds

• Foster an inclusive culture that drives innovation and creativity

• Mitigate legal and reputational risks associated with discrimination

• Enhance our employer brand and corporate reputation

• Align our practices with the expectations of customers, investors, and other stakeholders

ii. Scope of Application

This policy applies to all facets of our business operations and talent management lifecycle, including but not limited to:

• Recruitment, selection, and onboarding

• Performance management and career development

• Compensation and benefits administration

• Succession planning and leadership development

• Corporate culture and employee experience

• Vendor and partner relationships

• Corporate social responsibility initiatives

It encompasses all employees, contractors, vendors, partners, and other stakeholders across our global operations.

3. Policy Statement

Solapave prohibits discrimination based on any characteristic protected by applicable law or recognised as a dimension of diversity, including but not limited to:

• Race, colour, and ethnicity

• Sex, gender identity, and expression

• Sexual orientation

• Religion, belief, or philosophical conviction

• Political opinion or affiliation

• National origin, citizenship, or migration background

• Social or economic class

• Age and generational identity

• Physical or mental ability status

• Neurodiversity

• Genetic information

• Marital, family, or caregiver status

• Veteran or military status

• Educational background

• Work style and personality type

• Or any other characteristic protected by law or relevant to fostering a diverse and inclusive workplace

We are committed to ensuring that all individuals are afforded equal opportunities to contribute, succeed, and advance based on their merits, qualifications, and potential.

4. Definitions and Conceptual Framework

i. Key Concepts

• Diversity: The presence of differences within a given setting. In the workplace, this refers to the composition of the workforce across various dimensions.

• Equity: The fair treatment, access, opportunity, and advancement for all people, while striving to identify and eliminate barriers that have prevented the full participation of certain groups.

• Inclusion: The creation of a work environment where all individuals feel respected, accepted, supported, and valued to fully participate.

• Belonging: The experience of feeling psychologically safe, accepted, and valued within the organisation.

ii. Types of Discrimination

Direct Discrimination: Treating an individual less favourably because of a protected characteristic.

• Indirect Discrimination: Applying a provision, criterion, or practice that disadvantages people with a protected characteristic without objective justification.

• Associative Discrimination: Treating an individual less favourably because of their association with someone who has a protected characteristic.

• Perceptive Discrimination: Discrimination against an individual because of a perception that they have a particular protected characteristic.

• Harassment: Unwanted conduct related to a protected characteristic that violates an individual's dignity or creates an intimidating, hostile, degrading, humiliating, or offensive environment.

• Victimisation: Subjecting a person to detrimental treatment because they have made or supported a complaint about discrimination or harassment.

• Microaggressions: Subtle, often unintentional, behaviours or comments that communicate hostile, derogatory, or negative attitudes toward marginalised groups.

5. Strategic Alignment and Governance

i. Alignment with Corporate Strategy

This policy supports our corporate strategy by:

• Enhancing our ability to innovate and adapt in a rapidly changing global market.

• Improving decision-making through diverse perspectives.

• Strengthening our brand and reputation among customers and stakeholders.

• Increasing employee engagement and productivity.

• Expanding our talent pool and improving talent retention.

ii. Governance Structure

• Directors: Oversee the overall DEI strategy and holds executive leadership accountable for progress.

• Diversity Officer: Reports to the CEO, leads the development and execution of DEI initiatives.

• DEI Department: Supports the implementation of this policy across all business units.

• Business Unit DEI Champions: Drive implementation within their respective units.

• Employee Resource Groups (ERGs): Provide insights and support for DEI initiatives.

6. Key Stakeholder Responsibilities

i. Directors

• Ensure DEI is integrated into the corporate strategy.

• Review and approve DEI goals and metrics.

• Hold executive leadership accountable for DEI performance.

ii. Executive Leadership

• Model inclusive leadership behaviours.

• Incorporate DEI goals into business unit objectives.

• Allocate necessary resources for DEI initiatives.

• Regularly communicate the importance of DEI to the organisation.

iii. Human Resources

• Develop and implement DEI-focused talent management practices.

• Provide DEI training and development programs.

• Monitor workforce demographics and inclusion metrics.

• Manage the grievance and investigation process.

iv. Managers and Supervisors

• Foster an inclusive team environment.

• Make fair and equitable decisions in hiring, promotion, and development.

• Address non-inclusive behaviours promptly.

• Support team members' participation in DEI initiatives.

v. All Employees

• Treat all colleagues and stakeholders with respect and dignity.

• Participate in DEI training and initiatives.

• Report any incidents of discrimination or non-inclusive behaviours.

• Provide input on DEI efforts through surveys and feedback mechanisms.

7. Strategic Initiatives and Procedures

i. Talent Acquisition and Management

• Implement AI-powered tools to reduce bias in job descriptions and resume screening.

• Use structured interview processes with diverse interview panels.

• Set diverse slate requirements for all leadership positions.

• Develop partnerships with diverse professional organisations and educational institutions.

• Implement blind evaluation processes for key talent decisions.

ii. Learning and Development

• Mandatory unconscious bias and inclusive leadership training for all employees.

• Tailored DEI training programs for different organizational levels and functions.

• Mentoring and sponsorship programs for underrepresented groups.

• Inclusion of DEI competencies in leadership development programs.

iii. Performance Management and Compensation

• Regular pay equity analyses with action plans to address any gaps.

• Inclusion of DEI goals in performance evaluations for all managers.

• Transparent promotion and succession planning processes.

• Recognition and reward programs for inclusive behaviours and DEI contributions.

iv. Inclusive Culture and Employee Experience

• Regular inclusion surveys to measure employee sentiment and experiences.

• Support and resources for Employee Resource Groups (ERGs).

• Inclusive facilities and workplace design (e.g., prayer rooms, gender-neutral bathrooms).

• Flexible work arrangements to accommodate diverse needs.

• Inclusive language guidelines for all corporate communications.

v. Supplier Diversity

• Set targets for spending with diverse suppliers.

• Provide mentoring and development programs for diverse suppliers.

• Include DEI requirements in vendor selection processes.

vi. Product and Service Inclusion

• Integrate inclusive design principles into product development processes.

• Conduct regular accessibility audits of products and services.

• Establish diverse customer advisory boards.

vii. Community Engagement and Corporate Social Responsibility

• Partnerships with organisations promoting equity in education and employment.

• Employee volunteer programs focused on underserved communities.

• Philanthropic initiatives aligned with our DEI objectives.

8. Complaint Resolution and Non-Retaliation

i. Reporting Mechanisms

• Confidential hotline managed by a third-party provider.

• Online reporting tool with option for anonymity.

• Open-door policy with direct access to HR and DEI team.

ii. Investigation Process

• Prompt, thorough, and impartial investigations of all complaints.

• Protection of confidentiality to the extent possible.

• Regular updates to involved parties on investigation status.

iii. Resolution and Corrective Action

• Range of actions from counselling to termination based on severity.

• Focus on restorative practices where appropriate.

• Systemic review to identify and address root causes.

iv. Non-Retaliation Commitment

• Strict prohibition of retaliation against anyone who reports concerns or participates in investigations.

• Regular check-ins with reporters to ensure no retaliation occurs.

• Severe consequences for any confirmed retaliatory actions.

9. Measurement, Accountability, and Continuous Improvement

i. Key Performance Indicators (KPIs)

• Workforce diversity metrics at all levels.

• Pay equity ratios.

• Promotion rates for underrepresented groups.

• Inclusion index from employee surveys.

• Supplier diversity spend.

• DEI training completion rates.

• Number and types of reported incidents.

ii. Reporting and Transparency

• Annual DEI report published externally.

• Quarterly DEI dashboards for leadership and board review.

• Integration of DEI metrics into corporate ESG reporting.

iii. External Benchmarking and Certification

• Participation in relevant DEI indices and benchmarks (e.g., Bloomberg Gender-Equality Index, Disability Equality Index).

• Pursuit of third-party DEI certifications.

iv. Continuous Improvement Process

• Annual policy review and update.

• Regular external audits of DEI practices.

• Incorporation of emerging best practices and research findings.

• Stakeholder feedback sessions to inform policy evolution.

10. Legal and Regulatory Compliance

This policy is designed to comply with and exceed the requirements of various international, federal, state, and local non-discrimination laws and regulations, including but not limited to:

• European Union: EU Employment Equality Directive

• United Kingdom: Equality Act 2010

Solapave is committed to monitoring legal developments and updating this policy as necessary to ensure ongoing compliance across all jurisdictions in which we operate.

11. Policy Review and Evolution

This policy will be reviewed annually by the Executive DEI Council and updated as necessary to reflect:

• Changes in legal and regulatory requirements

• Evolving best practices in DEI

• Feedback from employees and other stakeholders

• Results of policy effectiveness evaluations

Any significant changes to this policy will be communicated to all employees and relevant stakeholders in a timely manner.

At Solapave, we believe that cultivating a diverse, equitable, and inclusive workplace is not just a moral imperative but a business necessity in today's global economy. This policy represents our commitment to creating an environment where all individuals can thrive, innovate, and contribute to our collective success. By embracing our differences and fostering a culture of belonging, we position ourselves to better serve our customers, deliver value to our shareholders, and make a positive impact on the communities in which we operate.