Semapa : EQUALITY PLAN FOR 2024

EQUALITY PLAN FOR 2024

(SEPTEMBER 2023)

1. Framework

Law no. 62/2017, of 1 August, adopting the scheme for a balanced representation of men and women in the Board of Directors and Audit Boards of corporate state-owned enterprises and listed companies, obliges listed companies to draw up and disclose annual equality plans. The goal is to effectively enforce equal treatment and opportunities between women and men, promoting the elimination of discrimination based on gender and making it possible to balance personal, family, and professional life, in accordance with Article 7 therein.

Semapa continues to believe that, more than compliance with a legal obligation, the pursuit of measures aimed at ensuring equality between women and men is an essential endeavour of socially responsible management; it fosters a better performance of the organisation and helps attract and develop new Talent.

Consequently, the present Equality Plan, drawn up by Semapa, incorporates the provisions of Article 7 of Law No. 62/2017, of 1 August, and follows the guidelines contained in the "Guide for the Preparation of Equality Plans (annual)".

The present plan is an evolving document, which is reviewed and approved on an annual basis.

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1.1. Semapa as a holding and as a separate company

As a holding company, Semapa consolidates the financial and non-financial information with its subsidiaries, as is required by law, but such consolidation does not and may not correspond to management consolidation.

Consequently, Semapa has a global and holistic overview of the entire economic group and exercises its shareholder functions in relation to its subsidiaries, by seeking to share common values and principles. This vision is reflected in the Deontological Principles adopted by the Board of Directors in 2002, applicable to subsidiaries where the obligation of non-discrimination is expressed, among others: "In the company's internal relations and with third parties, Semapa employees must not discriminate or accept discrimination in any way, on the basis of descent, gender, race, language, national origin, religion, political convictions or ideologies, education, economic situation or social status."

Furthermore, since the adoption of the Deontological Principles, Semapa has always deemed "equal opportunities" to be a critical and fundamental principle in labour relations, which is elaborated in our sustainability report.

Furthermore, in 2017 Semapa adopted a Code of Good Conduct for Preventing and Fighting Harassment at Work, also applicable to all male and female employees of the entities that comprise the Semapa Group (unless they have a specific Code to this topic), which prohibits harassment at the workplace and sets out the obligations of male and female employees and employers in this regard, as well as the procedure to be followed in the case of harassment.

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In 2021, Semapa and the main companies of the Group reinforced their commitment to the fight against discrimination through the creation of the Whistleblowing Channel, allowing the internal communication of irregularities, in an anonymous and confidential manner, by the members of the Corporate Bodies and Committees of the Company, shareholders, employees, candidates on recruitment process, service providers, contractors and subcontractors, suppliers, volunteers, and trainees. Such communication includes, namely, the report of discriminatory practices regarding gender, thus allowing Semapa to act over situations that are not of its knowledge and better defend and ensure respect for the principles of equality between women and men.

On the other hand, Semapa adopted in 2023 its Human Rights Policy, where it undertakes to respect human rights, namely (i) the prohibition of discriminatory actions towards its employees on the basis of race, religion, gender, sexual orientation, disability, age, nationality, political convictions or economic or social situation and valuing diversity, gender equality and inclusion, as a way of ensuring effective equal opportunities, namely with regard to people with disabilities, (ii) the prohibition of all forms of harassment, abuse and violence in the workplace, and (iii) access to decent work, guaranteeing its workers a safe and healthy working environment, from a physical and psychological point of view, fair and equitable remuneration, personal development and continuous training, privacy of their personal data, respect for rest periods, access to applicable social protection schemes and respect for the right to parenthood, and encouraging the reconciliation of working and family life.

In addition to this Group's vision and the intended alignment between the Group's companies, Semapa makes its individual choices as a separate company, which it will lay out in this Plan. The choices are such as deemed most appropriate to its reality and size while fostering the sustainable implementation of such measures in the company. All of this is carried out notwithstanding the obligation of reporting on such matters in consolidated terms in the sustainability report.

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1.2. Diagnosis

Semapa decided to carry out an Engagement Survey in 2023, whose results are currently being analysed. This will allow us to be more focused on the actions to be carried out in 2024, since the demographic data from the questionnaire will allow us to gauge responses by gender. As we are currently in the process of tabulating and analysing the results and setting up some focus groups in order to understand some preliminary results in greater detail, the current Plan has not yet tapped into this instrument. We therefore keep as a reference the information from previous diagnoses and the evaluation of some of the measures implemented in the meantime.

This knowledge allows us to conclude the following:

1. Semapa has a consistent culture and practice of treating its male and female employees without discrimination of any kind, including gender;
2. Semapa has implemented the principles of diversity in its core strategic and structural documents;
3. Opportunities for improvement continue to exist, notably in the dissemination of its practices to male and female employees and its partners. The Equality Plan 2024 seeks to emphasise these matters. Equality of treatment between genders is a subject addressed in some internal forums, namely team and focus group meetings. For 2024 we intend to evolve on this subject, by raising further the awareness of our external partners, as we began doing in 2023 in relation to hiring.

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It should also be noted that Semapa has implemented an Annual Talent Review process, a forum where the careers of both men and women employees are assessed and where attention to non-discrimination and the creation of equal opportunities for men and women is reinforced.

Of the 32 male and female employees at Semapa, considered on an individual basis to date, 62.5% are women and 37.5% are men.

Looking into the functional areas of the company, we see the following break-down:

Functional Areas	Women		Men
	Number	%	Number	%
Directors	4	40%	6	60%
Senior Managers	9	81.82%	2	18.18%
Other	7	63.64%	4	36.36%

The figures show that Semapa's workforce is balanced in terms of gender and is developing an internal pipeline to progressively reinforce the balance, even among top management.

On the other hand, Semapa's corporate governance is governed by the Principles for the Composition of the Governing Bodies, published on Semapa's website, in which Semapa acknowledges, "the benefits of diversity in its corporate bodies, particularly the Board of Directors and the Audit Board, for ensuring greater balance in its composition, boosting the performance of each member and, together, of each body, improving the quality of decision-makingprocesses and contributing to its sustainable development."

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