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Last Updated: September 24, 2025

Gender Equality & Anti-Harassment Policy

Legal entity: Digital Trade, poslovne storitve d.o.o., Ajdovščina 4, 1000 Ljubljana, Slovenija

Version: 1.1

Effective date: 24 September 2025

Owner: Management / HR Responsible Person

Equality & Reporting Contact (confidential): office@digitaltrade.com

Review: Annual

1. Purpose

Digital Trade, poslovne storitve d.o.o. commits to gender equality, equal opportunities, and a safe workplace, with zero tolerance for discrimination, harassment, sexual harassment, bullying, or gender-based violence connected to work (including online). We apply the EU approach of gender mainstreaming plus targeted measures and an intersectional lens (recognising compounded inequalities).

2. Scope

This policy applies to all employees, managers, interns, candidates, freelancers and contractors working under company direction, and (where relevant) suppliers or partners interacting with our workplace or work platforms.

3. Principles & Commitments

3.1 Equal treatment and opportunity

  • No discrimination based on sex, gender identity or expression, pregnancy, parenthood or care duties, marital status, or any other protected characteristic.
  • Equal access to recruitment, training, project allocation, promotion, leadership opportunities, and working conditions.

3.2 Equal pay and pay fairness

  • Equal pay for equal work or work of equal value.
  • Documented, objective pay-setting criteria (role scope, skills, experience, performance).
  • Annual pay fairness check with documented outcomes and corrective actions where needed.

3.3 Work-life balance

  • Flexible work arrangements where feasible (working hours, hybrid or remote work, predictable scheduling).
  • No negative treatment for using lawful leave or flexibility related to parenting or caregiving.

3.4 Prevention of harassment, sexual harassment, and gender-based violence

  • Prohibited conduct includes unwanted sexual conduct; sexist or gender-degrading behaviour; coercion; stalking; intimidation; bullying; retaliation; and technology-facilitated harassment linked to work.
  • The company will act promptly to protect affected persons, stop misconduct, and prevent recurrence.

4. Roles & Responsibilities

  • Management: accountable for implementation, resourcing, and enforcement.
  • Equality & Reporting Contact: receives reports, coordinates response, maintains policy and training records, and ensures confidentiality and documentation.
  • Managers: apply objective criteria in recruitment, pay and performance reviews; maintain respectful teams; act immediately on concerns.
  • All personnel: behave respectfully, complete required training, and report concerns in good faith.

(If the company grows) Management may appoint an Equality Committee (management and employee representatives) to support monitoring and improvements.

5. Reporting and Whistleblowing (Confidential)

Reports can be submitted confidentially to the Equality & Reporting Contact: office@digitaltrade.com.

Non-retaliation: retaliation against anyone who reports a concern or participates in an investigation is prohibited and may lead to disciplinary action up to termination.

Minimum process

  • Acknowledgement within 5 working days (where identity is known).
  • Initial assessment begins within 10 working days.
  • Confidential investigation with impartial decision-making and a documented outcome.
  • Measures may include protection steps, mediation only when appropriate, training, corrective action, disciplinary action, and reporting to competent authorities where required.

6. Training and Awareness

  • Policy briefing during onboarding.
  • Annual refresher for all personnel.
  • Additional manager training on bias-aware hiring, inclusive leadership, and harassment prevention and response.

7. Monitoring and Records (privacy-respecting)

To demonstrate operational compliance, the company keeps proportionate records, such as:

  • Workforce snapshot by role level (where feasible).
  • Training completion.
  • Annual pay fairness check note.
  • Anonymised incident log (type, resolution, corrective action).

8. Approval

This policy is approved by the management of Digital Trade, poslovne storitve d.o.o. and is effective from 24 September 2025.

Digital Trade, poslovne storitve d.o.o.
Ajdovščina 4, 1000 Ljubljana, Slovenija

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