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ESG POLICY

PURPOSE AND SCOPE OF APPLICATION

Purpose
This document establishes the basic guidelines and courses of action regarding LeverX ESG strategy. This approach allows the formalization and implementation of the ESG concept within the framework of the organization, its communication to stakeholders, and the progressive systematization in all systems and operational processes of the Company.
Scope of application
This policy mandatorily applies to all companies controlled by LeverX — specifically LeverX and Emerline. The entire team is responsible for the application of this policy.
LeverX

Companies in which LeverX possesses or may possess control, either directly or indirectly, 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 internal regulations and corporate policies.

LEVERX VALUES

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Reliability

LeverX companies are deeply immersed in the client's business. From the very first stages of cooperation we begin to share common goals. In this way, the Company ensures the successful completion of each project for each client.

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Honesty and integrity

Honesty, transparency and integrity in our work is what makes companies worldwide trust us.

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Noteworthy and professional

Before project launch, the LeverX Team carefully analyzes the business needs of each client and takes into account all expectations. Thus, we ensure the successful development and implementation of the product.

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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.

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Environmental footprint

We have already established a smooth process of providing high-quality IT-solutions and services on a remote basis to meet challenging global conditions, reduce environmental impact, and contribute to a sustainable and prosperous business future.

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.

The chief executive of each company of LeverX 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 organization's activities and in all countries in which it operates, both directly and indirectly. It covers the entire life cycle of the LeverX 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)
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In line with these standards, LeverX commits to comply with all requirements, which applies to all Company’s activity.

In accordance with these standards, LeverX recognizes 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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Environment

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LeverX is committed to the protection and preservation of the environment where the Company activities occur. This involves preserving biodiversity and conserving the ecosystem, using renewable energies, mitigating and adapting to climate change, and contributing to sustainable development through an efficient use of resources.

LeverX is committed to the protection and preservation of the environment where the Company activities occur. This involves preserving biodiversity and conserving the ecosystem, using renewable energies, mitigating and adapting to climate change, and contributing to sustainable development through an efficient use of resources.

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Gender Equality

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

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

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Partnerships for the goals

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The identification of the organization'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 organization'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

Based on the above basic principles, LeverX defines the following lines of action, within which are framed the strategic principles developed by the Company to achieve its objectives in terms of ESG-related matters.

IN THIS REGARD, THE STRATEGIC AREAS WHICH ARE CONTAINED IN THE ESG MASTER PLAN, ARE THE FOLLOWING:

1

People management:

“Boosting employee talent that includes diversity, inclusivity and gender equality”

2

Integrity and transparency:

“Showing what we are, acting with integrity and transparency”

3

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 acquires the following commitments. These, in turn, contribute to the achievement of various targets of United Nations Sustainable Development Goals (SDGs) 4, 5, 17:

Boosting talent of employees, being diverse, inclusive and gender equal

This document establishes the basic guidelines and lines of action regarding the LeverX ESG strategy. This allows the formalization and implementation of the concept of ESG within the framework of the organization, its communication thereof to stakeholders, and the progressive systematization in all systems and operational processes of the Company. These guidelines are as follows:.

  • Create and support a common corporate culture among the Group
  • Promote and foster talent attraction and retention
  • Define and implement equity, diversity, inclusion and gender equal program
  • Create and support opportunities to acquire new knowledge and enhance professional skills
  • Respect the health and safety of employees at their workplace.
Showing what we are by acting with integrity and transparency
  • Act ethically, respecting compliance and regulation standards
  • Define and implement our equity, diversity, inclusion and gender equal program
  • Contribute to smart digitalization and enhance the IT environment 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 and contribute to their growth
Growing with a long-term sustainable environmental approach
  • Plan and manage our environmental sustainability strategy and invite people to join it
  • Mitigate our impact to climate change inside and outside the Group by managing the use of resources within LeverX responsibly and circularly
  • 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, 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 Board of Directors is to approve 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 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 the LeverX process model, reviewed annually by the Management Team and updated according to their evolution and environment. Likewise, all departments in LeverX 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 organization will be involved in the process of collecting data and evidence of progress in the field of ESG. These 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 reviewed every year by the LeverX ESG team.

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