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ESG POLICY
BACKGROUND
PURPOSE AND SCOPE OF APPLICATION
Companies in which LeverX Group possesses or may possess, directly or indirectly, the control, where control means:
- the ownership of the majority of the voting rights
- the ability to appoint or remove a majority of the members of the Board of Directors (or equivalent body)
- the ability to hold, by virtue of any agreements concluded with third parties, the majority of the voting rights
This Policy is aligned with and complemented with LeverX Group's internal regulations and corporate policies.
AND WITH THE FOLLOWING POLICIES AND INTERNAL PROCEDURES OF THE COMPANY:

LEVERX GROUP’S VALUES
Reliability
Whatever project stage LeverX Group joins, we provide cross-sectional support and deep immersion in our client’s business needs. From the first day of cooperation, we treat our clients' goals and values as our key priorities. Thus, our company ensures successful project completion for each client.
Honesty and Integrity
We act honorably and transparently, providing up-to-date information regarding our actions and committing to doing what we promise. Our ethical culture permeates our entire organizational ecosystem and corresponds to our company's compliance policies.
Expertise-First Services
LeverX Group has a long-time experience in the dynamic high-tech market, investments, and a professional team of certified consultants, engineers, and other employees. We are ready to ensure modern, high-quality, and customer-oriented services. Every project is thoroughly researched before launch and tested on each stage before its release.
Open collaboration
Being open to new ideas and innovative approaches to business cooperation, we arrange cross-functional team discussions and group brainstorming. We support diversity by building teams with experience, knowledge, and skill sets to speed up problem solving and increase productivity.
Environmental footprint
We have already established a smooth process of remote service delivery to reduce our carbon emissions and protect our planet against the deterioration of the environment and climate change. We’ll continue to contribute towards building a sustainable and prosperous business future by reducing the environmental impact.
ESG BASIC PRINCIPLES
The policy defined herein constitutes the minimum requirements in terms of ESG-related matters to be met by all companies that operate under the umbrella of LeverX Group.
The chief executive of each company of LeverX Group must ensure that internal regulations are developed and/or adapted in line with this policy and with any applicable legal regulations.
The ESG Policy is applicable to all the organisation's activities and in all countries in which it operates both directly and indirectly. It covers the entire life cycle of the LeverX Group’s activity and complements the Group’s companies’ commitment to comply with the requirements of the legal framework in each country.
This policy is implemented within the following international standards of reference, which it also undertakes and adopts as regulatory framework of the limits under which the activity of the company shall be carried out:
- Principles of the United Nations Global Compact (UN Global Compact)
- Guiding Principles on Business and Human Rights (United Nations)
- Sustainable Development Goals (United Nations)
- Paris Agreement on Climate Change
- Task Force on Climate-related Financial Disclosures (TCFD)
- International Labour Organization’s (ILO) Fundamental
- OECD Guidelines for Multinational Enterprises (OECD)

In line with these standards, LeverX Group commits to comply with all requirements, which applies to all Company’s activity.
In accordance with these standards, LeverX Group recognises three basic principles which apply transversally to all lines of action and commitments and upon which the implementation thereof is based:

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The protection and preservation of the environment, preserving the areas, and their biodiversity, in which the Company activities are carried out, using renewable energies, mitigating of and adapting to climate change, and contributing to sustainable development through an efficient use of resources
The protection and preservation of the environment, preserving the areas, and their biodiversity, in which the Company activities are carried out, using renewable energies, mitigating of and adapting to climate change, and contributing to sustainable development through an efficient use of resources

Gender Equality
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The protection and preservation of gender equality in which all genders of LeverX Group are free to pursue whatever career, lifestyle choice, and abilities they want without discrimination. Their rights, opportunities, and access to society are not different based on their gender. The Company strives to avoid imbalances in the Company and builds conditions for gender equality.
The protection and preservation of gender equality in which all genders of LeverX Group are free to pursue whatever career, lifestyle choice, and abilities they want without discrimination. Their rights, opportunities, and access to society are not different based on their gender. The Company strives to avoid imbalances in the Company and builds conditions for gender equality.

Partnerships for the goals
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The identification of the organisation's stakeholders, taking into consideration the entire value chain of the activity, the development of communications and participation channels and their direct and indirect involvement in the identification of material aspects and the assessment of the performance – everything what could be aimed to projects for enhance the use of enabling technology, in particular IT technologies
The identification of the organisation's stakeholders, taking into consideration the entire value chain of the activity, the development of communications and participation channels and their direct and indirect involvement in the identification of material aspects and the assessment of the performance – everything what could be aimed to projects for enhance the use of enabling technology, in particular IT technologies
ESG BASIC PRINCIPLES
IN THIS REGARD, THE STRATEGIC AREAS WHICH ARE CONTAINED IN THE ESG MASTER PLAN, ARE THE FOLLOWING:
People management:
“Boosting talent of employees, being diverse, inclusive and gender equal”
Integrity and transparency:
“Showing what we are, acting with integrity and transparency”
Sustainable development:
“Growing with a long-term sustainable environmental approach”
Based on the defined axes, and through the development of the strategic lines, the LeverX Group acquires the following commitments which, in turn, contribute to the achievement of various targets of United Nations Sustainable Development Goals (SDGs) 4, 5, 17:
This document establishes the basic guidelines and lines of action regarding the LeverX Group’s ESG strategy which allow the formalisation and implementation of the concept of ESG within the framework of the organisation, its communication thereof to stakeholders and the progressive systematisation in all systems and operational processes of the Company.
- Create and support a common corporate culture among the Group
- Promote and foster talent attraction and retention
- Define and implement our equity, diversity, inclusion and gender equel program
- Create and support opportunities for new knowledge, professional skills enhancing
- Respect health and safety of our employees at their workplace.
- Act ethically, respecting compliance and regulation standards
- Define and implement our equity, diversity, inclusion and gender equal program
- Contribute to smart digitalization and enhancing of IT enviroment with high-quality solutions
- Manage the risks and opportunities of our activity
- Create and support strong relationships with all stakeholders and alliances with third parties, contribute to their growth
- Plan and manage our environmental sustainability strategy, involve people to join it
- Mitigate our impact to climate change inside and outside the Group by managing responsibly and circularly the use ofresources within LeverX Group
- Respect and minimize our impact on natural spaces and biodiversity
The capacity to have an impact in the application of the policy, will vary on the basis of the existing management capacity, as well as on the stakeholders involved in each of the material aspects. Moreover, each Business Unit and Functional Area,
in coordination with the Marketing Department of LeverX Group, is responsible for implementing the corresponding actions for compliance with the commitments outlined in this policy, as well as the specific linked procedures and regulations.
APPROVAL, MONITORING AND CONTROL
One of the responsibilities of the LeverX Group Board of Directors is the approval of the corporate policies, and as a consequence of the ESG Policy, as well as of any substantial modifications made to it.
The Management Team of LeverX Group undertakes to review the ESG Policy periodically, adapting it to new organizational, environmental or market requirements which may arise, as well as to communicate it to the organization and to make it available to interested parties at all times.
The objectives in terms of ESG defined by the Company are consistent with this Policy, aligned with LeverX Group's process model, reviewed annually by the Management Team and updated according to their evolution and environment. Likewise, all departments in LeverX Group participate directly and indirectly in the implementation of actions and the monitoring thereof, in accordance with the corresponding sphere of competence and the relationship thereof with the material aspects in ESG-related matters.
Annually, the entire organisation will be involved in process of collecting data and evidence of progress in the field of ESG, which are reflected in the Integrated Annual Report in which the results of the performance analysis are collected for each of the economic, environmental, social and governance aspects.
The Integrated Annual Report is of a public nature.
It is prepared following the standards of such documents and can be reviews every year by LeverX Group’s ESG team.
