1.INTRODUCTION

The Executive Committee of Grupo Kairós has approved this Sustainability & ESG (Environmental, Social and Governance) Policy to reaffirm its commitment to sustainable development and the implementation of ESG criteria. This policy is aligned with the company’s purpose: to foster the holistic growth of people while contributing to a better world through diverse talent and responsible technology.

This policy defines the purpose, strategy, scope, key objectives, guiding principles, commitments to our Stakeholders, and the corresponding communication and dialogue channels. It also outlines its interrelationship with other corporate policies and establishes monitoring systems and oversight mechanisms for corporate sustainability matters. These elements guide our business activities to ensure that our business model contributes to the creation of shared value and to a more prosperous and sustainable society.

2.PURPOSE

The purpose of this Policy is to establish a regulatory framework that guides the environmental, social, economic and governance performance of Grupo Kairós, with a long-term shared value creation approach. It also seeks to meet the needs and expectations of all stakeholders while ensuring regulatory compliance for business operations.

This Policy therefore serves as a reference framework for all employees and strengthens Kairós’ public positioning in ESG matters.

3.SCOPE

This Policy is mandatory for all companies that are part of Grupo Kairós and extends to its suppliers and business partners, both within and outside Spain, Mexico and Peru. All parties involved must be familiar with, understand and comply with the guidelines set out herein.

This commitment is particularly relevant for members of the Board of Directors and the Executive Team, who are responsible for actively promoting its implementation at all levels of the organization through leadership by example, supervision and the promotion of guiding principles within their areas of responsibility, integrating them into the way they think, communicate and act.

4.OUR STRATEGY

Grupo Kairós’ Sustainability & ESG strategy to help build a better world through diverse talent and responsible technology is based on three fundamental pillars:

• Environmental (E) - Waste reduction and awareness. We are committed to reducing our carbon footprint and resource consumption through a remote work model and the optimization of internal processes, minimizing waste generation. Responsible technology and service digitalization are key drivers of corporate sustainability and social awareness.
• Social (S) - Education, diversity and inclusion. We accelerate education, promote diversity and foster inclusion to build a more equitable society. Our professional development programs are designed to enhance talent and ensure that all employees, regardless of background, can grow in an inclusive and motivating environment.
• Governance (G) - Innovative and ethical governance. We implement an ethical and transparent governance system, ensuring that data management and security are priorities in our practices. Ethics are embedded across all operations and processes, supported by a compliance framework and high standards of transparency and accountability.

In addition, as part of our commitment to a sustainable present and future through innovation in corporate and business initiatives, we directly contribute to 16 of the 17 United Nations Sustainable Development Goals (SDGs) under the 2030 Agenda.

This strategic contribution is detailed in Grupo Kairós’ 2024 ESG Report.

5.GUIDING PRINCIPLES

To achieve the purpose of this Policy and the sustainability objectives outlined in our ESG Report, the following guiding principles are established:

• Promote progress towards the United Nations 2030 Agenda for Sustainable Development and the Sustainable Development Goals (SDGs), with particular focus on the nine most closely linked to our business activity, as well as the principles of the UN Global Compact, adopting and promoting their dissemination.
• Identify and integrate sustainability-related opportunities and risks into the company’s business model, strategy and sustainability processes.
• Incorporate Sustainability and ESG criteria into all organizational processes and decision-making, providing stakeholders with the necessary tools to ensure effective implementation.

Environmental

Environmental performance: We work to ensure that all our activities, processes and services respect the environment and comply with applicable regulations, striving to exceed minimum legal requirements whenever possible.

Responsible resource consumption: We optimize the use of key resources (energy, water, paper) and electronic devices, applying measures to minimize consumption and encourage recycling.

Waste management and reduction: We promote a circular economy by reducing, reusing and recycling waste. Electronic equipment is donated whenever possible, extending its useful life and benefiting non-profit organizations.

Supplier environmental assessment and control: We monitor the environmental performance of our suppliers, ensuring alignment with our sustainability commitments and high environmental standards.

New technologies to minimize environmental impacts: We encourage innovation in new technologies, services and work models (remote work, digital tools) to reduce environmental impacts and help our clients become more sustainable.

Environmental participation and awareness: We establish awareness campaigns, training initiatives and volunteer projects focused on environmental protection and awareness.

Social

Human Rights: Human dignity and rights are a priority in all our activities.

Job creation: We are committed to creating stable, high-quality employment in flexible environments that promote professional growth.

Talent management: We enhance employee skills and invest in training plans that support professional development and employability, as well as attract new talent through partnerships with academic institutions and associations.

Responsible and inclusive R&D&I: We manage innovation and promote research and development of new products and services, ethically integrating Artificial Intelligence and other disruptive technologies, and building client partnerships to create societal value and competitive differentiation.

Occupational Health and Safety: We ensure the highest levels of workplace safety and protect the health of all Group professionals.

Work-life balance, wellbeing and benefits: We promote policies that support work-life balance, flexible working hours, remote work and digital disconnection, while caring for emotional and physical health and providing social benefits to employees.

Diversity and inclusion

Equal opportunities: We guarantee equality of opportunity, non-discrimination and inclusion regardless of race, culture, sexual orientation, religion, age, gender, disability or any other dimension of diversity.

Gender equality: We promote gender balance and increase the presence of women in leadership positions to reduce the gender gap.

Disability inclusion: We integrate people with diverse abilities and adapt workplaces to ensure universal accessibility.

Social commitment: We develop initiatives aligned with our business strategy that generate positive social and environmental impact while contributing to the UN 2030 Agenda SDGs.

Customer satisfaction: We meet customer expectations regarding the quality and delivery of Grupo Kairós’ services.

Supplier integrity: We strengthen supplier relationships and promote mutual collaboration.

Governance

Compliance: We promote compliance with applicable legislation in all jurisdictions where Grupo Kairós operates and adopt international standards where legal frameworks are insufficient. Our daily activities are guided by our Purpose, Mission, Vision, Corporate Values and Compliance model.

Anti-corruption and anti-bribery: We strengthen and ensure the application of our Anti-Corruption Policy and Code of Ethics through control measures, awareness initiatives, training and communication.

Human rights and due diligence: We go beyond compliance with the UN Guiding Principles on Business and Human Rights to prevent violations across the entire supply chain, promoting an inclusive, shared-value business model.

Transparency: We apply policies and guidelines that ensure transparency in communications.

Stakeholder engagement: We promote proactive, two-way dialogue with stakeholders to address their needs and expectations.

Information security and data protection: We protect personal data in accordance with applicable regulations, including the EU GDPR and the highest international security standards.

Fiscal and financial responsibility: We meet tax obligations and promote policies that ensure financial strength and long-term company development.

Whistleblowing channel: We strengthen confidential and anonymous reporting channels for irregularities, including human rights violations, corruption, bribery, illegal activities or workplace harassment.

Corporate reputation: We safeguard our corporate image through rigorous management grounded in transparency, ethics, integrity and quality.

6.COMMITMENTS TO OUR STAKEHOLDERS

In order to comply with these Guiding Principles, we establish the following commitments to our stakeholders:

Commitment to employees

To create stable, sustainable, high-quality employment within flexible work environments that foster innovation and the development of new products and services in diverse and dynamic settings. We promote the attraction, integration and development of professional talent, regardless of race, gender or personal circumstances, ensuring equal opportunities for all, with particular focus on work–life balance and on the safety, health and wellbeing of our entire workforce.

Commitment to customers

We develop products and services under the highest quality standards, meeting sustainability needs and exceeding expectations, while ensuring strict data confidentiality in line with Grupo Kairós’ Code of Ethics and Conduct.

Commitment to suppliers 

We extend this Policy’s principles across our supply chain, prioritizing suppliers with high standards in environmental, social and economic sustainability and human rights, ensuring fair and impartial treatment and encouraging local sourcing and inclusive employment centers.

Commitment to regulators

We ensure compliance with applicable legislation and maintain open, constructive dialogue with regulatory bodies to promote collaborative solutions that benefit society.

Commitment to the environment and local communities

We develop initiatives that leverage talent and technology to support sustainable development in the communities where we operate, focusing on environmentally respectful technologies, education, professional development, diversity and equal opportunities.

7.FUTURE STRATEGIC LINES 2024 - 2026

Environmental Action Plan 2024-2026

1.Carbon footprint and climate neutrality:

We aim to reduce our carbon footprint through a combination of initiatives. These include optimizing internal processes, adopting renewable energy sources, and promoting energy efficiency across all our operations. In addition, we will explore options to offset unavoidable emissions, such as investing in reforestation projects, the restoration of degraded ecosystems, and clean energy generation, ensuring that these projects meet internationally recognized certifications. We will also develop awareness programs to encourage our employees and partners to actively contribute to climate neutrality.

2. Biodiversity and environmental regeneration:

We are committed to the conservation and restoration of biodiversity in areas affected by our activities, working alongside NGOs and other partners on projects aimed at restoring and protecting ecosystems.

We pledge to preserve and regenerate biodiversity in areas impacted by our direct and indirect activities. This includes identifying and prioritizing critical ecosystems for restoration and collaborating with specialized NGOs, local communities and other strategic partners. We will develop habitat restoration projects, native species planting initiatives and the recovery of ecological corridors.

3. Circularity and regenerative economy:

We seek to develop partnerships with clients and suppliers to foster a circular economy throughout our value chain, driving the transition through strategies that include the design of more durable, reusable and recyclable products, as well as the promotion of business models based on resource reuse and sharing. In addition, we will explore the adoption of innovative technologies that optimize resource recovery and reuse, promoting a regenerative economy that benefits both the environment and our communities.

4. Environmental transparency and reporting:

We will strengthen our commitment to transparency through environmental reporting aligned with global standards such as ISO 14001, Science-Based Targets and the GRI (Global Reporting Initiative) framework. These reports will highlight not only our actions and achievements, but also the areas where we face challenges, ensuring an honest and constructive approach. 

We will publish an annual Non-Financial Information Statement (NFIS), detailed and accessible to all stakeholders, including shareholders, employees, clients and local communities. This report will reflect our progress towards environmental objectives, supported by quantitative metrics that demonstrate our performance and positive environmental impact.

Social Action Plan 2024-2026

1. Human rights and decent work:

We aim to implement policies and processes that ensure respect for human rights across all our operations, including regular audits to identify potential risks of labor rights violations.

We are committed to preventing any form of forced or child labor or unfair working conditions within our supply chain by conducting periodic supplier assessments.

We will promote pay equity across genders, cultures and abilities, ensuring that professional development opportunities are fair and equitable for all employees. To this end, we will adopt clear, auditable indicators to measure and support our progress toward genuine pay equity.

2. Wellbeing and holistic health:

We promote a healthy work–life balance through flexible working hours, remote work arrangements, and emotional and psychological support programs.

We provide benefits focused on physical and mental wellbeing, including enhanced health insurance covering specialized services, group sports activities, ergonomics programs and mindfulness workshops. In addition, we encourage participation in holistic wellbeing initiatives that include physical activities and nutritional guidance.

We conduct awareness campaigns on occupational health and safety, with a particular focus on risks associated with remote and technology-driven work environments.

We will implement emergency response drills and training to ensure a safe working environment both in offices and in remote work settings.

3. Diversity, inclusion and equal opportunities:

We aim to implement mentoring and professional development programs specifically designed to support the advancement of women and historically underrepresented groups into leadership roles. To achieve this, we will establish measurable objectives and report annually on our progress.

We promote recruitment policies that prioritize cultural, functional and gender diversity, ensuring that our workforce reflects the diversity of the communities in which we operate and fosters a workplace culture that celebrates and respects differences.

We will deliver awareness workshops on unconscious bias and inclusive practices, ensuring that leaders and employees are equipped to contribute to an equitable and respectful work environment.

4. Community impact and education:

We will continue to design social responsibility programs focused on technological training for young people and disadvantaged communities, in collaboration with NGOs and local universities, with a strong emphasis on digital skills for employability and professional development.

We encourage corporate volunteering by enabling employees to dedicate paid time to social initiatives aligned with our values, promoting positive impact through mentoring, educational activities, project participation and emergency support.

In addition, we will explore opportunities to engage in environmental education and sustainability projects, ensuring that our actions contribute to long-lasting positive impact in the communities where we operate.

Governance Action Plan 2024–2026

1. Ethics and regulatory compliance:

We will keep our Code of Ethics and Conduct up to date and under regular review, establishing clear standards and mandatory compliance for employees, executives and external partners.

The Code sets out clear principles and applies to all employees, executives and external partners, who receive periodic training to ensure awareness and effective implementation. In addition, we operate confidential whistleblowing tools and monitoring systems to address any non-compliance promptly.

We will conduct annual compliance reviews to ensure alignment with local and international laws in all countries where we operate, including proactive monitoring of legislative changes to keep our practices current and compliant.

2. Anti-corruption and fraud prevention:

We implement internal control systems that include strict policies to prevent money laundering, corruption and fraud across our operations and supply chain. These include financial and operational controls, as well as periodic audits to ensure compliance.

We will continue to assess our business partners and suppliers to identify and mitigate risks related to illicit activities, applying strict due diligence criteria. Where risks are identified, we will implement corrective measures or terminate the commercial relationship as appropriate.

3. Transparency and responsible communication:

We publish annual sustainability reports aligned with recognized standards (GRI, SASB, ISO 26001), openly sharing our ESG performance.

We ensure that our policies and practices are accessible and understandable to all stakeholders, fostering constructive, two-way dialogue.

We promote responsible communication across all channels, safeguarding the accuracy and integrity of our public statements and marketing communications.

4. Data protection and cybersecurity:

We give the highest priority to the privacy and security of data belonging to our clients, employees and partners, implementing advanced protection systems in accordance with the EU General Data Protection Regulation (GDPR – Spain), the Federal Law on the Protection of Personal Data Held by Private Parties (Mexico), Supreme Decree No. 003-2013-JUS (Peru), and other applicable local regulations. These measures include advanced encryption, strict access controls and anonymization processes where appropriate.

We conduct regular cybersecurity testing, including attack simulations, to ensure system integrity and minimize risks.

We design internal cybersecurity incident management protocols to ensure a swift and effective response to any data breach.

We promote continuous cybersecurity training for our employees, increasing awareness and reducing risks associated with human error.

5. Diverse and participatory governance:

We foster a diverse leadership structure, ensuring balanced representation of gender, generations and perspectives at strategic decision-making levels.

We establish a direct channel with the ESG Department to ensure the participation of employees and other stakeholders in sustainability-related decisions.

This channel enables continuous dialogue and ensures that governance, environmental and social responsibility initiatives are aligned with stakeholder needs and expectations.

8.APPROVAL AND ENTRY INTO FORCE

At the proposal of Grupo Kairós’ Executive Committee, this Sustainability & ESG Policy was approved at its meeting held on December 4, 2024.