Sim osam ser d.o.o. – Gender Equality & Anti-Harassment Policy

Legal entity: Sim osam ser d.o.o., Jurija Gagarina 231, 11000 Belgrade

Version: 1.1

Effective date: 24 September 2025

Owner: Management / HR Responsible Person

Equality & Reporting Contact (confidential): office@sim8.eu

Review: Annual

1. Purpose

Sim osam ser 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

predictable scheduling).

caregiving.

• Flexible work arrangements where feasible (working hours, hybrid or remote work,

• No negative treatment for using lawful leave or flexibility related to parenting or

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@sim8.eu.

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 Sim osam ser d.o.o. and is effective from 24

September 2025.

Company: Sim osam ser d.o.o., Jurija Gagarina 231, 11000 Belgrade