1. General Principles and Commitment

Valuing diversity and inclusion are a priority commitment of BUGNION Spa, to support a work environment that is stimulating, inclusive, respectful of all forms of diversity as well as participatory, inspired by principles of fairness, freedom and dignity in professional relations, and free of collective and individual discriminatory behaviour.

This Policy, in line with the Code of Ethics, formalises BUGNION’s principles on diversity, fairness and inclusion, which endorse the values expressed:

• by the Constitution of the Italian Republic;
• by the United Nations International Declaration of Human Rights;
• by the Declaration on Fundamental Principles and Rights at Work of the International Labour Organisation (ILO) and its applicable conventions;
• by the European Convention on Human Rights;
• by the UN and OECD Conventions on the rights of women, children and persons with disabilities and on combating racial and gender discrimination.

The Policy aims to prevent and counteract anything that may hinder the realisation of a work environment in which all diversity can be welcomed and valued, promoting the well-being of people and highlighting their individual contributions.

2. Allocation of responsibility

Responsibility for the implementation of this policy lies with a DE&I/Gender Equality Committee, consisting of: Company Chairman, Vice Chairman General Manager, Human Resources Manager, Personnel Manager and Personnel Administration Associate.

3. Perimeter of application

The Policy applies to all persons working within the company and on its behalf, irrespective of their contractual status, including trainees, apprentices, clients, suppliers, partners and in general all persons having relations with BUGNION.

A culture of diversity that, with an inclusive logic, aims to value all differences as activators of added value and innovation, and is based on the recognition of the dignity and unique value of each person.

Bugnion aims to play a social role in favour of the protection of human rights and the inclusion and respect of diversity, seeking to have a positive effect on the respect of human rights by the organisations it works with.

4. Qualitative and quantitative objectives

Diversity, equity, inclusion and gender equality policies aim at the following qualitative objectives:

• to prevent discrimination at the selection stage, enhance specific skills and talents, and promote training, which underpins any strategy for the development of people;
• to ensure that everyone has access to fair opportunities for professional growth, regardless of their role in the organisation.

Bugnion and the DE&I/Gender Equality Committee set a quantitative target:

• To deliver an annual survey on diversity, equity and inclusion to the entire corporate population to take a snapshot of the level of awareness and knowledge of these key issues.

Should the results of the survey reveal gaps in knowledge and/or problems, the DE&I Committee will take it upon itself both to carry out any training/information measures and to address, by initiating the appropriate investigations, any problems that may emerge.

5. Diversity, equity and inclusion programmes

BUGNION’s commitment to the issues of diversity, equity and inclusion focuses on four main pillars:

Gender, generational, ability and cultural diversity.

BUGNION is also committed to using dignified, inclusive and neutral language with the intention of avoiding any form of discrimination.

Targeted actions

Bugnion organises various information/updating events on the company’s activities that have concerned, concern and will concern the issues of gender, generational, ability and cultural diversity. Specifically:

• For years, four on-line LIVE events per year have been organised, to which all employees and collaborators are invited and during which topics/news/organisational changes of major importance for the company population are shared.
• Occasionally, when the need arises, meetings on functions and/or new processes are organised in the various offices.
• In November, it is customary for all new employees of the previous 12 months to be invited to an in-person training/information course.

Gender diversity

Bearing in mind that at a national level in both public and private company workforces, the prevalence of personnel is male, and that this historically stems from structural and socio-cultural reasons, BUGNION undertakes to contribute, as it has done so far, to balancing this situation, through the following actions:

• drawing up a specific Gender Equality Policy
• implementing a selection process that is fair (see selection grid) in that it is based on skills and suitability for the role;
• designing and implementing up-skilling and re-skilling training and information pathways, oriented at providing opportunities for development in every professional field, regardless of gender, generation, ability and culture (see Training Catalogue 2024, resulting from a bottom-up survey of training needs, currently being revised for the new 2025 training plan).

On a cultural level, BUGNION is also engaged in awareness-raising initiatives at all levels with actions aimed at overcoming stereotypes and unconscious biases, and promotes welfare policies and actions, aimed at fostering a beneficial work-life balance (see ‘smart working’ (remote) regulation), maternity protection and the sharing of family and care responsibilities.

BUGNION undertakes, as far as possible, to ensure a balanced gender representation among speakers at round tables and events.

Finally, BUGNION is committed to combating gender-based violence in all its forms through awareness-raising actions in line with the specific Gender Equality Policy, which lays down zero tolerance of harassment and violence in the workplace.

For this reason, Bugnion has also equipped itself with specific channels through which reports of misconduct can be addressed (guaranteeing maximum confidentiality of the reporter).

Generational diversity

BUGNION considers the coexistence of different generations within the organisation to be a value for all, as it provides the opportunity to open up to change, to face the challenges associated with the evolution of society and the market, and to drive innovation. In fact, the different generations bring with them knowledge, experiences of work, roles and relationships that are unique to each ‘age’.

In order to facilitate cooperation and successfully integrate different generations in the professional sphere, Bugnion has always believed in and promoted the creation, wherever possible, of teams and/or workplaces with people of different ages and experiences.

For BUGNION, formal and informal training and on-the-job coaching are the fundamental tools for promoting communication and the mutual exchange of experiences between generations, stimulating a productive exchange and transfer of knowledge and skills so that differences are recognised and accepted.

Diversity of abilities

BUGNION will continue to foster and implement a work environment that promotes accessibility and the adoption of practices aimed at socialisation, integration and personal well-being.

BUGNION upholds the need to value each individual in his or her specificity and to seek to break down all kinds of sensory or physical barriers that limit inalienable rights, bringing about the changes necessary to improve the living conditions of persons with disabilities.

BUGNION also considers it necessary to shift the focus from disabilities to abilities, enhancing the capabilities of each individual including through training actions to enrich knowledge and skills.

The objective is to welcome the needs of people in situations of distress, through the activation of active listening moments by both the direct managers on an ongoing basis and cyclically by the Human Resources Office, talks that can also be aimed at promoting integration and improving the work situation.

The company is committed to continuing to support sports and recreational/cultural activities aimed at the inclusion and enhancement of people with different abilities, e.g., Baskin, PizzaAut, Agorà (Inclusive Judo).

Cultural diversity

Cultural diversity stemming from ethnic origin, nationality, idiom, religious beliefs, marital status, sexual orientation and political convictions represents an opportunity for personal and corporate enrichment through the mutual exchange of views.

In line with the principles of the Code of Ethics, BUGNION considers the enhancement of the cultural diversities present in the company one of its fundamental objectives and is committed to fostering the integration of all existing cultures.

It is therefore BUGNION’s commitment to combat all forms of discrimination and prejudice, to provide all people with opportunities for professional growth and to create a work environment that welcomes each person, recognising their value and respecting their differences.

The commitment of the entire organisation is fundamental to the application of all the principles set out in this Policy.

6. Review procedure

The DE&I Policy, like the Gender Equality Policy, is subject to annual review by the specific Diversity, Equity and Inclusion/Gender Equality Committee and according to the steps outlined below.

Should the need arise, the DE&I/Gender Equality Committee may make changes, additions and/or updates that will be submitted to the Board of Directors (henceforth BoD) for final approval, prior to presentation to the entire corporate population.
The review is conducted through the following process:

6.1 Identification of revision needs: the DE&I/Gender Equality Committee is responsible for identifying factors requiring revision – regulatory changes, changes in the business environment or reports.

6.2 Preliminary review: the working group ensures compliance with applicable laws and regulations, as well as gathering internal feedback.

6.3 Content review: the working group incorporates the necessary changes and verifies that the changes and possible new sections fit organically into the document.

6.4 The document is then submitted to and approved by Bugnion’s Board of Directors.

6.5 Implementation: the updated DE&I Policy is communicated to all employees, highlighting those affected by the changes, and a training/information session on the main changes is also held, if necessary.

Update 1.02 dated February 2025
Update 1.03 dated 19/05/25