Diversity, Equity & Inclusion (DE&I) and Equal Pay Policy

1. Statement of Intent and Purpose

Clivet Spa recognizes that diversity, equity, and inclusion are fundamental drivers of innovation, growth, and corporate well-being. We are committed to creating a work environment where every person feels valued, respected, and empowered to express their full potential, regardless of gender, gender identity or expression, sexual orientation, age, ethnic or national origin, religion, disability, neurodivergence, union or political affiliation, or any other characteristic protected by the laws of the countries in which we operate.

Clivet Spa actively promotes equal treatment and opportunities, committing to removing any cultural, organizational, or physical barrier that limits the full expression of individuals and gender equality at all levels of the organization.

2. Scope of Application

This policy applies to all people working for or with Clivet Spa, including temporary and permanent employees, executives, interns, external collaborators, job candidates in the selection phase, and suppliers operating along the entire supply chain.

3. Core Principles

3.1 Gender Equality and Equal Opportunities at All Levels

Balanced Representation: Clivet Spa pursues a balanced gender representation at all levels of the organizational chart, actively combating both horizontal occupational segregation (e.g., gender imbalance in specific functions) and vertical segregation (e.g., absence of women in managerial and executive roles) in line with the principles of fairness and transparency set out by European and normative frameworks.

Impartial Selection Processes: All job postings and role descriptions are drafted using inclusive and gender-neutral language. Selection panels for managerial and leadership positions must aim for a balanced gender representation among eligible candidates.

Transparent Pay Ranges: In compliance with EU Directive 2023/970, every job posting or formal offer will clearly and transparently indicate the pay scale or the expected starting salary for the role.

Ban on Salary History: During the recruitment phases, recruiters and hiring managers are strictly prohibited from asking candidates for information regarding their current or past compensation.

Professional Development and Leadership: Training programs, succession plans, and corporate career paths are structured to ensure equal access. Clivet Spa implements specific programs for female leadership development and mentoring to overcome existing glass ceilings.

Objective Evaluation Criteria: Performance evaluation and career advancement processes are based exclusively on objective, measurable, and merit-based criteria, free from any implicit or explicit gender bias.

3.2 Pay Equity and Transparency (Equal Pay for Work of Equal Value) (EU Directive 2023/970)

Principle of Equality: Clivet Spa guarantees equal pay for male and female workers for the same work or work of equal value.

Right to Information: Every employee has the right to know the criteria used to determine their pay and career progression, as well as to request data on the average pay level for their professional category, disaggregated by gender.

3.3 Protection of Minors and Minimum Age Requirements (EU Directive 94/33/EC)

Employment Standards: Clivet Spa condemns any form of child labour exploitation.
The minimum age for employment in any European location of the Group is set at 16 years (or higher, if the national law of the reference country requires a higher age for the completion of compulsory education).

Internship and Apprenticeship Programs: Any educational projects or school-work transition programs aimed at minors under 16 (but never under 15) must be carried out in total compliance with national laws regarding compulsory education and the protection of minors, and must not involve night shifts, hazardous, or heavy labour.

3.4 Inclusive Work Environment and Respect for Diversity

Reasonable Accommodations: We are committed to removing architectural and digital barriers, ensuring the necessary tools (hardware, software, flexible hours) for colleagues with disabilities or neurodivergence needs.

Inclusive Parenting: Parental leaves and care leaves are guaranteed to all parents, regardless of gender and family structure (including adoptive, foster parents, and same-sex couples), supplementing legal protections with flexible working arrangements upon return.

Gender Transition: Clivet Spa supports employees undergoing a gender transition process, guaranteeing confidentiality, respect for the chosen name in internal IT systems (e.g., ID badge, company email), and access to leaves for medical reasons related to the transition.

3.5 Freedom of Association and Social Dialogue

Right of Association: Clivet Spa recognizes and respects the right of all employees to form trade unions or to join them freely, as well as to participate in union activities and collective bargaining, without fear of discrimination, retaliation, or career disadvantage.

Corporate Neutrality: The company adopts a stance of absolute neutrality and guarantees that union affiliation will in no way be used as an evaluation criterion in hiring, promotion, remuneration, or termination processes.

Collaboration and Industrial Relations: Clivet Spa is committed to maintaining an open, constructive, and transparent dialogue with employee representatives (local, national, and with the European Works Council, where present). We consider social dialogue an essential tool to guarantee a fair working environment and the effective application of this policy.

4. Governance, Whistleblowing Channels, and Sanctions

Reporting Channels: Any discriminatory behavior, anti-union conduct, harassment, or violation of this policy (including principles of pay transparency or unauthorized employment of minors) can be reported confidentially and without fear of retaliation through the company's Whistleblowing platform.

Sanctions: Violations of this policy will be treated with the utmost seriousness and may result in disciplinary action, in accordance with applicable collective bargaining agreements and local laws.