Statement of the Diversity and Inclusion policy

1.0

Spuerkeess’ diversity and inclusion policy aims to provide everyone with a working environment that respects differences in values, age, gender and sexual orientation, disability, health status, ethnic and cultural origin, lifestyle, religion, political orientation and/or labor union involvement.

Diversity and Inclusion is an internal strategic programme that supports the Bank’s ambition. It focuses on the visible and invisible differences impacting everyone within Spuerkeess. The impact can manifest itself in areas such as human resources, product development, communication, etc.

With regard to service providers, subcontractors and external staff, the commitments are limited to a contractual obligation accepted by the latter and the controls and verifications of the Bank are limited to due diligence.

Spuerkeess’ diversity and inclusion policy complements the Code of Conduct by promoting collective collaboration, inclusive and professional behaviour, and mutual respect. It establishes a formal and explicit framework to promote diversity and inclusion within the company.

Since the signing of the “Lëtzebuerg Diversity Charter” in 2020, we have committed to:

• raise awareness, train and involve decision-makers and employees in the challenges of diversity as a source of enrichment, innovation, progress and social cohesion;
• define a diversity policy and implement practices and action plans that consciously integrate the management of people’s individual differences;
• apply the principles of equal opportunity and the promotion of diversity both in the decision-making and management processes of the company and in the management of its human resources;
• regularly assess these practices, their results and effects;
• communicate to all the company’s stakeholders the commitments made and the concrete results of the actions carried out; - encourage all its partners to work towards non-discrimination and the promotion of diversity.

The HR & People Management Business Unit:

• Manages and organizes annual diversity, equality and inclusion trainings and programs
• Ensures that effective procedures and mechanisms are in place to support this policy
• Leads and supports the implementation of this policy for a diverse and inclusive environment

Where appropriate, the Executive Committee, heads of departments, branch managers, heads of divisions and heads of services will be responsible for ensuring that all grievances due to discrimination are expressed through appropriate channels, while encouraging officers to use the existing system if necessary.

Spuerkeess is committed to ensuring the absence of discrimination in all areas and promotes an inclusive culture.

To create this enriching environment, we act on 4 levers:

• Staff: Spuerkeess’ staff benefits from external recruitment and internal mobility processes based on principles of non-discrimination and inclusion, promoting diverse teams and optimal integration.
• Working conditions: The Bank ensures fair and non-discriminatory working conditions, while paying particular attention to the well-being of employees at all stages of their professional lives (individualised support, health/well-being, work-life balance).
• Skills and access to hierarchical positions: It encourages skills development and access to hierarchical positions through a varied training offering and individual support, by opening these opportunities to all qualified and motivated employees.
• Involvement: The Bank seeks to involve all stakeholders, including the Executive Committee, team leaders, HR and employees, through initiatives such as the Diversity and Inclusion Working Group and the SPARK Idea Box, in order to foster an environment where everyone is encouraged to share their point of view and actively collaborate.

The diversity and inclusion policy, and thus the resulting statement, are reviewed at least annually or when relevant practices and/or regulatory aspects require it.