LSG - DE&I Policy_ENG

GROUP POLICY DIVERSITY, EQUITY & INCLUSION (DE&I)

GROUP POLICY DIVERSITY, EQUITY & INCLUSION (DE&I)

TABLE OF CONTENT INTRODUCTION

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1. PURPOSE AND REGULATORY CONTEXT

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2. RECIPIENTS AND FIELD OF APPLICATION

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3. ISSUE, REVIEW MECHANISM AND TERMS OF VALIDITY

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4. TERMS AND DEFINITIONS

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5. GOVERNANCE, RESPONSIBILITIES AND DISCLOSURES

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6. PRINCIPLES AND GUIDELINES OF CONDUCT

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7.IMPLEMENTATION OF DE&I PRINCIPLES IN COMPANY PROCESSES

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8. DE&I OBJECTIVES AND ACTIONS

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9. REPORTS

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10. DISSEMINATION

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INTRODUCTION In a complex and constantly evolving working environment, the enhancement of People is a strategic element for corporate growth and sustainability.

Promoting Diversity, Equity and Inclusion (hereinafter “DE&I”) means recognising that each individual brings with them unique experiences, skills and perspectives, which constitute a competitive advantage and a source of innovation for the Company.

Companies that adopt an inclusive approach create more collaborative, motivating and wellness-oriented work environments, fostering the involvement and growth of everyone’s potential. DE&I is not only an ethical responsibility, but also a strategic lever to attract, develop and retain talent, improving the quality of relationships and overall performance.

1. PURPOSE AND REGULATORY CONTEXT This document defines the principles and guidelines of Diversity, Equity & Inclusion of the Laminazione Sottile Group, aimed at promoting the integration and implementation of the DE&I culture in business processes and daily actions.

The main objective of this Policy is to promote diversity in all its forms, combat discrimination and ensure equal treatment for each member of the Organisation, with the ultimate aim of creating an inclusive work environment, where all People feel respected and appreciated, with equal opportunities for growth and development, where different ideas and points of view are valued and encouraged to stimulate innovation and creativity.

The main regulatory references of the Policy are as follows: • The United Nations 2030 Agenda for Sustainable Development and the related Sustainable Development Goals (SDGs); • The United Nations Universal Declaration of Human Rights (1948); • The Declaration on Fundamental Principles and Rights at Work and the ten fundamental Conventions of the International Labour Organisation (ILO); • The United Nations Conventions on the Rights of Women, on the Elimination of All Forms of Racial Discrimination, on the Rights of the Child and on the Rights of Persons with Disabilities; • The Principles of the UN Global Compact and Women’s Empowerment Principles of the United Nations; • The United Nations Guiding Principles on Business and Human Rights (UNGP); • The European Directive 970/2023, known as the Pay Transparency Directive.

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GROUP POLICY DIVERSITY, EQUITY & INCLUSION (DE&I)

2. RECIPIENTS AND FIELD OF APPLICATION This Policy applies to Laminazione Sottile S.p.A. and all its subsidiaries (part of the LS Group).

In particular, this Policy applies to Employees, Collaborators, Corporate Bodies and subjects with whom the LS Group establishes relationships or business relationships that, for any reason and regardless of the type of contractual relationship, operate in the name and on behalf of the Group Companies (hereinafter also “Recipients”).

Subsidiaries are responsible for adopting this document and ensuring compliance with it

3. ISSUE, REVIEW MECHANISM AND TERMS OF VALIDITY This Policy is valid from the date of its issue (indicated on the document).

Any subsequent update repeals and supersedes, from the date of its issue, all previously issued versions.

The Group HR Department is responsible for updating and disseminating this Policy.

The Policy is subject to periodic review (at least five years) and is reissued by the Issuing Body where necessary (in particular in the event of organisational changes, any gaps/critical issues found or if the applicable national and international standards and regulations, referred to as best practices, are subject to change).

4. TERMS AND DEFINITIONS DE&I (Diversity Equity & Inclusion): The term “diversity, equity, inclusion” (DE&I) refers to the set of organisational policies aimed at guaranteeing the same rights and the same opportunities to all, regardless of the differences of individuals. These are three closely related but distinct concepts, which refer to the creation of work environments and societies that are more just, inclusive and representative of human differences.

DIVERSITY: refers to the presence of differences between people that may be visible (gender, ethnicity, age, disability, etc.) or invisible (cultural background, personal experiences, skills, religion, etc.). Enhancing diversity means promoting a context in which differences between people can enrich the working environment.

EQUITY: it is about creating a working environment that offers equal opportunities to all people, ensuring that everyone is guaranteed the same conditions for development, training, promotion and recognition.

INCLUSION: is the process of creating an environment where all people feel accepted, respected and valued for their differences. Every individual, regardless of their characteristics, has the opportunity to fully contribute and feel an integral part of the Company.

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DISABILITY: the term “disability” includes all forms of physical, cognitive, and sensory fragility, even temporary and hidden.

HUMAN RIGHTS: inalienable rights of each person by virtue of their belonging to humanity. These rights are based on recognition of the dignity, freedom and equality inherent in all human beings.

GENDER: set of socially constructed roles, behaviours, activities and attributes that a given society considers appropriate for people of a given sex. Gender is to be distinguished from “sex”, understood instead as the sex assigned at birth, that is, the set of physical and biological characteristics that distinguish females, males and intersex people.

ETHNICITY: human grouping based on community or on the strong affinity of physical-somatic, cultural, linguistic and historical-social characteristics.

SEXUAL ORIENTATION: a person’s emotional, romantic, and/or sexual attraction to individuals of the opposite sex, the same sex or both sexes. It differs from biological sex, gender identity and gender role. In fact, they define, respectively, the genetic sex of a person determined by sex chromosomes, the gender to which they feel they belong and the social norms on the behaviour of men and women related to a given culture and era.

DISCRIMINATION: behaviour (action or omission) that causes unequal treatment of a person or of a group of people, by virtue of their belonging to a certain social group or characteristics or attributes of the individual.

EQUAL OPPORTUNITIES: the need for legal and social equality between people, in order to enhance the gender difference and to establish a fair relationship between the sexes.

WHISTLEBLOWING: spontaneous disclosure by an individual, called a “whistle-blower”, of an offence or irregularity committed within the institution, of which the same has been a witness in the exercise of their functions. The whistle-blower is often an employee but can also be a third party, for example a supplier or a customer.

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GROUP POLICY DIVERSITY, EQUITY & INCLUSION (DE&I)

5. GOVERNANCE, RESPONSIBILITIES AND DISCLOSURES The governance bodies of the LS Group, supported by the Steering Committee and by the Group Sustainability Committee, and with the involvement of the various Departments involved (including but not limited to the Human Resources, Social Sustainability, Compliance and Legal Departments) play a strategic role in the full implementation of this Policy, ensuring the involvement of all workers and collaborators so that they may express behaviours consistent with the values contained therein.

In particular, the following specific responsibilities are defined for the implementation of this Policy:

GROUP HR MANAGEMENT Authorises the company’s DE&I strategy Oversees sharing of the results of DE&I activities with senior management Coordinates the process of defining and updating the proposed corporate strategy in the field of DE&I Supports business functions in the identification and implementation of DE&I initiatives Ensures regular reporting on DE&I on the overall progress of initiatives, also contributing to mandatory and voluntary sustainability reporting Guarantees dissemination of the Policy

ALL THE CORPORATE DEPARTMENTS Contribute, for the organisational areas of relevance, to ensuring application of the plan of initiatives of the inclusion policies in their Team Ensure implementation of the planned initiatives of relevance and guarantee the return of information to the HR Department that supervises the DE&I activities

MANAGEMENT (COMPANY MANAGEMENT) Actively promotes the culture of diversity, equity and inclusion, supporting the initiatives and policies proposed by the Human Resources Department

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In order to ensure continuous improvement of its performance, in relation to the processes covered by this Policy, the LS Group undertakes to identify the most significant performance indicators (KPIs), to set achievable quantitative targets and qualitative objectives and to periodically monitor and report the results achieved in the Annual Sustainability Report.

6. PRINCIPLES AND GUIDELINES OF CONDUCT In their daily activities, each person of the Group is required to commit, with consistency and transparency, to implementing the values and contents of the LS Group Code of Ethics, as well as the principles defined in this DE&I Policy, in order to respect, promote and enhance diversity and to constantly exercising actions aimed at maximum inclusion.

The role of each Person in the Group Each person operating in the Group is required to: • respect the rights and dignity of every person, acting on the front lines to put into practice the ethical principles of fairness, loyalty and integrity; • recognise, accept, promote and enhance diversity at all levels and in all contexts, always contributing to establishing a working climate that promotes dialogue, collaboration and participation of the other, for the generation of ideas and solutions; • communicate clearly and consistently, being sure to modulate own communication (language, style, vocabulary) according to the other, removing obstacles to the active participation of all people, whether colleagues or third parties (e.g. customers or suppliers); • train themselves to recognise and act on their own conscious and unconscious biases, particularly in relationships with others (e.g. colleagues, customers, suppliers).

The role of each Resource Manager Each Group Resource Manager (hereinafter Manager) has the task of setting an example with respect to the DE&I principles contained in this document and of actively disseminating them both internally and externally.

In this regard, Managers are required to intervene in the event of breaches of the afore-mentioned principles, also drawing on the support of the competent Human Resources departments of the Companies. Within this framework, each Manager is required to: • recognise the diversity present within teams; • understand the different and specific contribution that each team member can express, rewarding their merit fairly in all evaluation processes;

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GROUP POLICY DIVERSITY, EQUITY & INCLUSION (DE&I) • create the organisational condition for each team member to express their contribution and potential while respecting personal work-life balance needs, creating a climate that is receptive to the expression of all members; • ensure that fair treatment, inclusion and non-discrimination are guaranteed in the workplace at all levels, promptly intervening whenever they become aware of behaviours that do not guarantee respect for the other; • promote, in cascade among their collaborators, the afore-mentioned principles.

7. IMPLEMENTATION OF DE&I PRINCIPLES IN COMPANY PROCESSES The fundamental principles of conduct on which this Policy is based are the following: • Not tolerating, allowing or engaging in any conduct that may constitute discrimination or denial of the diversity of Persons, in any form, in the course of business or professional activity and in relations with persons, whether employees of the LS Group or of Third Parties; • Promoting a preventive culture based on the principle of “zero tolerance” towards all forms of discrimination or denial of diversity; • Establishing adequate controls and preventive measures (including, but not limited to, through the internal rules and procedures approved for this purpose) for the identification, control, mitigation and prevention of all forms of discrimination or denial of diversity, and in particular in all activities involving relationships with third parties; • Implementing appropriate training programs and communication plans for all Group personnel regarding this Policy and, in particular, the content of the Code of Ethics; • As part of the company program aimed at preventing any form of discrimination or denial of the diversity of People, all employees and collaborators are required to sign a letter of acceptance of the LS Group Code of Ethics at the time of their hiring.

The Policy refers to all organisational processes, whether they concern the company population or are directed towards the outside world, and must be implemented and applied by all the competent company departments.

HR Processes The Human Resources Department (of each Group Company) assumes the role of constant stimulus to the inclusion and enhancement of diversity through the processes managed and of “guarantor” of equal opportunities in all phases of the person’s working life cycle, from selection to termination of the employment relationship.

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Within this framework, all Persons belonging to the Human Resources Department must: • strive, each for their own scope of activity and integration with business processes, to promote the adoption of and compliance with the Group’s DE&I principles and guidelines; • within the scope of the processes of competence (management, recruitment, selection, training, evaluation, development, remuneration, welfare, caring, etc.) they must promote widespread dissemination and compliance with the corporate principles of DE&I, ensuring achievement of the following objectives: º encourage the dissemination, at all organisational levels, of a culture open to the recognition of differences, the sharing, adoption and acquisition by all people of the Group of behavioural models that make explicit the ability to act to challenge stereotypes, highlighting the added value brought by diversity and providing overarching behavioural skills that facilitate integration, acceptance and the creation of an inclusive network of relationships; º ensure equal opportunities and equity in terms of gender balance at all organisational levels, remuneration treatments, enhancement of skills and meritocratic standards, as well as transparent growth paths, protection of certain “categories” that may be more subject to the risk of discrimination (just as an example: women, seniors, people with disabilities - and all those vulnerabilities that changes in the context could cause) and diversification of the company population in all areas of the organisation; º ensure the application of common meritocratic standards and the appropriate use of diversity and inclusion enhancement tools, in compliance with the principles defined by this Policy and by the Code of Ethics; º adopt communication methods that are fully accessible in physical, linguistic and cultural terms; º promote and enhance inclusive strategies and behaviours to consolidate the social impact and the Group’s inclusive and non-discriminatory organisational model, both internally and externally, including through employer branding actions (e.g. in schools and universities); º promote the implementation of adequate layouts of offices, toilets and workplaces in general, also in terms of reasonable accommodations, understood as necessary and appropriate modifications and adaptations that do not impose a disproportionate or excessive burden, to guarantee all people the enjoyment and exercise, on an equal basis with others, of all human rights and fundamental freedoms, as required by current legislation.

Internal communication processes Internal communication processes, which refer to all those activities aimed at involving people through the Group’s institutional channels, must guarantee achievement of the following objectives: • adopt channels, means and tools of internal communication that are fully accessible in physical, linguistic and cultural terms;

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GROUP POLICY DIVERSITY, EQUITY & INCLUSION (DE&I) • adopt accessible communication channels, means and tools to promote the maximum dissemination of the DE&I, caring and welfare initiatives made available by the LS Group to colleagues, including at an international level; • ensure the dissemination of inclusive strategies to consolidate, among people, an organisational model based on respect for and enhancement of diversity.

External communication processes The external communication processes, which refer to all those activities aimed at communicating to the public through the Group’s institutional channels, must guarantee achieving of the following objectives: • promote the dissemination of a non-conformist and inclusive culture, highlighting the added value brought by diversity and avoiding a stereotypical representation of society; • promote and enhance inclusive strategies and behaviours to consolidate the Group’s social impact that is fair, inclusive and non-discriminatory, towards the outside, including through employer branding actions; • adopt external communication channels, means and tools that are fully accessible in physical, linguistic and cultural terms.

8. DE&I OBJECTIVES AND ACTIONS The Laminazione Sottile Group undertakes, by issuing this Policy, to: • foster and promote a culture of diversity, equity and inclusion (within and outside the Group itself), guaranteeing each employee equal conditions and opportunities, without distinction of age, sex and gender identity, sexual orientation, ethnicity/culture, religion, physical condition and disability, economic condition, political and trade union opinion and more besides.

• inform and raise awareness among all workers about the rights and duties for the prevention and removal of all discriminatory behaviour, for the promotion of a working environment that ensures respect for the dignity of each person.

To achieve this, the LS Group undertakes to pursue a series of objectives over time and to implement a plan of targeted actions, which will focus on the following areas: 1) Gender Equality (one of the most visible and concrete aspects of inclusion policies): Directly addressing gender inequalities, such as pay gaps and equal opportunities, enables tangible and measurable results (KPIs) to be achieved in a timely manner. It also means responding to a social requirement and at the same time making evident and tangible a commitment to all our stakeholders (employees, customers, suppliers, local communities, etc.).

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2) Removal of any obstacles and encouraging of all issues related to Diversity & Inclusion, such as: • Ethnicity • Disability • Sexual orientation • Age. The objective for the three-year period 2026-2028 is to reduce, where present, the gender gap in the workforce and the gender pay gap by defining actions in line with the strategic plan presented by the HR Department.

The HR Department processes involved in defining specific and measurable KPIs for reducing the gender gap in workforce and gender pay gap are: • Employer Branding: Focus on STEM disciplines and pathways, both for testimonials and career days in Women Targets • Recruitment and Selection: Definition of actions aimed at reducing the gender gap in the workforce compared to the reference band • Training and Development: Initiation of awareness training courses: º cascading from management to all LSG employees on DE&I issues º unconscious bias and gender stereotypes º inclusive language • Remuneration: Definition of a dedicated budget for reduction of the gender pay gap compared to the reference category/”band” 3) Welfare: : Definition of actions aimed at promoting a better work-life balance 4) Communication: • Initiate internal communication campaigns on DE&I issues: promote a culture of diversity and a work environment that ensures respect for the dignity of each person • Initiate a staff interview plan for publication on internal and external channels, with a focus on their experience related to DE&I topics

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GROUP POLICY DIVERSITY, EQUITY & INCLUSION (DE&I) 5) Local Communities: Activate partnerships with associations active on DE&I issues, present in the areas where the various companies operate 6) Certifications: Obtaining of the following certifications: • UNI PdR 125:2022 certification for gender equality, for Italian companies • EDGE Certification relating to the Corporate Gender Gap, for Italian and foreign companies 7) Monitoring and pursuit of the following objective: zero cases of reports concerning discrimination within the Group.

9. REPORTS The LS Group undertakes to promote an open culture, which does not allow discriminatory or retaliatory actions of any kind against the authors of any reports of violations of this Policy, and to take all necessary measures to guarantee confidentiality and discretion to the reports received (in accordance with the applicable laws and to the extent permitted by any investigations to be carried out).

Recipients are required to report any other breaches of this Policy, alternatively: • through the channels provided for by the Whistleblowing Policy (available on company websites); • to the HR Contact Person of their Group Company and/or to the Group HR and/or Compliance Department; • to their direct Manager or, where this is involved, to their line manager, on the basis of their reporting lines, who in turn will involve the HR Contact Person and/or the Group HR and Compliance Departments; • through any other channel available in force at the specific Group Company.

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10. DISSEMINATION The LS Group promotes the communication of this Policy, in a manner suitable for dissemination to all Recipients and the implementation of specific training programmes, in order to ensure effective knowledge by its personnel.

LATEST REVISION October 27, 2025

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