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 and personnel issues, and anti-corruption. The Policy outlines the values that motivate UNGUESS to manage its impact responsibly 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 among 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 to which they are exposed, under the ESG reporting requirement that was introduced by the EU CSRD (Corporate Sustainability Reporting Directive), it nevertheless decides to adopt through such a Policy, a sustainability strategy that creates a corporate culture that complies with current laws and is in line with international “best practices”, thus achieving, greater efficiency, reduction of costs and risks in the medium to long term, 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 started 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 implemented in different sectors at the 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 included in the Fortune TOP500 List – is having achieved the goal of 100% carbon neutrality.

THE PURPOSE

UNGUESS has created a Crowdtesting methodology to meet the needs related to Quality, User-Experience and Security of digital services created by its customers and partners. Indeed, it allows them to study and optimize ease of use, delve into final user feedback, and the functionality and security of customer digital products (Apps, Websites, Chatbots, etc.) by leveraging the collective knowledge of their community of online testers: The Crowd.

All Crowdtesting and quality verification activities are vertical, intensive but not exhaustive activities that are intended to give the customer insight into the issues that the application presents and how real users interact with the application. UNGUESS thus provides the possibility of leveraging the professionally managed, geographically distributed and interconnected community of testers through our cloud platform and consisting 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, an always-available community 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 to verify their skills and some profiling data (e.g., the combinations of devices available to the individual tester), so that they can be engaged within Crowdtesting Campaigns that are designed to meet the needs of UNGUESS’ own customers and partners.

THE SOLUTION

The UNGUESS solution consists of three macro components:

  • The Crowd: community of more than 250,000 testers and profit users of various nationalities (hereafter, the “Trybers”), which guarantees access to thousands of devices with different configurations so as 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 can serve in the case of particularly complex clusters.
  • The Technology: the proprietary platform of UNGUESS, through which it is possible to. (i) for the Client to monitor the progress of projects in real time and manage single test reports; (ii) for the Trybers to join testing campaigns, upload their activities, and collect their fees; (iii) for UNGUESS contributors to be able to take advantage of a flexible and intuitive flexible platform
  • The Customer Success Manager: a point of reference for the customer, is the figure who guides the Customer in choosing the best test plan, designs and plans together with the Customer all the testing phases, including medium- to long-term, recommending the best solutions; internally affirms operations to ensure compliance with design requirements and ensures the quality of the final result.
PRINCIPLES AND VALUES

For the firms of providing its services in accordance with the applicable rules, laws and regulations, UNGUESS is committed to respecting and enforcing the Tryber hired, its employees and all third parties that collaborate with UNGUESS itself, its Code of Ethics, the content of which complies with the principles of sustainability and ethics, as well as with the Italian national legislation on:

  • Environmental protection and respect for the environment in work processes;
  • Prohibition on the use of confidential information;
  • Confidentiality, confidentiality, and trade secrets;
  • Corruption and illicit payments;
  • Money laundering prevention;
  • Counterterrorism and anti-mafia;
  • Child labor and forced labor;
  • Equal opportunity, equality, fairness, and prohibition of discrimination;
  • Harassment;
  • Occupational health and safety;

UNGUESS COMMITMENT TO ESG STANDARDS

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

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

UNGUESS to this finish, within the scope of its activity, commits itself to:

  • Establish a team to coordinate the company’s Sustainability and, more generally, ESG issues inorder to find a Sustainability Plan, its implementation, monitoring, and perform a materiality analysis, consisting within a process to identify relevant ESG issues for the company, based on the business sector or global trends, and thus establish ESG goals.
  • Promote the use of the latest technologies to achieve excellence in worker health protection, occupational safety and environmental protection.
  • involve within the company all levels of the organization and all employees in ESG compliance, ensuring that responsibilities and operating procedures, in this regard, 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 judicially prosecuted.

 

This Policy, communicated to all UNGUESS employees, will be subject to continuous updating and improvement in order to be in compliance with ESG standards at all times.

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 behavior of its employees and collaborators. To this end, UNGUESS will also continuously update its Code of Ethics to continually conform to 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 the reduction of greenhouse gas emissions and climate change, and their contribution to achieving a decarbonized economy.

With this in mind, UNGUESS is committed to reducing and minimizing 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. Through conducting business activities in full-remote, UNGUESS reduces travel and use of transportation to the point of minimizing emissions and waste while optimizing 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 rifits or the processing of liquids. UNGUESS offices are not owned by the company, so UNGUESS is not directly responsible for the edifices and related facilities, and as such cannot independently implement initiatives to increase their sustainability.

However, UNGUESS is sensitive to the issue of minimizing 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 complies with 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 keeps up-to-date the ISO 14001 Certification..
  • quantify, monitor, and report on 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.
  • have possessed for the past two years certified carbon neutrality, thanks to an external partner, with which albeit limited emissions are offset, to ensure neutrality.
  • favoring, when choosing locations for corporate team-building events, green and eco sustainable solutions, such as at the 2023 retreat, held at a bio-resort, which encouraged outdoor activities and received appreciation from employees for so many aspects related to recycled materials, energy efficiency, and all-around eco-sustainability
  • incentivize the use of sustainable means of transportation, such as car-sharing, public transportation, or bicycling, including providing adequate infrastructure for bicycle parking. With this in mind, UNGUESS has and keeps up-to-date appropriate internal Sustainability Policy regarding measures taken to this end, such as car-sharing and the use of hybrid vehicles, in order to internally raise everyone’s 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 related obligations arising from its activities. This analysis enables the identification of significant environmental aspects on which UNGUESS will focus its monitoring and management in the future, identifying risk mitigation actions where possible.

SOCIAL

ESG Criteria related to Social, aim at companies’ management of their employees, contractors and customers, promotion of decent work policies, equal opportunity and work-life balance, training, respect for human rights and prohibition of child labor.
With this in mind, UNGUESS is committed to basing relations among individuals internally on the principles of justice, transparency, liberty, loyalty, and fidelity, constantly striving to provide working conditions that support individual worth, 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 affecting t h e employment of its employees, promoting the employment of labor and personnel from diverse backgrounds, recognizing and respecting quality such as gender identity, etm, 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 goal of UNGUESS is to create a work environment in which all employees are equally included and valued based on their contributions, thereby ensuring a sustainable work environment in which inclusion is expected and prioritized. This responsibility is conducted with an awareness of the problems and benefits that such diversity may entail and is recognized by management, which supports the collective promotion of a culture that recognizes the value of its employees and values respect and inclusion.

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

As a demonstration of its commitment to meeting standards related to Social, UNGUESS is committed to:

  • Respect human rights and prevent any complicit in human rights violations
  • Respect equality and diversity among employees, adopting non-discriminatory employment practices, in this sense UNGUESS has entered into an agreement with the Disability Employment Office of the Province of Cremona, in compliance with Law No. 68 of March 12, 1999 “Standards for the Right to Work of the Disabled”. UNGUESS is committed to continuous compliance with the content of this agreement in order to promote the inclusion and labor integration, within its organization, of people with disabilities.
  • To ensure, again in relation to equality among employees and in particular in relation to gender parity, an equitable recognition of rights between persons of different sexes in the workplace, by compiling, for the purpose of demonstrating the transparency of the treatment of female workers, every two years the “Periodic Report on the Situation of Male and Female Personnel”, ex art. 46 of the Equal Opportunity Code, regarding the two-year period of reference, and transmitting the report itself to the regional paytm councilor and councilor. In order to certify the concrete policies and measures adopted by employers to reduce the gender gap, in relation to opportunities for growth in the company, equal pay for equal duties, gender difference management policies, and maternity protection, and thus, to demonstrate the absence of discrimination against female workers, UNGUESS undertakes to obtain and keep updated the Gender Equality Certification, ex L. 162/2021, by undertaking appropriate path of certification for the purpose of obtaining it.
  • ensure that employees are able to work 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 provided that 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, it provides SmartWorking, in full-remote mode, and is also able to house its employees within special office, thus ensuring great working flexibility, according to the needs of each worker.
  • comply with its legal obligations in terms of health and safety, and to protect the welfare of its employees, giving them the opportunity to maintain a work-life balance. In this regard, UNGUESS has introduced from 2022 for its employees a Welfare system, 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 work environment by providing training for all employees to improve understanding of behaviors that may be perceived as discriminatory, exclusionary, and/or harassing and by providing safe avenues for employees to report such behaviors.
  • verifier to ensure that all employees remain periodically updated on workplace safety issues, fulfills appointments of specialized personnel for firefighting and first aid procedures, has appointed RLS, RSPP and forensic doctor, all consistent with the provisions of the DUVRI, which is constantly updated.
  • have the HR department, sometimes with the help of outside consultants, take care to administer questionnaires to survey the company climate, which is also monitored through 1-to-1 sample interviews. The outcome of these cores has always proved invaluable in taking preventive action and intercepting what may represent possible foci of internal malaise or other dynamics that require targeted management. The adoption in fine 2023 of a specialized 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 implement optimal management in following codes of ethics and conduct, transparency of their activities, and anti-corruption by the board of directors and management team.

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

  • To adopt within the company, ex. Legislative Decree 231/2001, the Organizational Model 231, which aims to protect the company in case of the commission of certain crimes committed in the interest or to the advantage of the company, by its own directors or employees, having, therefore, in this sense, established the Supervisory Board, which must supervise the proper functioning and observance of the organization, management and control models suitable for preventing the crimes provided for in Legislative Decree 231/2001.
  • disapprove of any case of extortion, coercion or unjust enticement to provide or receive benefits, ensuring compliance with its Code of Ethics, with, also, the provision of disciplinary sanctions to be imposed on individuals within UNGUESS who fail to comply with its content, and raising awareness among all personnel, partners and suppliers about unethical behavior. UNGUESS does not allow any kind of unethical activity, as it considers it a risk to a sustainable development economy, good governance, and ethical business practices. Infine, our entire corporate governance has been guided by our ethical values, which do not have performance as a 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 falls within the companies targeted by this norm. This rule introduces the new whistleblowing regulation in Italy, implementing the EU Directive 2019/1937.
  • to ensure absolute compliance with the GDPR (European Data Protection Regulation 2016/679), using 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 individuals concerned, so that such personal data are not altered in any way. To this end, UNGUESS has adopted a Privacy Management Model and a Processing Register, both of which are constantly updated.
  • provide within its bylaws, along with the Board of Directors, for a Control Body represented by the specially appointed Single Statutory Auditor, who is constantly involved in the meetings of the administrative body and with whom quarterly audit verifications are held, in parallel with audits with the Supervisory Board.
  • Involve, in the statutory audit of the financial statements, external auditors of primary standing, who ensure professionalism and reliability of accounting and administrative control and audit procedures.
  • lead the management team, in some cases with the support or endorsement of the BoD, to periodically review key roles in the company and the organizational 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.
  • Promote a culture of integritm, transparency and conformitm in order to prevent, detect and manage situations of corruption, both active and passive. To demonstrate this, UNGUESS holds and keeps up-to-date the ISO 37001 Certification and is complemented by the other ISOs held and kept up-to-date (ISO 9001 and ISO 45001) and the 231 Model specifically adopted

CONCLUDING REMARKS

SCOPE OF APPLICATION

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

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

DISCLOSURE

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

APPROVAL AND UPDATING

The following ESG Policy has been 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.