Gender Equality Policies

La gway S.r.l., which operates in the field of application design and development, as well as in the provision of systems
information technology, system support services, and IT consulting, is committed to upholding impartiality and inclusivity, fairness and transparency, respect for and the empowerment of its staff, the protection of individuals, and the fight against all forms of violence and discrimination, with the aim of reducing the gender gap, leading to improvements in employee well-being as well as ethical impacts, and generating a positive market image resulting from the adoption of robust protections for the rights and freedoms of its employees.

The Gender Equality Management System (SGPG), in accordance with the UNI/PdR 125:2022 standard, is the tool that ensures the presence and professional growth of women, promoting an inclusive culture and implementing processes designed to foster women’s empowerment and equal opportunities. gway S.r.l. has developed a human resources development and management strategy based on meritocracy and equality, designed to value the uniqueness of individuals and ensure access to the same opportunities for professional growth—including training programs— regardless of gender or the role held within the organization.

The dedication with which Gway S.r.l. focuses its efforts to ensure that the SGPG meets the requirements specified by the Standard is inspired—in line with the European Union’s objectives regarding gender equality—by the pursuit of the following goals: increasing women’s participation in the labor market; reducing the pay and pension gaps between men and women; protecting parental rights and promoting work-life balance; promoting gender equality in decision-making; combating stereotypes and gender-based violence, as well as protecting and supporting victims of such abuses.

The requirements for implementing gender equality policies are consistent with the Organization’s objectives and operational procedures. In fact, the SGPG encompasses the rules of conduct, processes, infrastructure, and chain of responsibility aimed at promoting gender equality. Even in marketing and communication activities, such as public events, gway S.r.l. is committed to always acting in a professional and engaging manner, taking the utmost care to avoid gender stereotypes based on subject matter expertise and to promote women’s contributions in the workplace.

To facilitate the achievement of the stated principles and objectives, the Company considers the adoption of the SGPG and its continuous improvement to be essential. Performance indicators for each of the main thematic areas are described in the System documentation and supported by specific policies and procedures.

The definition of roles and responsibilities provides the framework within which the SGPG has been implemented and is dynamically updated in response to the ongoing evolution of that framework. Other key elements of this Policy include the procedures related to the topics outlined in the Strategic Plan, along with specific KPIs, which explain how the Organization is making progress toward its established gender equality goals.

La gway S.r.l. raises awareness among its staff and stakeholders to ensure their conduct aligns with the guidelines set forth in this Policy and in the Management System that implements it. To this end, recognizing the importance of fostering a positive internal culture, gway S.r.l. takes appropriate measures to inform all staff and also promotes behaviors and language that ensure an inclusive and equitable environment, with the aim of eliminating stereotypes, discrimination, and all forms of physical and verbal abuse.

Management has identified the Head of the Gender Equality Management System (RSGPG) as the person responsible for managing the SGPG; this position is designated at the R1 Group level and is common to all Group companies. Furthermore, in order to establish an active oversight mechanism regarding gender equality, it has set up specific reporting channels, including the internal reporting channels provided for by Legislative Decree 24/2023 (whistleblowing), so that situations not in line with the aforementioned corporate principles can be reported—while respecting the confidentiality of the whistleblower—and, for matters pertaining to gender equality, brought to the attention of the Gender Equality Steering Committee, which was also established at the R1 Group level.

This policy, within the broader framework of the Organization’s strategic guidelines, is periodically reviewed to take into account any changes, in collaboration with the R1 Group’s Gender Equality Steering Committee, as well as to establish and periodically review gender equality objectives.

Rome, October 1, 2026
The Administrator
Diego Barbarani