CORPORATE PROCEDURE P&O 008
HR Policy for Gender Equality

Company: OTB Group
Issued by: People & Organization
Approved by: Governance Committee
Type: Corporate Procedure
Effective as from: September 2023
Recipients: OTB Group employees

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TABLE OF CONTENTS
1 FOREWORD

32 PRINCIPLES OF CONDUCT52.1 SELECTION AND RECRUITMENT

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2.2 PERFORMANCE AND TALENT MANAGEMENTSYSTEMS

62.3 TRAINING AND DEVELOPMENT

72.4 REMUNERATION

72.5 WORK - LIFE BALANCE

82.6 TURNOVER ANALYSIS

92.7 PARENTING, CAREGIVING

92.8 PREVENTING AND REPORTING WORKPLACEHARASSMENT10

2.9 LANGUAGE

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3. RESPONSIBILITY AND MONITORING10Page 2 of 11
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1. Foreword
The OTB Group (hereinafter also 'the Group') is committed to promoting aculture of gender equality in all its operations, recognising everyone's value
and contribution regardless of their gender, sexual orientation, age,nationality, religion, physical, cognitive or other abilities or health status.
The HR Policy on gender equality, defined by Top Management incollaboration with the Diversity, Equity & Inclusion Committee (hereinafteralso 'DEI Committee') aims at ensuring a fair, safe and stimulating
environment for all employees, collaborators and partners.
Inclusion is a fundamental principle inspiring the Group, which promotes
diversity as a strategic aspect for innovation, creativity and competitiveness,
and which is committed to enhancing and protecting it in every area.
The Policy and compliance therewith are the responsibility of the People &Organization Department in collaboration with the DEI Committee and theperson responsible for DEI issues for the Group, appointed by the Committee.

1.1 Recipients and relevant standards
This Policy is intended for all OTB Group collaborators and is communicatedand disseminated internally to all Group employees, other than being madeavailable on the OTB Group's corporate intranet platform to all stakeholders.
The Parent Company and other Companies subject to the OTB Group's
direction and coordination undertake to implement and adopt this Policy,
without prejudice to their own specificity and independence.
The Policy refers to and applies along with the following internal documents:-Code of Ethics;-DEI Policy;-Diversity, Equity & Inclusion Plan;-Diversity, Equity & Inclusion Committee Regulations;Page 3 of 11
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-Procedure for the anonymous reporting of unlawful conduct, regulated

in the Code of Ethics.
The relevant external standards are:--Uni/PdR 125:2022
ILO (International Labour Organization)
UNGC (UN Global Compact)
Law 162/2021 on gender equality within companies

DEFINITIONS AND REFERENCESTERMOTB Group

MEANING
It is the set of legal entities consisting of the OTB Parent
Company and the companies controlled thereby, whether
directly or indirectly (Global Business Headquarters,Branches, sourcing, manufacturing, business units,financial units, non-profit organizations, etc.).

Diversity, Equity & Inclusion (DEI)

These three terms are the pillars of companies' humanrights policies: the first stands for acceptance of all
genders, ages, etc., the second means equal treatment
for all and the third signifies the involvement of all
categories in company dynamics.

Code of Ethics

A document defining the set of principles of conduct to beobserved at work.

DEI Policy

A document defining the guidelines that determine theOrganization's commitment to issues related to genderequality and the enhancement of diversity, equity andinclusion.

Diversity, Equity & Inclusion Plan

A document that defines the company's short-, mediumor long-term strategy in relation to gender equality, theenhancement of diversity, equity and inclusion.

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Diversity,Equity&Committee Regulations

Diversity,EquityCommittee&Inclusion

A document that defines the guidelines for the monitoringand management of the Diversity, Equity & Inclusion
Committee

A body within the Organization that is required to carryout assessments related to the management andInclusionmonitoring of issues connected with diversity, equity,inclusion and gender equality.

Top Management

This means the Chief Executive Officer of the Parent
Company and those reporting directly thereto, as well as
the Chief Executive Officers of BWs and Regions

Caregiving

Caregiving and assistance provided to other people

2. Principles of conduct
The Group operates in compliance with applicable regulations in connection
with diversity, equity and the promotion of inclusion.
In this Policy the OTB Group identifies the principles of conduct to be adoptedto ensure respect for gender equality within corporate processes for themanagement of human resources. The areas that identify these principles
are reported and emphasised in this document, and specifically concern:•Selection and recruitment;•Performance and Talent Management systems;•Training and Growth;•Remuneration;•Work - life balance;•Turnover analysis;•

Parenting, Family and Caregiving;

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•Preventing and reporting workplace harassment;•Inclusive language.

2.1 Selection and Recruitment
The OTB Group is committed to attracting and recruiting people from different
backgrounds and realities and to ensuring gender-balanced recruitments at
all organisational levels. The Group also makes sure that job descriptions aregender-neutral.
During the selection process, practices are adopted to avoid gender discrimination,
specifically focusing on eliminating bias and promoting gender balance in candidate
short-lists, and on the gender-neutral definition and communication of roles andduties.

The OTB Group assesses candidates on the basis of their professional
background, skills, competences and qualifications, without any genderbased discrimination.

During interviews, candidates are not asked about

potentially discriminatory topics, such as marriage, pregnancy or family care.
The company also ensures that those involved in the selection process areadequately trained on gender equality and on any cognitive biases that may
negatively influence the assessment of candidates.

2.2 Performance and Talent Management systems
The OTB Group is committed to enhancing people's potential, ensuring equal
opportunities for professional growth without any gender distinction. To thisend, it adopts transparent and uniform standards in its Performance
Management and Talent Management processes.
The Performance Management system fosters dialogue between managers
and employees, creating a culture geared towards enhancing people's skills,
without any gender distinction. In the final definition of evaluations, the People

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& Organization department checks that such evaluations are not influenced
by gender bias.
In addition, the OTB Group will include Diversity, Equity and Inclusion issues

within its leadership skills model, which is one of the performance systemevaluation standards.
The Talent Management system is based on assessing the skills,
performance and growth potential of employees, without any gender-based
discrimination or unequal treatment so as to ensure opportunities for
professional growth and promote the best talent.
By pursuing gender-balanced succession planning and career advancement
activities, the OTB Group supports the career development of women so as
to foster their presence in responsibility and leadership roles and achieve
gender balance in executive positions.

2.3 Training and Development
The design and assignment of training and development programmes, at alllevels, follows principles of inclusion and equality so as to avoid these being
affected by gender bias and stereotypes. Moreover, training processes andopportunities must ensure fair and equal participation of both genders.
Training is planned for all employees, aimed at raising awareness in theorganization on the enhancement of differences, gender equality, inclusion
and the impact of these issues on business. Specifically, everyone within thecompany participates in training sessions focused on issues related tounconscious bias and the ability to communicate in an inclusive manner.

2.4 Remuneration
The OTB Group acknowledges that fair and transparent remuneration isessential to ensure an inclusive and merit-based working environment as wellas to attract, motivate and retain the best talent.
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The OTB Group believes that all employees should be paid according to theirskills and qualifications and should be evaluated according to theircontribution and potential, without any gender-based discrimination or any
other discriminating factor.
To ensure pay equity, transparent and objective standards are applied inannual remuneration review processes and in performance and talentmanagement

systems.

The OTB Group monitors data on employees' remuneration and benefits,progressively correcting any pay inequalities for equal work or equivalentroles that appear unjustified or potentially due to gender bias.
Lastly, the Group is committed to periodically informing employees about thecompany's remuneration policies, also with respect to benefits, bonuses andwelfare programmes. Therefore, welfare initiatives take into account theneeds of people of all kinds and ages.

2.5 Work - life balance
The OTB Group is committed to adopting measures ensuring work-lifebalance for all employees, also through specific agreements which, whereapplicable and in compliance with organisational needs and possibilities andthe relevant regulatory framework, allow for part-time work for thoserequesting it; it also offers flexible working hours by communicating simple
and accessible rules and procedures to use this option.
The Group periodically reviews the flexibility needs of employees, offeringsmart working options or other forms of flexible working, and promoting,where possible and on the basis of the employee's role within theorganization, the possibility of holding work meetings at times that arecompatible with work-life balance.

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2.6 Turnover analysis
The Group regularly monitors Turnover data by gender in order to analysetrends, check for irregular terminations of employment and promptly ensure
actions for improvement and prevention. Particular attention is paid toterminations of employment for reasons that might be gender-related, (e.g.
employees not returning to work after maternity leave, difficulties in ensuring
work-life balance, etc.), so as to monitor and prevent potentiallydiscriminatory conduct. The OTB Group has thus defined an Exit Interview
process that ensures the prompt detection of terminations of employment for
conduct not in accordance with the principles included in this Policy and in
the Diversity, Equity & Inclusion Policy.

2.7 Parenting, Caregiving
The OTB Group adopts a flexible working policy (e.g. smart working, flexible
working hours) that is designed to promote the well-being of its employees inevery area and stage of their lives, whilst ensuring the achievement of theirwork and professional growth goals.
The OTB Group also promotes parenting as a value and source for theacquisition of new skills and encourages the sharing of family responsibilities.
The OTB Group is thus committed to implementing initiatives and training that
support motherhood, fatherhood and, more generally, caregiving, assisting
both new parents and people managers in the various stages of parental
leave and arranging for back-to-work meetings for new parents.

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2.8 Preventing and reporting workplace harassment
The OTB Group combats harassment in the workplace with a monitoring,prevention and training plan, in order to promote a culture of respect andresponsibility among employees and to educate staff, at all levels, on theinadmissibility of any form of violence.
The OTB Group guarantees the possibility for employees to report any form of noninclusiveness and behaviour that does not comply with the Code of Ethics by sendingan anonymous report to the mailbox (codeofethics@otb.net) as indicated inArticle 5 of the Code of Ethics. Reports, where grounded, are submitted to theDEI Committee to identify any remedies.

2.9 Language
To communicate in an effective and respectful manner, both inside andoutside the organization, the OTB Group requires the adoption, in all formsof language (whether written, oral or non-verbal), of an inclusive language
which takes into account everyone's point of view and sensitivity, different
identity and personal characteristics, avoiding non-inclusive and potentiallyoffensive expressions. Where possible, a neutral language should be used.
The Group fosters initiatives to spread the culture of inclusive language
among employees.

3. Responsibility and MonitoringThis Policy is designed to promote the evolution of corporate culture in orderto foster gender equality throughout the organization. Hence all employees
are involved and play an active part in achieving their goals.

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The People & Organization department, the Group's Top Management andthe Diversity, Equity & Inclusion Committee (DEI) are responsible for thedissemination and implementation of this Policy, which is fully incorporated
into the broader Diversity, Equity & Inclusion strategy and the OTB Group'sSustainability strategy. The People & Organization department, incollaboration with the DEI Committee, monitors and checks every year
whether the processes listed in the previous paragraphs are consistent with
the Policy for Gender Equality, also by using specific indicators andmonitoring the same. Action plans for realignment to established practices
and objectives are also defined in case of distortions or critical issues in orderto ensure continuous improvement.

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