Diversity, Equity & Inclusion (DEI) policy

Purpose

UP Catalyst is committed to fostering, cultivating and preserving a culture of diversity, equity and inclusion. Our human capital is the most valuable asset we have. The collective sum of the individual differences, life experiences, knowledge, inventiveness, innovation, self-expression, unique capabilities and talent that our employees invest in their work represents a significant part of not only our culture, but our reputation and company’s achievement as well.

We embrace and encourage our employees’ differences in age, color, disability, ethnicity, family or marital status, gender identity or expression, language, national origin, physical and mental ability, political affiliation, race, religion, sexual orientation, socio-economic status, veteran status, and other characteristics that make our employees unique.

The Diversity, Equity & Inclusion policy sets out the principles and requirements that are based on our Company Values ​​and by which UP Catalyst will enhance diversity, equity and inclusion throughout the organization.

Scope

The policy is applicable- but not limited- to our practices and policies on recruitment and selection; compensation and benefits; professional development and training; promotions; transfers; social and recreational programs; layoffs; terminations; and the ongoing development of a work environment built on the premise of gender and diversity equity.

The policy applies to all employees and anyone conducting work on behalf of UP Catalyst or any of its operating companies.

The main principles of this policy, mentioned in section Purpose, applies internally to employees, but also to all external stakeholders with whom UP Catalyst employees may interact.

Policy

It is an understanding that each individual is unique, and recognition of our individual differences. These differences can include skills, experience, thought, gender, age, disability, ethnicity, cultural or socio-economic background, religion, sexual orientation, political or ideological beliefs as well as other dimensions such as lifestyle and family responsibilities.

At UP Catalyst, we are committed to:

• a workplace which is free from discrimination, harassment, bullying, and victimization
• treating employees fairly and with respect
• a workplace culture that is inclusive and embraces individual differences
• equal employment opportunities based on ability, performance and potential
• awareness in all staff of their rights and responsibilities with regards to fairness, equity and respect for all aspects of diversity
• flexible work practices and policies to support employees and their changing needs
• attraction, retention and development of a diverse range of talented people
• equitable frameworks and policies, processes and practices that limit potential unconscious bias.

We ensure all our people’s policies, systems and practices support a diverse and inclusive culture. Several practices within our organization that support our values are summarized below.

Recruitment, Selection & Promotion

We recognise the value of recruiting, selecting and promoting employees with different backgrounds, knowledge and experience.
We structure our recruitment and selection practices at all levels so that a diverse range of candidates are considered, guarding against any conscious or unconscious biases that might discriminate against certain candidates. We proceed to the following practices regarding our recruitment and selection process:

• We review job descriptions, imagery, and language to eliminate bias and ensure they encourage a diverse range of candidates to apply for available positions.
• We monitor candidate shortlists for diversity in gender, age, culture, capabilities and background.
• We do not ask about criminal history during recruitment unless it is necessary due to the nature of the work or required by law.

Employee engagement

We frequently engage with our employees to understand their views on promoting and managing inclusion and diversity.

We use anonymous, whole-of-company surveys to measure, track and report on our engagement as well as issues such as organizational culture, flexibility, inclusion, and leader’s behavior.

Remuneration

Our role grading and remuneration review processes actively consider equity in both grading and remuneration and we will continue to develop strategies and initiatives to resolve any identified gaps.

At this end, UP Catalyst adopts the following practices for fair and equal remuneration:

• We stay up to date with salary trends in Estonia for similar positions to ensure our compensation remains competitive. We are also developing a structured plan for salary adjustments, which will define the frequency of raises and establish clear criteria for performance-based increases, including maximum percentage increases based on KPIs and performance.

Career development and performance

Employees are encouraged to develop and progress their careers through opportunities that build capability and all employees are supported to participate in career development conversations.

Available opportunities for promotion and transfer are advertised to all employees to enable them to apply for roles and develop their career path. We encourage and reward excellence and performance is measured based on agreed goals to promote equity and remove bias.

Talent and succession planning

Talent and succession planning are core practices within the organization.

Talented individuals are identified based on their performance and potential and divisional reviews ensure that talent and succession decisions are equitable, consistent and aligned to diversity and equal opportunity principles across UP Catalyst.

The talent and succession process is used to identify candidates for leadership development programs and gender diversity is a key consideration during candidate selection.

Equal opportunity training

UP Catalyst offers careers that broaden and deepen our employees’ skills, abilities and knowledge. We design and implement programs that will help build our capability for the future and assist in the development of a broad and diverse pool of skilled and experienced employees, including the skills and capabilities required for senior leadership positions.

The following initiatives are implemented:

• We conduct learning needs analyses to ensure our people capability development plans are aligned with organizational inclusion and diversity objectives.
• We are in a process to put in place a training for our people managers on the importance and value of inclusion and diversity in the workplace.

Flexibility

Our Flexibility practices enables employees to apply for flexible work arrangements, particularly employees with parenting, family, carer, cultural and religious commitments.

To ensure flexibility is implemented equitably, all managers are encouraged to support team members who require flexible working arrangements.

Gender diversity

Gender equality at all levels of the organization is a key component of our Diversity and Inclusion Strategy. At this end, we commit to:

• Employee consultation – employees are consulted annually through surveys, focus groups and forums to gain insight into potential barriers to diversity and issues and opportunities for further action.

Responsibilities

All employees of UP Catalyst have a responsibility to treat others with dignity and respect at all times. All employees are expected to exhibit conduct that reflects inclusion during work, at work functions on or off the work site, and at all other company-sponsored and participative events.
HR is responsible for the correct application of the policy.

Duty to provide explanations

To promote equal treatment and to avoid discrimination, an employer shall inform employees of the rights ensured by this policy and in legal acts within fifteen working days after receipt of a written request.

When a person suspects discriminatory behaviour in professional life, cases in which an employer selects for employment or a position, hires or admits to practical training, promotes, selects for training or performance of a task or sends for training a person of one sex and overlooks a person with higher qualifications and of the opposite sex, in respect of them, the employer is required to provide a written explanation to the person at the person’s request within ten working days as of submission of such written application. In the explanation the employer shall submit the following information concerning the person who was selected:

1. length of employment;
2. education;
3. work experience and other skills required for the work;
4. other skills or reasons which give the person a clear advantage.

Within fifteen working days as of submission of an application, the employer is required to provide a written explanation concerning the activities of the employer to the person who believes that has been discriminated against on a basis specified in this policy or legal acts.

 An employee has the right to demand that the employer explain the bases for calculation of salaries and obtain other necessary information on the basis of which it is possible to decide whether discrimination has occurred.

Within 15 working days after submission of an application, the employer is required to provide an explanation to the person whose application to create working conditions which are suitable for both women and men and enhance the reconciliation of work and family life, taking into account the needs of employees, has been refused or whose flexible working arrangements have been postponed.

The person suspected of discrimination is required to provide a written explanation concerning them activities within fifteen working days after receipt of a written request to the person who believes that has been discriminated against on grounds of any characteristic specified in this policy.

Communication

This Policy is communicated on an annual basis to all employees via the normal UpCatalyst’s channels and the Company’s intranet including Company’s internal rules and is introduced to all new staff at induction. The Policy is also distributed to external stakeholders and is available on UpCatalyst’s website.

Whistleblowing system

Any employee who encounters or believes that encounters a breach of the policy through them own situation or through the situation of a colleague should alert HR.

The employee can either alert HR directly, by the means of their choice (e-mail, telephone, direct messaging, verbally, etc.) or by using the anonymized alert system.

Each alert will then be analysed by HR confidentially and impartially as soon as possible. HR will decide whether it is a genuine breach of policy and will adopt an appropriate response.  The employee who made the notification will receive feedback within two weeks after the notification or, if the case is being processed, within a week after its completion.

Sanctions

In the event of a proven breach of policy or discrimination, the employee may be subject to the sanctions provided by law.

Resolution of discrimination disputes

Discrimination disputes shall be resolved by a court or a labour dispute committee. Discrimination disputes shall be resolved by the Chancellor of Justice by way of conciliation procedure.

Policy revision

This Policy is reviewed by HR and the management at least once a year.

Contact

For more information, please contact HR.
This Policy was last reviewed and approved in July 2024 by CEO.