Diversity and Equal Opportunity Policy
1. Purpose
This Diversity and Equal Opportunity Policy (the "Policy") provides a framework that embraces and promotes diversity within Green Earth. As a global organisation, we recognise and respect the inherent value and contributions of every individual and are committed to cultivating an inclusive and equitable environment. We believe that diversity in all its forms (gender, age, nationality, culture, religion, educational background and professional experience) fosters innovation, strengthens decision-making and contributes to the overall success of our company.
This Policy explains how diversity is managed and enhanced within Green Earth. It sets out our commitment to a diverse workplace and our intent to recognise and appreciate the unique insights, perspectives and backgrounds that each individual brings to the organisation. It supports practices that encourage a culture of inclusion, respect and equal opportunity. By promoting diversity and inclusion, we seek to create a workplace where all employees feel valued, are treated fairly and can realise their full potential.
The Policy also sets out our commitment to equal treatment and to a working environment free from unlawful discrimination, harassment and retaliation, in line with Dutch equal treatment law. Promoting diversity and inclusion is continuing work, and we are dedicated to it.
2. Scope
This Policy applies to Green Earth Group N.V. (the "Company") and its subsidiaries (together, "Green Earth"), in all facets of their operations, including administrative offices and project sites. It applies to all employees, regardless of their role, level or location, and to the executive and non-executive directors of the management board of the Company (the "Board"). The Company has a one-tier board: the Board is made up of executive directors and non-executive directors, and the Company has no supervisory board. In this Policy, "Board" always means that one-tier board. It applies whenever an employee is performing a function of their job, including at all company locations, customer worksites, and company-sponsored or customer-sponsored business and social functions.
Subsidiaries outside the Netherlands apply this Policy within the law of the country in which they operate. Where local law sets a stricter requirement, that requirement applies.
While this Policy is primarily directed at employees, we also encourage our stakeholders, business partners, suppliers and other associated entities to uphold the principles of diversity and inclusion set out in it.
3. Principles
Green Earth is an equal opportunity employer that values diversity and inclusion, that is, it provides opportunities to put differences to use in a manner that adds value to the business. Under our equal opportunity principles, any qualification or requirement applied to a job that has, or may have, the effect of inhibiting applications from groups of the population is retained only if it can be justified in terms of the job to be done.
Green Earth implements diversity and inclusion in talent management.
We commit to fostering a diverse and inclusive environment. We acknowledge and respect the richness of diversity in its many forms, and we value the unique contributions of all our employees.
We recognise that diversity strengthens our decision-making processes and governance structures. A broad array of perspectives contributes to robust discussion, innovative thinking and improved performance.
In promoting diversity, we consider a range of criteria, including but not limited to age, gender, nationality, education and professional experience. These criteria are applied within the limits of Dutch equal treatment law. They never replace selection on merit and are never a reason to exclude anyone.
4. Equal treatment and non-discrimination
We maintain a working environment free from all forms of unlawful discrimination (onderscheid) and harassment, including sexual harassment (intimidatie en seksuele intimidatie). This follows Article 1 of the Dutch Constitution and the Dutch equal treatment legislation, in particular:
- the General Equal Treatment Act (Algemene wet gelijke behandeling, AWGB);
- the Equal Treatment of Men and Women Act (Wet gelijke behandeling van mannen en vrouwen, WGB) and article 7:646 of the Dutch Civil Code;
- the Equal Treatment in Employment (Age Discrimination) Act (Wet gelijke behandeling op grond van leeftijd bij de arbeid, WGBL);
- the Equal Treatment on the Grounds of Disability or Chronic Illness Act (Wet gelijke behandeling op grond van handicap of chronische ziekte, WGBH/CZ).
We prohibit discrimination and harassment against any applicant or employee on any of the following grounds, or on any other ground prohibited by law:
- race, including skin colour, ethnic origin and ancestry;
- religion or belief, including religious dress and grooming;
- political opinion;
- sex or gender, including pregnancy, gender identity and gender expression;
- nationality, including citizenship status;
- age;
- disability or chronic illness, including medical condition and mental or physical disability;
- sexual orientation;
- civil status (burgerlijke staat), including marital status;
- genetic information.
All employment decisions about applicants and employees are non-discriminatory and based only on valid job requirements. This applies to all terms, conditions and privileges of employment, including recruitment, selection, pay and benefits, training, promotion and disciplinary action.
We make effective accommodations (doeltreffende aanpassingen) for qualified applicants and employees with a disability or chronic illness, as the WGBH/CZ requires, and we accommodate the sincerely held religious beliefs, practices or observances of applicants and employees. An accommodation is not required where it would impose a disproportionate burden (onevenredige belasting) on the business.
5. Positive action
We are committed to taking positive action (voorkeursbeleid) to employ, advance in employment and treat without discrimination qualified women, people from ethnic minority groups, and people with a disability or chronic illness. Positive action is taken only where it is permitted by law, within the limits set by Dutch equal treatment law. In a selection decision, preference on one of these grounds is given only where candidates are equally qualified for the position, and never as an automatic or unconditional preference.
6. Diversity in the Board and management
When selecting executive and non-executive directors and executives, we consider diversity in age, gender, nationality, educational background and professional experience, seeking a balanced representation. We also ensure that appointments are made on merit, skills and relevant experience.
Our hiring and promotion policies ensure fair and equal opportunities for all employees, regardless of their background. We strive for a diverse workforce and commit to non-discrimination and equal opportunity.
The Nomination and Remuneration Committee takes this Policy into account when it reviews the composition and size of the Board, plans succession and makes recommendations for appointments, as set out in the Terms of Reference Nomination and Remuneration Committee.
As article 2:166 of the Dutch Civil Code requires, where that article applies to the Company, the Board sets appropriate and ambitious objectives for a more balanced gender composition of the Board, and of the categories of senior employees that the Board determines, together with a plan to achieve them.
The Board also sets the objectives of its diversity policy for the composition of the Board, explains how this Policy is applied in nominations, appointments and succession planning, and keeps them under review.
Each year the Board reports in the management report (bestuursverslag) on these objectives, on how they are applied, and on the progress made and the results achieved in the financial year, including, where applicable, the information that article 3d of the Decree on the contents of the management report (Besluit inhoud bestuursverslag) requires: the gender composition, the objectives, the plan to achieve them and, where an objective has not been met, the reasons.
7. Roles and responsibilities
| Post | Responsibility |
|---|---|
| Everyone covered by this Policy | Treats colleagues, applicants and others with respect, follows this Policy and reports concerns. |
| Line managers | Make employment decisions in line with this Policy, receive concerns and act on them. |
| Country Director | Applies this Policy within the venture, within local law. |
| Compliance Officer | Receives and handles reports of discrimination, harassment and retaliation. |
| Nomination and Remuneration Committee | Takes this Policy into account for the composition of the Board and succession planning. |
| Head of Legal | Owns this Policy and keeps it under review. |
| Board | Oversees this Policy; the Chief Executive Officer approves it and any changes to it on the Board's behalf. |
8. Reporting concerns and protection from retaliation
Concerns about discrimination, harassment, retaliation or other inappropriate behaviour should be identified and remedied promptly, thoroughly and effectively. Report a concern to your direct line manager or the Compliance Officer. Serious concerns, or concerns you do not wish to raise with your line manager, can be reported through the process set out in the Whistleblower and Non-Retaliation Policy.
Anyone outside Green Earth who has a concern can contact the Company at contact@green.earth or through the contact form at https://www.green.earth/contact.
This Policy does not limit anyone's right to ask the Netherlands Institute for Human Rights (College voor de Rechten van de Mens) for an opinion on equal treatment.
We prohibit retaliation against any applicant or employee who, in good faith:
- files a complaint about perceived harassment or discriminatory conduct;
- assists or takes part in an investigation, hearing or other procedure relating to equal treatment;
- opposes any act or practice that is prohibited by equal treatment law;
- requests an accommodation; or
- engages in other protected activity.
9. Breaches
Any employee who is found to have violated the anti-discrimination or anti-retaliation provisions of this Policy is subject to corrective action, up to and including termination of employment.
10. Approval and review
The Chief Executive Officer approves this Policy and any changes to it on behalf of the Board. The Head of Legal owns this Policy and reviews it at least every two years.
This Policy takes effect on the date of approval. It replaces the Diversity Policy issued by the Company, then named DGB Group N.V., on 9 January 2018 and revised on 24 May 2023, and the Equal Employment Opportunity and Affirmative Action Policy of 24 May 2023, presented at the 2023 Annual General Meeting.
