Diversity & Inclusion

Fair employment. Inclusive recruitment. Respectful relationships.

Policy commitment

Evergreen Talent Group is committed to equal opportunity, dignity and respect in its own workplace and in every recruitment service it delivers. Decisions will be based on lawful, objective and job-relevant criteria, with barriers identified and removed wherever reasonably possible.

Policy status. This policy is non-contractual, does not reduce any statutory right and may be updated to reflect legal or operational change. Where law provides a higher standard, the law prevails.

1. Purpose and commitment

Evergreen Talent Group ("Evergreen") values difference and believes that fair access to opportunity improves decision-making, candidate outcomes, employee engagement and business performance. Evergreen will maintain a working and recruitment environment in which people are treated fairly, can contribute without discrimination, and are protected from harassment, sexual harassment, bullying and victimisation.

This policy sets the minimum standard for how Evergreen:

• recruits, employs, develops, rewards and manages its own people;

• advertises vacancies, sources and assesses candidates, creates shortlists and advises clients;

• responds to requests for reasonable accommodation and accessible communication;

• prevents and addresses inappropriate conduct by employees and third parties; and

• uses candidate data, analytics and recruitment technology in a fair and accountable manner.

2. Scope

This policy applies to all Evergreen employees, directors, workers, interns and contractors, regardless of status, seniority, hours, location or working arrangement. It also governs Evergreen's dealings with job applicants, registered candidates, placed candidates, clients, prospective clients, suppliers, visitors and other business contacts.

It applies to conduct in the office, on client sites, during business travel and events, in hybrid or remote work, and through email, telephone, messaging, video calls and work-related social media. Irish law is the baseline for operations in Ireland; where Evergreen recruits or operates in another country, the applicable local law must also be followed.

No discriminatory instruction

Evergreen will not action a client request to prefer, exclude or disadvantage a person because of a protected characteristic. The instruction must be challenged, documented and escalated; Evergreen may refuse or end the assignment or client relationship.

3. Legal and regulatory framework

This policy is designed to align with the Irish legal framework in force at 19 August 2026, including the following legislation and codes, each as amended, replaced or extended:

• Employment Equality Acts 1998–2015, which prohibit discrimination in employment, access to employment, promotion, training and pay, and apply to employment agencies and discriminatory advertising;

• Equal Status Acts 2000–2018, where Evergreen provides goods or services falling within those Acts;

• Employment Equality Act 1998 (Code of Practice) (Harassment) Order 2012;

• Safety, Health and Welfare at Work Act 2005 and the WRC/HSA Code of Practice for Employers and Employees on the Prevention and Resolution of Bullying at Work 2021;

• Employment Agency Act 1971 and associated regulations;

• Data Protection Act 2018 and Regulation (EU) 2016/679 (GDPR);

• Gender Pay Gap Information Act 2021 and regulations, where the applicable employee threshold is met;

• Work Life Balance and Miscellaneous Provisions Act 2023 and other applicable family-leave and employment-protection legislation;

• Protected Disclosures Act 2014, as amended by the Protected Disclosures (Amendment) Act 2022; and

• Regulation (EU) 2024/1689 (EU AI Act), the Regulation of Artificial Intelligence Act 2026 and related Irish implementing measures, where recruitment or employment AI is used.

The Irish Human Rights and Equality Commission Act 2014 establishes the national human-rights and equality body and forms part of the wider equality framework. This policy is not a substitute for legal advice and must be read with Evergreen's recruitment, data-protection, dignity-at-work, grievance, disciplinary, protected-disclosures and flexible/remote-working procedures.

4. Protected grounds and Evergreen's wider standard

The Employment Equality Acts prohibit discrimination on nine grounds:

Evergreen's behavioural standard is intentionally wider. It also rejects unfair treatment connected with gender identity or expression, sex characteristics, neurodiversity, socio-economic background, caring responsibilities, health status, accent or language, trade-union activity, political opinion, or any other irrelevant personal characteristic. These additional categories are company standards and are not presented as a statement that each is a separate statutory equality ground under the Employment Equality Acts.

5. What this policy prohibits

Prohibited conduct can be written, spoken, visual, physical or digital. It includes jokes, images, banter, exclusion, stereotyping, slurs, unwanted contact, intrusive questions, offensive posts, retaliation, or allowing a client or other third party to subject someone to such treatment.

6. Equal opportunity in Evergreen employment

6.1 Recruitment, progression and termination

• Roles will have a clear purpose and objective, job-relevant essential criteria. Requirements such as length of experience, qualifications, travel or location must be genuinely necessary and proportionate.

• Vacancies will use inclusive language, accessible channels and, where practicable, transparent pay information. Applicants will be offered a clear route to request accommodation.

• Selection, promotion, training, allocation of accounts, performance assessment, commission, pay, benefits, redundancy and termination decisions will be based on documented, consistent and lawful criteria.

• Interviewers and decision-makers will identify conflicts of interest and avoid questions or assumptions about protected or irrelevant personal matters.

• Part-time, fixed-term, hybrid, remote-working and family-leave arrangements will not result in unjustified disadvantage.

6.2 Equal pay and reward

Evergreen supports equal pay for like work, work rated as equivalent and work of equal value, subject only to lawful and objectively supportable differences. Salary, bonus and commission decisions must follow approved criteria, be recorded accurately and be reviewed for unexplained patterns. Gender pay gap reporting will be completed when Evergreen falls within the statutory threshold, and earlier voluntary analysis may be undertaken where data is sufficiently reliable and privacy can be protected.

6.3 Reasonable accommodation and accessibility

Evergreen will consider effective and practical measures that enable a person with a disability to access recruitment, participate in work, progress or undertake training, unless the measures would impose a disproportionate burden when the relevant statutory factors and available assistance are considered.

• Applicants and employees may request accommodation at any stage and do not need to disclose more medical detail than is reasonably necessary to identify support.

• Possible measures include accessible formats, adjusted interview methods or timing, assistive technology, modified equipment, changes to duties or working arrangements, and accessible premises or meeting locations.

• Requests will be discussed promptly and individually. Evergreen may seek appropriate occupational or specialist input with the person's knowledge and in line with data-protection law.

• A request will not count against an applicant or employee. If the preferred measure is not reasonably available, Evergreen will explore effective alternatives before deciding.

7. Inclusive and lawful recruitment services

Every recruiter, account lead and hiring adviser must apply the following controls to client assignments.

Genuine occupational requirements

Any proposal to rely on a statutory exception or genuine occupational requirement must be exceptional, narrowly interpreted, documented and approved by the Managing Director with legal advice where appropriate.

8. Recruitment technology, data and AI

Technology must support—not replace—accountable human judgement. Before an AI or automated tool is used for advertising, sourcing, CV parsing, ranking, interviewing, assessment, monitoring or employment decisions, Evergreen will:

• document the purpose, owner, supplier, data inputs, outputs, affected people and decision impact;

• assess equality, accessibility, accuracy, privacy and security risks, including whether a data-protection impact assessment is required;

• determine whether the tool is prohibited, high-risk or otherwise regulated under the EU AI Act and Irish implementing measures, and follow applicable commencement dates;

• test and monitor for unjustified adverse impact, data drift and proxy discrimination, using appropriately representative evidence where lawful;

• maintain meaningful, trained human oversight and a route for an individual to seek review or challenge an outcome;

• give candidates and employees appropriate, understandable information about material use of automation; and

• retain only proportionate records and stop or suspend use where a material risk cannot be controlled.

Evergreen will not use AI to infer emotions of workers or job applicants except in any strictly limited circumstance expressly permitted by applicable law. Evergreen will not make a solely automated decision producing legal or similarly significant effects unless a valid legal basis and all required safeguards exist.

9. Respect, dignity and third-party conduct

Everyone covered by this policy must communicate professionally and respect personal boundaries. Managers must act when they observe or receive information about possible misconduct; silence or informal culture is not a defence.

• The standard applies to conduct by colleagues, managers, candidates, clients, suppliers, visitors and other business contacts.

• Work events, client entertainment, messaging groups and work-related social media are covered, including conduct outside normal hours where there is a work connection.

• A person may experience prohibited conduct even if it was not directed at them. Intent is relevant to context but does not determine whether conduct had a prohibited effect.

• Evergreen will take reasonable steps to protect staff and candidates from third-party harassment, including warnings, changed contact arrangements, removal from assignments or ending a relationship.

10. Raising a concern or complaint

A person is encouraged to raise a concern early, but may use a formal route immediately. Nothing in this policy requires a person to confront the alleged respondent.

Confidentiality will be respected as far as reasonably practicable, but cannot be guaranteed where information must be shared to investigate, ensure fair procedures, protect a person or comply with law. Knowingly false or malicious complaints may be addressed under the disciplinary procedure; a complaint that is not upheld is not, by itself, false or malicious.

11. Protection from retaliation and external rights

Evergreen prohibits victimisation, penalisation or retaliation against anyone who raises a concern in good faith, requests accommodation, supports another person, gives evidence or participates in a process. Suspected retaliation should be reported immediately and may be treated as serious misconduct.

Internal action does not remove any right to contact the Workplace Relations Commission, Irish Human Rights and Equality Commission, Data Protection Commission, Health and Safety Authority, An Garda Síochána or another competent body. Statutory time limits continue to run while an internal process is under way. A concern about relevant wrongdoing may also fall under Evergreen's Protected Disclosures Policy.

12. Roles and accountability

13. Data protection and equality monitoring

Evergreen may monitor workforce or recruitment outcomes to identify barriers and evaluate this policy. Equality data—particularly information revealing racial or ethnic origin, religious or philosophical beliefs, health, sexual orientation or other special-category information—will be handled only where a valid legal basis and Article 9 condition apply.

• Collection will be transparent, proportionate and limited to a defined purpose. Participation in optional self-identification will be voluntary where appropriate.

• Monitoring data will be separated from selection decisions, access-controlled and reported in aggregated or anonymised form wherever practicable.

• Small-number reporting that could identify an individual will be suppressed or combined.

• Retention periods, sharing, security and individual rights will follow Evergreen's privacy notices and data-retention policy.

• Consent will not be used as the default employment-law basis where the power imbalance means it is unlikely to be freely given.

14. Training, breaches and continuous improvement

Evergreen will provide proportionate induction and refresher training for employees, with additional training for managers, recruiters, interviewers, complaint handlers and users of recruitment technology. Learning will cover inclusive advertising, objective assessment, reasonable accommodation, harassment, data protection, client challenge and AI oversight.

A breach by an employee may lead to action under the disciplinary procedure, up to and including dismissal in serious cases. Breaches by contractors, candidates, clients or suppliers may lead to removal from an assignment, restricted contact, contract remedies or termination of the relationship. Action will be proportionate and taken through a fair process.

At least annually, Evergreen will review relevant complaints, recruitment outcomes, accommodation requests, training completion, pay and progression patterns, client issues and technology risks. The review will seek practical improvements and will protect personal data.

15. Review and approval

The Managing Director owns this policy. It will be reviewed at least annually and sooner following a material complaint, organisational change, regulatory development or change in Irish law. Substantive changes will be communicated to those affected.

Appendix A — Recruitment equality decision check

Before a vacancy is advertised, a shortlist is issued or a candidate is rejected, the responsible consultant should be able to answer “yes” to each question:

1. Are the criteria genuinely necessary for the work and proportionate to the role?

2. Would I apply the same evidence threshold to every candidate?

3. Have I removed wording, channels or process steps that could create an unnecessary barrier?

4. Has the candidate been told how to request reasonable accommodation, and has any request been considered individually?

5. Can I explain the decision using documented, job-related evidence without referring to a protected or irrelevant personal characteristic?

6. If technology influenced the outcome, has a trained person meaningfully reviewed it and can Evergreen explain the material factors?

7. Have I challenged and escalated any client request that could be discriminatory?

8. Are the records accurate, proportionate, secure and retained only for the approved period?

Stop and escalate

If any answer is “no” or uncertain, pause the decision and consult the Managing Director or designated EDI lead before proceeding.

Appendix B — Key official references

These official sources informed version 1.0. Legislation and guidance can change; the current version should be checked when the policy is reviewed.

1. Workplace Relations Commission — Employment Equality

2. Electronic Irish Statute Book — Revised Employment Equality Act 1998

3. Electronic Irish Statute Book — Revised Equal Status Act 2000

4. IHREC — Discrimination Against Workers: Recruitment and Promotion

5. Electronic Irish Statute Book — Harassment Code of Practice 2012

6. HSA — Prevention and Resolution of Bullying at Work Code

7. Workplace Relations Commission — Employment Agencies

8. Data Protection Commission — Guidance

9. Workplace Relations Commission — Role under the EU AI Act

10. Electronic Irish Statute Book — Regulation of Artificial Intelligence Act 2026

11. Government of Ireland — Gender Pay Gap reporting

12. Electronic Irish Statute Book — Work Life Balance and Miscellaneous Provisions Act 2023