Diversity, Equity & Inclusion (DE&I) Policy

Introduction

This Diversity, Equity & Inclusion Policy of the Miramis Group has been developed with the aim of fostering a fair, inclusive, and respectful work environment, where every person, regardless of gender, sexual orientation, gender identity, age, ethnic origin, disability, religious belief, or personal circumstances, can fully express their potential and contribute to the organization’s success. In line with the principles of UNI/PdR 125:2022, it is embedded within the Group’s sustainability strategy as a key driver for innovation, organizational well-being, and positive social impact.

DE&I is considered a strategic component for business competitiveness, contributing to the creation of shared value and a culture based on respect, collaboration, and the recognition of diversity as a resource.

Miramis recognizes DE&I as one of the cross-cutting pillars of its ESG governance, committing to integrate these values into all operational and decision-making dimensions. The adoption of this policy is the result of a participatory process involving internal functions, listening sessions, and training workshops, with the aim of consolidating a shared vision oriented toward continuous improvement.

This process has placed people’s experiences and needs at the center, promoting a cultural change that goes beyond regulatory compliance and translates into concrete, measurable, and responsible commitments.

Scope of application

This Policy applies to all companies under the Miramis brand, including the operational sites of ErqoleS.r.l., Erqole Properties, Erqole Hospitality, Erqole Community, and La Capitana, and covers employees, collaborators, consultants, clients, suppliers, and external stakeholders. Its provisions apply to all workplaces and work-related occasions, including corporate online activities, public events, and business interactions.

Objectives and general principles

Through the adoption of its DE&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 the DE&I Policy is entrusted to the leadership, which adopts a coordinated and strategic approach. Alta Direzione (Top Management) is responsible for defining the policy and allocating adequate resources. The Comitato Guida (Steering Committee) oversees the adoption and effective application of the policy. The Responsabile per la Parità di Genere (Gender Equality Officer) coordinates the implementation of specific initiatives, is responsible for defining and monitoring KPIs, collecting documentation as required by UNI/PdR 125:2022, and verifying the activities outlined in the action plan.

Individual responsibility is shared across all levels of the organization: every employee is expected to actively contribute to maintaining a respectful, collaborative, open, and safe work environment. Compliance with the Policy is an integral part of the corporate Disciplinary Code, which includes sanctions for behaviors contrary to the principles set out herein.

Alignment with the sustainability strategy

The DE&I Policy is part of Miramis’s broader Sustainability Workplan 2025. This plan includes measurable objectives related to both people’s well-being and social impact. As part of this process, the Group has developed a materiality matrix, conducted consultations with stakeholders, and identified priority areas such as mental health, intergenerational equity, safety, and inclusion in decision-making processes. The commitment to DE&I is also aligned with the Group’s adherence to the United Nations Sustainable Development Goals, in particularGoal 5 – Gender Equality and Goal 10 – Reduced Inequalities.

These objectives are pursued through ESG governance that values participation, continuous improvement, and employee engagement in transformative processes. In this respect, DE&I is not an accessory set of measures but a structural component of Miramis’ organizational model. DE&I is interpreted as an enabling factor for innovation, competitiveness, and organizational resilience, in line with the principle that “sustainable business is good business.”

Monitoring and review

The DE&I Policy is subject to periodic review to ensure alignment with regulatory developments, organizational changes, and feedback gathered through established listening channels. The results of actions taken will be continuously monitored and transparently communicated to internal and external stakeholders through periodic reports, accessible dashboards, awareness campaigns, and engagement sessions with personnel, ensuring the principle of active participation.

The update of this Policy is the responsibility of the People Experience Department, in collaboration with the Comitato Guida and Alta Direzione.

Date: 11/08/2025

Approved by: Alta Direzione