ENVIRONMENTAL, SOCIAL AND GOVERNANCE POLICY

PREMISE AND OBJECTIVES OF THE DOCUMENT

This document constitutes the policy that UNGUESS follows regarding ESG factors. The objective of this ESG Policy is to define strategies and guiding principles regarding sustainability, with a focus on environmental protection, respect for human rights, social an personnel issues, and anti-corruption. The Policy outlines the values that motivate UNGUESS to manage its impact in a responsible manner towards the communities in which it operates and its employees, in order to demonstrate its commitment to sustainability and thus meet the demands of the various categories of stakeholders involved, both internal and external to the company. UNGUESS is committed to integrating its sustainability policy into its daily operations and interactions with its counterparts.

In defining ESG standards, UNGUESS considers how its business and its target sector, Crowdtesting and the IT sector, have a smaller impact than other industries. Although UNGUESS is not one of the large companies in the European Union that will be obliged to publicly disclose data on their impact on the environment, people, the planet and the sustainability risks they are exposed to, based on the ESG reporting obligation that was introduced by the EU CSRD (Corporate Sustainability Reporting Directive), it nevertheless decides to adopt through this Policy, a sustainability strategy that creates a corporate culture compliant with current laws and in line with international “best practices”, thus achieving greater efficiency, reduced costs and medium-long term risks, as well as an improvement in corporate reputation and greater alignment with the ethical values declared and shared with employees.

UNGUESS

Founded in 2015 and born as AppQuality, the first crowdtesting platform in Italy, in 2022 it evolved into UNGUESS, with the payoff ‘Be smart from the start’.

UNGUESS successfully supports more than 150 companies, with more than 3500 campaigns/projects realised in different sectors at Italian and international level.

UNGUESS to date has: – more than 75 employees, – thousands of people connected, – thousands of devices available, – presence in more than 100 countries, – customers on the Fortune TOP500 list, – achieved the goal of 100% carbon neutrality.

THE PURPOSE

UNGUESS created the Crowdtesting methodology to meet the Quality, User-Experience and Security requirements of the digital services created by its customers and partners. In fact, it allows to study and optimise the ease of use, deepen the feedback of final users and the functionality and security of customers’ digital products (Apps, Websites, Chatbots, etc.) by leveraging the collective knowledge of its community of online testers: The Crowd.

All Crowdtesting and quality verification activities are vertical activities, intensive but not exhaustive, which aim to provide the customer with an insight into the problems that the application presents and the way real users interact with the application itself. UNGUESS therefore provides the possibility of exploiting the professionally managed, geo-graphically distributed and interconnected community of testers via our cloud platform and composed of tens of thousands of “digital testers”.

THE CROWD

The Crowdtesting activity offered by UNGUESS to meet the needs of its customers and partners is made possible through the engagement of a community of certified testers called Tryber, a community always available, founded on the principles of loyalty, fidelity and collaboration, for a safer digital world.

All testers, called Trybers, enrolled in the community, are profiled and selected by UNGUESS on the Tryber.me platform, in order t o verify their skills and certain profiling data (e.g. the device combinations available to the individual tester), so that they can be engaged in Crowdtesting Campaigns that are designed to meet the needs of UNGUESS customers and partners.

THE SOLUTION

The UNGUESS solution consists of three macro components:

  • The Crowd: a community of more than 250,000 testers and profit users of various nationalities (hereinafter referred to as ‘Trybers’), which guarantees access to thousands of devices with different configurations in order to ensure maximum coverage of devices and operating systems, as well as the perfect target for any crowdtesting activities to be performed. This also includes the use of external panels, which may serve in the case of particularly complex clusters.
  • The Technology: UNGUESS’ proprietary platform, through which you can (i) for the Client to monitor the progress of projects in real time and manage the reports of an individual test; (ii) for the Trybers to join testing campaigns, upload their activities and collect their fees; (iii) for the UNGUESS collaborators to benefit from a flexible and intuitive platform
  • The Customer Success Manager: a point of reference for the customer, he is the figure who guides the customer in choosing the best test plan, he designs and plans together with the customer all the test phases, also in the medium to long term, advising on the best solutions; internally it supports operations to ensure compliance with project requirements and ensures the quality of the final result.
PRINCIPLES AND VALUES

In order to provide its services in accordance with the applicable rules, laws and regulations, UNGUESS undertakes to respect and to make its hired Tryber, its employees and all third parties cooperating with UNGUESS respect its Code of Ethics, whose contents are in accordance with the principles of sustainability and ethics, as well as with the Italian national legislation in the field of

  • Environmental protection and respect for the environment in work processes;
  • Prohibition of the use of confidential information;
  • Confidentiality, Confidentiality and Business Secrets;
  • Bribery and illicit payments;
  • Money Laundering Prevention;
  • Counter-terrorism and anti-mafia;
  • Child labour and forced labour;
  • Equal opportunities, equality, fairness and prohibition of discrimination;
  • Harassment;
  • Health and safety in the workplace;

UNGUESS COMMITMENT TO ESG STANDARDS

The operational scope of UNGUESS fits very well with the ‘best practices’ of ESG criteria. In fact, its core business is based on “full-remote” in-house activities and the use of Crowdtesting’s digital platform for the delivery of its testing services; all while minimising travel time, transport costs and the related environmental impact.

UNGUESS has decided to clearly outline its path into the era of sustainability, according to ESG standards. The integration of ESG criteria is a requirement and a n added value, for UNGUESS, that can improve and lead to: – competitive advantages, as ESG criteria management is an element of competitive advantage; – risk mitigation, as ESG information management helps to mitigate potential risks associated with environmental, social and governance activities, as well as personnel and supplier management; – talent attraction, as the workers favour socially committed companies with a clear purpose, so that the integration of ESG criteria is an incentive to work for a company; – attracting financial resources, as in recent years and in the aftermath of the pandemic, investors have shown that they demand a greater commitment from companies to curb and mitigate climate change, drive the transition to a decarbonised economy, contribute to addressing social sfindings and reducing inequality.

To this end, UNGUESS undertakes to

  • set up a team to coordinate the company’s Sustainability and, more generally, ESG issues in order to establish a Sustainability Plan, its implementation, monitoring, and perform a materialitm analysis, consisting of a process to identify the relevant ESG aspects for the company, based on the sector of activity or global trends, and thus establish ESG objectives.
  • promote the use of the latest technologies to achieve excellence in worker health protection, occupational safety and environmental protection.
  • Involve all levels of the organisation and all employees within the company in the fulfilment of ESG criteria, ensuring that responsibilities and operating procedures are precisely defined, appropriately communicated and clearly understood.
  • not tolerate corruption in any form or manner, in any jurisdiction, even when such activities have in practice been permitted, tolerated or not prosecuted.

 

This Policy, which is communicated to all UNGUESS employees, will be continuously updated and improved in order to always be in compliance with ESG standards.

UNGUESS is therefore committed to implementing procedures, rules and instructions with the aim of ensuring that the values expressed in this Policy are reflected in the behaviour of its employees and collaborators. To this end, UNGUESS will also continuously update its Code of Ethics to bring it in line with ESG standards.

ENVIRONMENT

The ESG Criteria related to the environment aim at companies’ management of their direct and indirect environmental impacts, their respect for the environment and biodiversity, their commitment to reducing greenhouse gas emissions and climate change, and their contribution to achieving a decarbonised economy.

With this in mind, UNGUESS is committed to reducing and minimising the direct and indirect short- and long-term effects of its activities on the environment, as well as to continuously monitoring risk factors related to environmental elements. UNGUESS is particularly active in using procedures and innovations that reduce consumption to help mitigate climate change. By carrying out its business activities in full-remote, UNGUESS reduces travel and the use of means of transport to the point of minimising emissions and waste, while optimising its activities.

UNGUESS operates in the IT services sector, through crowdtesting activities managed through a digital platform and as such its activities have a low environmental impact as they do not involve the management of waste or the treatment of liquids. UNGUESS offices are not owned by the company, therefore UNGUESS is not directly responsible for the buildings and related facilities, and as such cannot independently implement initiatives to increase the sustainability of these.

However, UNGUESS is sensitive to the issue of minimising negative effects on the environment and is committed to reducing emissions. To demonstrate this, it has long developed policies and best practices to reduce its environmental impact.

As a demonstration of its commitment to environmental protection, UNGUESS is committed to:

  • implement an Environmental Management System that meets the requirements o f ISO 14001, fulfilling its environmental policy and complying with applicable laws to limit pollution and to continuously improve its performance. As proof of this, UNGUESS holds and maintains the ISO 14001 Certification.
  • quantifying, monitoring and reporting greenhouse gas (GHG) emissions, thus managing GHG emissions in an efficient and consistent manner, providing a systematic approach to managing GHG emissions. As proof of this, UNGUESS holds and maintains the ISO 14064 Certification.
  • possessed for the past two years, carbon neutrality has been certified, thanks to an external partner, with which the albeit limited emissions are offset, to ensure neutrality.
  • When choosing locations for corporate team-building events, favour green and ecosustainable solutions, as in the case of the retreat 2023, held at a bio-resort, which favoured outdoor activities and received employees’ appreciation for many aspects related to recycled materials, energy efficiency, all-round eco-sustainability
  • incentivising the use of sustainable means of transport, such as car-sharing, public transport or cycling, also providing adequate infrastructure for parking bicycles. With this in mind, UNGUESS has and keeps up-to-date an internal Sustainability Policy on measures taken to this end, such as car-sharing and the use of hybrid vehicles, in order to raise everyone’s internal awareness of sustainable mobility.

 

UNGUESS continuously identifies actions that can contribute to the goal of preserving the quality of the environment.

UNGUESS is committed to conducting a preliminary analysis aimed at examining the direct and indirect environmental aspects related to its activities, the applicable regulatory framework and the status of implementation of the related obligations arising from its activities. This analysis allows the identification of significant environmental aspects on which UNGUESS will focus its monitoring and management in the future, identifying, where possible, risk mitigation actions.

SOCIAL

Social ESG criteria aim at the management by companies of their employees, collaborators and customers, the promotion of decent work policies, equal opportunities and work-life balance, training, respect for human rights and the prohibition of child labour.

With this in mind, UNGUESS is committed to basing relations between individuals internally on the principles of justice, transparency, liberty, loyalty and fidelity, and is constantly striving to offer working conditions that uphold individual value, human rights, equal opportunities and a positive working environment that supports and cares for minorities.

UNGUESS promotes a responsible work environment and ensures compliance with all laws regarding t h e employment of its employees, promoting the employment of labour and personnel from diverse backgrounds, recognising and respecting qualities such as gender identitm, ethm, race and ethnicity, nationality of origin, religious culture and/or political belief, language, education, socio-economic background, social, family or relational status, sexual orientation and/or disability, considering these qualities as one of the main corporate values.

The objective of UNGUESS is to create a working environment in which all employees are equally included and valued according to their contributions, thus ensuring a sustainable work environment in which inclusion is expected and prioritised. This responsibility is conducted with an awareness of the problems and benefits that such diversity can entail and is recognised by the company management, which supports the collective promotion of a culture that recognises the value of its employees and values respect and inclusion.

The IT sector, in which UNGUESS operates, is characterised by a high rate of technical innovation and the need for specialised know-how. For this reason, UNGUESS is committed to active policies of attraction and retention of qualified resources, investing significant resources in Human Resources.

As a demonstration of its commitment to social standards, UNGUESS is committed to

  • respect human rights and prevent any complicitm in human rights violations
  • Respect equality and diversity among employees, using non-discriminatory employment practices, in this sense UNGUESS has stipulated a convention with the Disabled Employment Office of the Province of Cremona, in compliance with law no. 68 of 12 March 1999 “Rules for the right to work of the disabled”. UNGUESS is committed to the continuous observance of the contents of this convention in order to promote the insertion and work integration, within its organisation, of people with disabilities.
  • To guarantee, again in relation to equality between employees and in particular in relation to gender paritm, a fair recognition of rights between people of different sexes in the workplace, by compiling, in order to demonstrate the transparency of the treatment reserved for female workers, every two years the “Periodic report on the situation of male and female staff”, ex art. 46 of the Equal Opportunities Code, regarding the two-year period of reference, and transmitting the report to the regional paritm councillor and councilor. In order to certify the policies and concrete measures adopted by employers to reduce the gender gap, in relation to opportunities for growth in the company, equal pay for equal work, policies for managing gender differences and maternity protection, and therefore, to demonstrate the absence of discrimination against womenworkers, UNGUESS undertakes to obtain and keep updated the Gender Equality Certification, ex L. 162/2021, by undertaking a specific research project on the issue of gender equality. 162/2021, by undertaking a specific certification process in order to obtain it.
  • guaranteeing employees the possibility of working wherever they prefer, from home or in the office, providing them with a certain level of flexibility even in relation to working hours. All this as long as they are clear about their priorities, focus on them, achieve their personal goals and, in doing so, contribute to those of the company. UNGUESS, in fact, provides for SmartWorking, in full-remote mode, and is also able to accommodate their employees in special offices, thus ensuring a high degree of working flexibility, according to the needs of each worker.
  • comply with its legal obligations in terms of health and safety, and to protect the wellbeing of its employees, giving them the opportunity to maintain a work-life balance. In this regard, UNGUESS has introduced from 2022 a Welfare system for its employees, to which everyone will have access, and with the aim of improving the quality of life and well-being of workers and their families, through a set of services and benefits.
  • Ensuring a safe working environment by providing training for all employees to improve understanding of behaviour that may be perceived as discriminatory, exclusionary and/or harassing, and providing employees with safe avenues to report such behaviour.
  • verifying that all employees are regularly updated on safety issues in the workplace, appointing specialised personnel for fire-fighting and first aid procedures, and appointing RLS, RSPP and forensic scientist, all in accordance with the provisions of the DUVRI, which is constantly updated.
  • have the HR department, sometimes with the help of external consultants, take care of administering questionnaires to survey the company climate, which is also monitored through 1-to-1 sample interviews. The results of these cores have always proved invaluable in taking preventive action and intercepting what may represent possible hotbeds of internal malaise or other dynamics requiring targeted management. The adoption at the end of 2023 of a specialised HR tool and the strengthening of the Human Resources and People Management area will help in this direction.

GOVERNANCE

The ESG Criteria related to Governance aim at the commitment of companies to optimal management in following codes of ethics and conduct, transparency of their activities and the fight against corruption by the board of directors and management team.

As a demonstration of its commitment to maintaining an optimal management system in relation to
the Governance criterion, UNGUESS is committed to

  • adopt within the company, ex. Legislative Decree 231/2001, the Organisational Model 231, which is designed to protect the company in the event of the commission of certain offences committed in the interest or to the advantage of the same, by its directors or employees, having, therefore, set up the Body of Supervision, which must oversee the proper functioning of and compliance with the organisation, management and control models suitable for preventing the offences provided for in Legislative Decree No. 231/2001.
  • disapprove of any case of extortion, coercion, or unjust enticement to provide or receive advantages, guaranteeing the respect of its own Code of Ethics, with, also, the provision of disciplinary sanctions to be imposed on those persons within UNGUESS who do not respect its contents, and making all personnel, partners, and suppliers aware of unethical behaviour. UNGUESS does not allow any kind of unethical activity, as it considers it a risk for a sustainable development economy, for good governance, and for ethical business practices. Infinally, our entire corporate governance is guided by our ethical values, which do not have performance as their primary objective, but consider it a direct consequence of the spontaneous application of a value system that, if applied and shared by all, can only lead to positive results.
  • provide for the internal whistleblowing channel envisaged by Legislative Decree No. 24/2023, as it is one of the companies covered by that provision. The rule in question introduces the new whistleblowing regulation in Italy, implementing the EU Directive 2019/1937.
  • ensure absolute compliance with the GDPR (European Data Protection Regulation 2016/679), by employing a DPO (Data Protection Officer) and two internally appointed System Administrators, in order to adopt all the various control and automation systems required to ensure total transparency in the protection of the personal data of the data subjects, so that such personal data are not altered in any way.
  • provide in its articles of association, along with the Board of Directors, for a Control Body represented by the specially appointed Single Statutory Auditor, who is constantly involved in meetings of the administrative body and with whom quarterly audits are held, in parallel with audits with the Supervisory Board.
  • Involve external auditors of high standing in the statutory audit of the financial statements, who guarantee professionalism and reliability of the accounting and administrative control and audit procedures.
  • lead the management team, in some cases with the support or endorsement of the board of directors, to periodically review the key roles in the company and the organisational structure, to ensure on the one hand the smooth running of the company’s activities, and on the other hand the meritocratic and relational verifications that may lead the company to appoint certain employees to key and responsible roles.

CONCLUDING REMARKS

SCOPE OF APPLICATION

The following ESG Policy applies to UNGUESS S.r.l.

The Company encourages its suppliers to follow the provisions and best practices contained in the document, where applicable.

DISCLOSURE

The following ESG Policy can be found at the bottom of the home page of the company website https://unguess.io/it/.

APPROVAL AND UPDATING

The following ESG Policy was approved by the UNGUESS Board of Directors S.r.l. on 22.12.2023. The document will be subject to revisions and/or modifications when necessary based on substantial changes related to UNGUESS’s business or the sustainability strategy pursued by the company.