1 Preamble

“DataPower Srl introduces this Gender Equality and Inclusion Plan as a practical commitment to how we build, sustain and grow our company. Gender equality at DataPower is not a statement of intent; it is a way of working that aligns with our mission, our values and the complexity of the work we carry out for clients across sectors. We operate in demanding, knowledge-intensive domains and set high standards for ourselves and for how we attract, support and advance people. Equal opportunity is the foundation; merit, responsibility and achievement are the drivers. Support, training and knowledge sharing make progress possible; engagement, accountability and responsiveness ensure that progress is real.

DataPower exists to enable better understanding of reality and better decision-making, and this Plan draws on the same evidence-based ethos: we set clear objectives, align them with our culture and operations, and measure outcomes so that commitments translate into tangible improvements. Our work requires a sophisticated, integrated approach to analytics and modelling.

Our team blends seniority and specialism, and the human dimension of our work is decisive: the quality of our services rises or falls with the quality of our people and the environment we create for them. DataPower is an equal-opportunity employer, providing equal chances to all employees and candidates, and we build careers on capability, commitment and outcomes. Hiring, retention and progression are fair and transparent, rooted in the value people bring and the potential they can develop. We pay close attention to role design, career paths, objective criteria for advancement and review processes that detect and correct bias. Equality is both structural and cultural: structures create the conditions for fairness; culture makes fairness the everyday default. We expect leaders at every level to steward both.

We are also a merit-based organisation. Merit at DataPower means the demonstrated ability to take advantage of professional opportunities—learning quickly, applying knowledge responsibly and delivering results that stand up to scrutiny. It includes the willingness to shoulder responsibility, to act with integrity under pressure and to work with colleagues in a way that raises the standard of the team.

Knowledge sharing and training are central. We invest in internal learning so that expertise circulates, practising internally the same skills we offer to clients. Our values emphasise clarity and transparency, and a disciplined assessment of sensitivities and biases and their influence on impact; we bring that mindset to the design of our training and to the evaluation of this Plan. This Gender Equality and Inclusion Plan is a living instrument: it binds leadership to a clear direction, equips managers with concrete practices and gives every colleague a transparent view of what fair opportunity looks like. Anchored in who we are and in the work we do, it is measured, reviewed and improved with the same care we bring to our client engagements. It ensures that our growth—individual and collective—remains grounded in equity, merit and the shared purpose of delivering insight that enables better decisions.”

2 What We Do and How We Do It

DataPower Srl is a fair, respectful workplace. We make that promise real through everyday behaviour, accountable leadership, clear decision-making and open, confidential routes for raising concerns, with firm protection against retaliation. Responsibility for this culture is shared by everyone, beginning with the executive team.

Every colleague has the right to work in safety and dignity, to be treated with respect and to be judged on merit. Discrimination, harassment and bullying are not tolerated. Opportunity to learn, grow and progress is open to all, and decisions that affect people’s careers are based on clear, relevant criteria and explained openly.

Expected behaviour applies to all, leaders first and foremost. We listen actively, speak respectfully and use inclusive language. We share credit fairly, give constructive feedback and challenge bias when we see it. Managers set the tone: they model the standards, intervene early when issues arise and ensure workloads, meetings and development opportunities are allocated transparently.

Decisions on hiring, pay, promotion and project assignment follow documented, skills-based criteria. Rationales are recorded and available on request. Where feedback is needed, it is provided promptly and with a focus on future development.

Raising concerns is safe, confidential and taken seriously. A dedicated reporting channel is available for sensitive matters. Concerns are acknowledged promptly and handled within defined timelines. Retaliation is prohibited; any attempt to disadvantage someone for speaking up will be treated as misconduct.

Accountability is shared and visible. Line managers are responsible for implementation in their areas and for fair access to opportunities and training. Every colleague has a duty to uphold the standards, complete required training and contribute to a culture where respect is the norm. Oversight includes periodic reviews of outcomes and processes to identify and correct bias.

Equality of treatment is grounded in merit. Our goal is a culture in which capability, responsibility and achievement are recognised without prejudice, and in which support—training, mentoring and knowledge sharing—enables people to realise their potential. Success depends on inclusion and on the commitment and engagement of the whole team, regardless of gender identity.

3 Hiring on an Equal Basis

Hiring fair, transparent and merit-based. Roles are defined with clear purpose, essential criteria and measurable responsibilities. Job adverts use plain, inclusive language, avoid coded or gendered terms, and state the skills and experience that genuinely matter. Where feasible, salary ranges and flexible or part-time options are indicated to widen access. Each advert carries our equal-opportunities commitment and explains how candidates can request reasonable adjustments at any stage.

Sourcing is broad by design. Shortlisting follows documented criteria that match the role profile. Screeners apply the same standards to every application. Where practicable, anonymised screening is used. Interviews and assessments are structured and based on common criteria.

Improving gender balance in leadership and senior roles is a specific focus. Alongside fair hiring, we ensure equitable access to high-impact assignments, visibility in decision-making forums and transparent criteria for advancement, so that talented colleagues can progress on the strength of their capabilities and contributions. Continuous review and adjustment keep the process accountable and effective.

4 Equal and Fair Pay

Pay is built on clarity, consistency and evidence, it is based on a transparent job architecture with role levels and salary bands set on robust market benchmarks and the relative value of the role within the organisation, checked against internal equity. The architecture is reviewed on a regular cycle to reflect changes in the market and in our business.

We run gender pay-gap analyses at least annually, with interim checks where appropriate. Analyses cover both the overall (unadjusted) gap and like-for-like comparisons within bands and roles where data allow.

Offers, promotions and bonuses are determined by clear standards, not by negotiation power. We use calibrated scoring against role criteria and agreed performance goals, with cross-checks to prevent drift from the bands. Bonuses are awarded against transparent objectives and are subject to the same fairness checks. Raises depend on individual performance, team contribution and company results.

In short, equal and fair pay at DataPower is not a matter of discretion but of design: a structured framework, tested by data, explained in plain terms and applied with consistency.

5 Training and Support

Training and support at DataPower Srl are practical, concise and continuous. Staff members complete mandatory modules on bias awareness, respectful conduct. Managers receive additional coaching on inclusive leadership. Practical guidance backs this up.

Career development is supported through individual development plans, internal workshops and method clinics, with time set aside for learning.

Effectiveness is monitored. We review completion rates, feedback scores and outcomes such as progression and retention, looking for patterns by team and role.

6 Work–Life Balance

Work flexibility is built on trust, clarity and teamwork, combining teleworking with time in the office to support collaboration and team cohesion. The team may choose their work location on most days and adjust start and finish times around agreed core hours, within which meetings and joint work take place. Part-time schedules, compressed weeks and temporary changes to hours are available subject to manager approval, based on role requirements and service needs.

Parental and carers’ leave align with EU standards and local law. No one is penalised for using flexible arrangements or taking leave. Consistency and fairness are monitored. In practice, this framework lets teams agree sensible arrangements that work for the role and the individual, while ensuring our clients receive a reliable, high-quality service.

7 Legal Provisions (EU baseline and Italian Law)

DataPower Srl’s Gender Equality and Inclusion Plan aligns closely with the European Union’s legal and policy framework on gender equality, non-discrimination, and work-life balance. It reflects both binding obligations and emerging best practices under EU law, and it incorporates Italy’s transposition of key directives into national legislation.

The foundational legal basis stems from the Treaty on the Functioning of the European Union (TFEU), particularly Article 157, which guarantees equal pay for equal work or work of equal value, and Article 8, which requires the elimination of inequalities and the promotion of equality between men and women in all policies. These principles are reinforced by the EU Charter of Fundamental Rights, particularly Articles 21 (non-discrimination) and 23 (equality between men and women).

Several directives shape everyday practice. The Equal Treatment Directive (2006/54/EC) prohibits discrimination in employment and occupation on the basis of sex, including provisions on pay equity and sexual harassment. The Framework Equality Directive (2000/78/EC) establishes broader protections against discrimination in employment, including on grounds of religion, disability, age and sexual orientation.

Work-life balance is addressed through Directive (EU) 2019/1158, which introduced individual rights for parental leave, carers’ leave, and flexible working. These provisions are now implemented in Italy through Legislative Decree 105/2022, which ensures protected access to parental leave, strengthens rights for carers, and mandates priority access to flexible arrangements for eligible employees.

Directive (EU) 2023/970 on pay transparency introduces new standards for closing the gender pay gap, including obligations for employers to disclose pay structures, report on gender pay differences, and provide transparency in recruitment. Italy is currently working on transposing this directive, with full implementation required by June 2026.

Further protections stem from Directive 92/85/EEC, which ensures safety, health and non-discrimination for pregnant workers, and from Directive 2019/1937 (the Whistleblowing Directive), which provides secure channels for reporting breaches of EU and national law, including discrimination and harassment in the workplace. DataPower’s internal channels align with these protections, offering confidentiality and safeguarding against retaliation.

Beyond compliance, DataPower goes further than the legal minimum. We incorporate the principles of the UNI/PdR 125:2022 gender equality certification framework, even in areas where we are not formally obliged to do so. This includes systematic reviews of career progression, targeted access to development opportunities, structured parental reintegration support, and proactive transparency in pay and decision-making processes.

We also recognise the importance of psychosocial risks in the workplace, as addressed by European occupational safety and health (OSH) guidelines. Our commitment includes promoting psychological safety, mitigating work-related stress, and providing practical tools for inclusive and respectful collaboration.

Responsibility for tracking legal updates and ensuring continued alignment with both EU and Italian law rests with the executive team, supported by the Gender Equality Plan Lead. They monitor developments via official channels such as EUR-Lex, INL (National Labour Inspectorate), and the Department for Equal Opportunities, and liaise with legal counsel as required. Updates to this section are made as new legislation is adopted or existing frameworks evolve.

By grounding our Plan in both European and national law, and by exceeding statutory obligations where it strengthens fairness and inclusion, DataPower ensures that equality is not only a value but a lived practice embedded in how we work every day.

Italy’s gender equality, employment fairness and work-life balance framework is shaped by a combination of constitutional principles, national legislation and EU directives.

• Gender Equality in the Workplace is governed by the Italian Constitution and Legislative Decree 198/2006 (Equal Opportunities Code), with recent updates under Law 162/2021. These prohibit gender-based discrimination and harassment, mandate equal pay, and protect against retaliation and discriminatory dismissal. The National Equality Councillor plays a monitoring and enforcement role.
• Fair Recruitment and Career Advancement are addressed through the Workers’ Statute and the Equal Opportunities Code. Law 162/2021 encourages positive action. Board quotas are established by Law 120/2011 and extended under Law 160/2019 and Law 162/2021.
• Parental Leave and Carers’ Rights are provided under Legislative Decree 151/2001 and strengthened by Legislative Decree 105/2022 (transposing EU Directive 2019/1158). Law 104/1992 protects carers, while paternity leave is regulated under Budget Law 2022 and subsequent circulars.
• Flexible Work and Right to Disconnect are regulated by Law 81/2017 on “lavoro agile,” with additional protections under Legislative Decree 66/2003 and reinforced by national agreements such as the 2021 Protocol on Agile Work.
• Gender Equality Reporting and Certification were introduced by Law 162/2021, with mandatory biennial reporting for companies with 50+ employees. The voluntary Gender Equality Certification follows UNI/PdR 125:2022 guidelines and is supported by government incentives.

These laws implement key EU directives, including:

• TFEU Articles 8 and 157;
• EU Charter Articles 21 and 23;
• Equal Treatment Directive (2006/54/EC);
• Work-Life Balance Directive (2019/1158);
• Pay Transparency Directive (EU) 2023/970;
• Pregnant Workers Directive (92/85/EEC);
• Framework Equality Directive (2000/78/EC).

8 Measurement and Assessment (Indicators + Qualitative)

At DataPower Srl, we take a data-informed approach to advancing gender equality and inclusion. We commit to tracking a focused set of indicators across the employee lifecycle and organisational activities, ensuring progress is measurable, transparent and actionable.

The core indicators we monitor include:

• Hiring funnel by gender, from application through to offer and acceptance;
• Gender representation across organisational levels, with a focus on leadership roles;
• Gender pay gap, reviewed at both aggregate and role-equivalent levels;
• Promotion rates, disaggregated by gender;
• Attrition rates, with exit data monitored for potential disparities;
• Training uptake, including completion of mandatory equality modules;
• Average time to resolve reported concerns, to ensure issues are addressed promptly and fairly.

In addition, we track gender balance in external-facing activities, such as:

• The percentage of publications co-authored by women;
• Representation of women as speakers and moderators at events and initiatives hosted or supported by DataPower Srl.

Quantitative data is reviewed quarterly and annually, with summaries shared with both staff and the executive team. To complement the numbers, we gather qualitative insight through pulse surveys, structured interviews and informal feedback channels. This helps us understand how policies are experienced in practice and where adjustments are needed.

Findings are used to guide concrete action plans, prioritise areas for improvement and test the effectiveness of our interventions. We will define annual targets or thresholds for each indicator, including specific goals for leadership representation and training completion rates. Where data suggests disproportionate outcomes, we investigate causes and take corrective action.

All data is handled in full compliance with GDPR and relevant Italian privacy legislation. Reports are anonymised where necessary, and data access is limited to authorised personnel for specific, legitimate purposes.

Our approach is designed for continuous learning: measure what matters, reflect on results, and refine our actions. Equality is not a static goal but a process of ongoing improvement—and this framework ensures we remain accountable at every step.

8.1 Basic Figures 2024

Staff

	Female	Male
Consultants/researchers	3	4

Governing bodies

	Female	Male
Partners	0	4
Managing Partner	0	1

The figures include both DataPower Srl,if any, employed staff, and freelancers working on research and innovation projects and under Public Grants, as “natural persons under a direct contract”.

9 Implementation

9.1 Roles and Responsibilities

To support the delivery of this Gender Equality and Inclusion Plan, DataPower Srl has established the role of Gender Equality and Inclusion Officer and a dedicated Working Group. Together, they provide leadership, coordination, and oversight of all actions related to gender equality within the organisation.

The Gender Equality and Inclusion Officer is responsible for collecting and analysing gender-disaggregated data, coordinating implementation activities, and producing an annual report. The officer ensures consistent application of policies across departments, monitors progress against key performance indicators (KPIs), and collaborates closely with the Working Group and senior management to align efforts with the plan’s objectives.

The Gender Equality and Inclusion Working Group reflects the diversity of DataPower’s structure, including staff from the secretariat, freelancers, human resources, and across different levels and functions. Its purpose is to promote a fair, inclusive, and respectful workplace culture and to embed equality principles into organisational values and leadership. The group supports the Officer in implementing actions, integrates equality objectives into daily operations, and meets periodically to assess progress, exchange ideas, and support collective accountability for results.

9.2 Yearly Priority Setting

Each year, the Gender Equality and Inclusion Officer and Working Group review the current status of gender-related metrics and practices to propose new priorities. This evidence-based assessment—centred on “as-is” data—is shared with the management team, who jointly agree on annual objectives.

Yearly priorities are aligned with the long-term goals of the Gender Equality and Inclusion Plan. For 2025, they will include:

• Publishing an annual gender equality report, including disaggregated workforce data;
• Drafting inclusive language guidelines to complement the company’s editorial standards;
• Organising internal workshops on gender equality and inclusion.

These targeted actions will help embed inclusive practices into both day-to-day work and broader strategic planning.

9.3 Monitoring and Accountability

Ongoing monitoring is critical to delivering meaningful change. The Gender Equality and Inclusion Officer leads the tracking of progress on all KPIs outlined in the plan, producing a comprehensive annual report that provides a clear picture of achievements, setbacks, and areas for improvement. This report will be published on the DataPower website to ensure transparency and demonstrate continued commitment.

The report will include:

• KPI outcomes for the reporting year;
• A summary of actions implemented;
• Priority objectives for the year ahead.

Together with the Officer, the Working Group will regularly review progress, identify obstacles, and suggest adjustments where needed. This structured oversight ensures that the plan remains dynamic and responsive, enabling timely course correction and promoting lasting, organisation-wide impact.

9.4 For more information, contact:

Avv. Enrica Morena

Gender Equality and Inclusion Officer

DataPower Srl

enrica.morena@data-power.net