Diversity, Equity & Inclusion (DE&I) Policy
Introduction
This Diversity, Equity &Inclusion Policy of the Miramis Group has been developed with the aim offostering a fair, inclusive, and respectful work environment, where everyperson, regardless of gender, sexual orientation, gender identity, age, ethnicorigin, disability, religious belief, or personal circumstances, can fullyexpress their potential and contribute to the organization’s success. In linewith the principles of UNI/PdR 125:2022, it is embedded within the Group’ssustainability strategy as a key driver for innovation, organizationalwell-being, and positive social impact.
DE&I is considered astrategic component for business competitiveness, contributing to the creationof shared value and a culture based on respect, collaboration, and therecognition of diversity as a resource.
Miramis recognizes DE&I asone of the cross-cutting pillars of its ESG governance, committing to integratethese values into all operational and decision-making dimensions. The adoptionof this policy is the result of a participatory process involving internalfunctions, listening sessions, and training workshops, with the aim ofconsolidating a shared vision oriented toward continuous improvement.
This process has placedpeople’s experiences and needs at the center, promoting a cultural change thatgoes beyond regulatory compliance and translates into concrete, measurable, andresponsible commitments.
Scope of application
This Policy applies to allcompanies under the Miramis brand, including the operational sites of ErqoleS.r.l., Erqole Properties, Erqole Hospitality, Erqole Community, and LaCapitana, and covers employees, collaborators, consultants, clients, suppliers,and external stakeholders. Its provisions apply to all workplaces andwork-related occasions, including corporate online activities, public events,and business interactions.
Objectives and general principles
Through the adoption of itsDE&I Policy, the Miramis Group aims to:
- Ensure equal opportunities throughout all stages of working life, removing systemic and individual barriers, and fostering fairness in recruitment, hiring, promotion, and career development processes;
- Guarantee equitable access to training and professional development opportunities, recognizing continuous learning as a driver of inclusion, growth, and self-determination for all individuals;
- Foster an inclusive, safe, and collaborative work environment that acknowledges and values personal, cultural, and identity differences;
- Promote fair and inclusive representation in decision-making positions, with specific attention to gender and generational balance, as well as to the representation of underrepresented minorities;
- Ensure balanced representation in public settings by guaranteeing the presence of women and individuals from minority groups in panels, working groups, and official events;
- Strengthen DE&I competencies through structured training programs for the entire workforce and leadership;
- Monitor pay equity and implement corrective measures to address any unjustified gender or other pay gaps;
- Promote respectful, accessible, and representative internal and external communication, countering stereotypes and exclusionary language;
- Foster a culture of respect through tools for the prevention and management of discrimination, harassment, and microaggressions, introducing a structured system for preventing and addressing behaviors that conflict with DE&I principles, including through the adoption of an internal Disciplinary Code;
- Support work–life balance and psychosocial well-being with concrete measures such as flexible work arrangements, part-time opportunities, and support for parenthood and caregivers;
- Value skills developed in non-traditional contexts, during long-term unemployment, or through non-linear career paths;
- Integrate DE&I principles into the value chain, supplier selection criteria, and community impact projects;
- Act in a transparent, measurable, and participatory way, involving internal and external stakeholders in the design and monitoring of inclusion policies;
- Guarantee a safe, inclusive, and respectful work environment for LGBTQIA+ individuals, in line with international human rights principles.
Implementation and responsibilities
The implementation of theDE&I Policy is entrusted to the leadership, which adopts a coordinated andstrategic approach. Alta Direzione (Top Management) is responsible fordefining the policy and allocating adequate resources. The Comitato Guida(Steering Committee) oversees the adoption and effective application of thepolicy. The Responsabile per la Parità di Genere (Gender EqualityOfficer) coordinates the implementation of specific initiatives, is responsiblefor defining and monitoring KPIs, collecting documentation as required byUNI/PdR 125:2022, and verifying the activities outlined in the action plan.
Individual responsibility isshared across all levels of the organization: every employee is expected toactively contribute to maintaining a respectful, collaborative, open, and safework environment. Compliance with the Policy is an integral part of thecorporate Disciplinary Code, which includes sanctions for behaviors contrary tothe principles set out herein.
Alignment with the sustainability strategy
The DE&I Policy is part ofMiramis’s broader Sustainability Workplan 2025. This plan includesmeasurable objectives related to both people’s well-being and social impact. Aspart of this process, the Group has developed a materiality matrix, conductedconsultations with stakeholders, and identified priority areas such as mentalhealth, intergenerational equity, safety, and inclusion in decision-makingprocesses. The commitment to DE&I is also aligned with the Group’sadherence to the United Nations Sustainable Development Goals, in particularGoal 5 – Gender Equality and Goal 10 – Reduced Inequalities.
These objectives are pursuedthrough ESG governance that values participation, continuous improvement, andemployee engagement in transformative processes. In this respect, DE&I isnot an accessory set of measures but a structural component of Miramis’sorganizational model. DE&I is interpreted as an enabling factor forinnovation, competitiveness, and organizational resilience, in line with theprinciple that “sustainable business is good business.”
Monitoring and review
The DE&I Policy is subjectto periodic review to ensure alignment with regulatory developments,organizational changes, and feedback gathered through established listeningchannels. The results of actions taken will be continuously monitored and transparentlycommunicated to internal and external stakeholders through periodic reports,accessible dashboards, awareness campaigns, and engagement sessions withpersonnel, ensuring the principle of active participation.
The update of this Policy isthe responsibility of the People Experience Department, in collaboration withthe Comitato Guida and Alta Direzione.
Date: 11/08/2025
Approvedby: Alta Direzione