Purpose
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The purpose of this Policy is to define the general principles and provide a basis for Metasite’s Environmental, Social and Governance areas which would create a business culture and practice based on corporate responsibility and sustainable development.

Scope

The policy applies to and covers Metasite’s business activities in all countries where Metasite operates. All the employees of Metasite, and non-permanent staff working on behalf of the company, are subject to this directive. It is the responsibility of each manager to ensure that this directive is, where relevant, known and conformed to within his/her respective area of responsibility.

Metasite’s Principles for Sustainability

Through its strategic activities, Metasite seeks to make a positive contribution to the Sustainable Development Goals, focusing on goals 3, 5, 9, 16 (specifically in the areas of Diversity & Equal opportunity, Employee Engagement & Satisfaction, Data privacy and Cybersecurity, Ethics and Compliance). The organisation commits to protecting the environment, people and society, through responsible management of its operations, by complying with or exceeding the environmental and social obligations, and by working proactively on the topics covered in this document.

Metasite takes a principles-based approach to sustainability, and ensures that the positive contributions to society and the environment do not cause adverse impacts on other areas of sustainability. Company also fully supports the ten principles of the United Nations’ Global Compact (UNGC).

Metasite is also committed to advancing Environmental, Social and Governance (ESG) initiatives. Employees at the organisation are encouraged to participate in the ESG initiatives and engage with the clients and stakeholders to pursue ESG-Related opportunities and accelerate the ESG progress.

1. Environmental
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Metasite contributes to the implementation of the European Green Deal and the Paris Agreement, with a commitment to reduce net CO2 emissions to zero by 2050.

As a software development company Metasite’s direct environmental impact is negligible. Nevertheless, the company has high ambition to reduce its environmental footprint. Metasite is committed to:

• work to reduce the direct negative impact of Metasite’s operations on the environment;
• reduce carbon emissions from its operations;
• be resource efficient and use renewable or recyclable materials;
• minimise and recycle waste.

• 1.1 Managing carbon emissions
• When it comes to mitigating actions against climate change, monitoring carbon emissions is a necessary step. For Metasite this means taking active steps to monitor its own emissions by calculating greenhouse gas emissions (Scope 1 & 2, and 3 (in progress)) according to GHG Protocol to achieve net zero GHG emissions throughout the entire value chain by 2050.
• The organisation also sets ambitious reduction targets for themselves as well as the value chain. For the employees, this includes minimising all non- essential business travel, especially air travel; most meetings and communications with clients, when possible, should be arranged online. When business travel is deemed necessary, the least environmentally damaging mode of transport shall be preferred. This means that where reasonable alternatives exist,
  Metasite does not encourage flying.
• Metasite also encourages using car sharing services for work related travels and covers all costs associated with this matter.
• 1.2 Environmental and waste management (internal initiatives)
• All employees of Metasite, and non-permanent staff working on behalf of the company, are encouraged to contribute to the internal initiatives directed to minimise the company’s environmental impact.
• Due to the nature of the business, Metasite’s waste to landfill and overall impact to the environment is minimal. However, the company practises efficient use of resources by eliminating paper usage, plastics and repurposing electronic equipment.
• Over 95% of the documents, such as employment contracts, customer and partner agreements, are signed electronically.
• Employees are encouraged to adopt the “reduce, reuse and recycle” (zero waste) philosophy by consciously purchasing supplies only when needed. Unnecessary plastic waste, such as water bottles at the meeting rooms, is also eliminated by choosing more eco-friendly alternatives, such as reusable or zero waste items. The remaining waste is recycled or repurposed (used electronic equipment provided to various charitable or non profit organisations).
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2. Social
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Metasite recognizes and carefully manages the social impacts along our value chain. Topics such as employee engagement and satisfaction, diversity and equal opportunity as well as data privacy and cybersecurity represent the largest sustainability impacts and are a company’s priorities. Metasite operates strictly in line with local and international regulations regarding the health & safety of the employees as well as protection of fundamental human rights.

• 2.1 Data privacy and cybersecurity
• Metasite protects personal data according to EU General Data Protection Regulation (GDPR). Ongoing compliance with GDPR is ensured through strict internal technical and organisational safeguards.
• Company’s internal policy on “Rules of personal data protection” regulates the principles of collection, use and storage of personal data. It also establishes purpose and means of personal data processing, categories of processed personal data as well as who and for what purposes may access the personal data processed by the company. The policy covers technical and organisational safeguards for the protection of personal data and regulates other issues related to processing of personal data in the company.
• Further information regarding the data privacy can be found in our Privacy Policy.
• Confidentiality agreements are also in place with employees, business partners and customers. Further data privacy and cybersecurity measures are outlined in the Integrated Management System Policy, which includes ISO 9001:2015 (quality) and ISO/IEC 27001:2013 (information security).
• 2.2 Labour management
• As a software development company, Metasite operates in a highly competitive area for skilled information technology professionals. Such competition raises standards of the working environment and compensation. Additionally to the basic annual remuneration package various well-being incentives are offered, such as bonuses based on work performance, possibility to work remotely, flexible working hours and financing of sports activities. Metasite’s extensive employee benefit program includes but is not limited to health insurance, insurance against accidents, III pillar pension funds and training budgets.
• • 2.2.1 Employee engagement & satisfaction
  • Employee engagement and satisfaction is one of the company’s top priorities. Metasite regularly measures employee engagement through periodic surveys. Weekly, monthly and/or quarterly reviews with direct supervisors are also in place to encourage feedback exchange.
  • 2.2.2 Diversity & equal opportunity
  • Metasite encourages equality in all aspects of operations and reimbursement of services. Company’s human resources strategy embodies equality and objective valuations of employee performance and related decisions. All the routines are documented in the quality management system (ISO 9001:2015 certified). Gender equality is imprinted in the company’s culture throughout all the organisational layers.
  • Metasite shall ensure equal opportunities and diversity for its employees and not tolerate any direct or indirect discrimination in all and any areas of its activities.
  • Non-discrimination policy is supported by management through all the decisions and documented according to the local law.
  • Feedback, complaints and suggestions for improvement are encouraged, clear procedures of decision making established in the Rules of Procedure and other internal policies are explained to employees.
  • 2.2.3 Occupational health & safety
  • Metasite follows all regulatory health & safety requirements and offers periodic training to employees, including first-aid courses. Additionally, the company monitors and constantly improves environmental conditions within an office, such as air quality, healthy snacks, and resting areas.
  • Employees are encouraged to share information on safe working methods and make suggestions for improving ergonomics and safety at work.
  • 2.2.4 Community investments, partnerships, and charitable giving
  • Metasite supports its local community by periodically participating in various educational and charitable initiatives.
• 2.3 Human rights & modern slavery
• Metasite respects and promotes human rights by complying with all the applicable local laws and supporting the internationally accepted principles set by the United Nations. This includes the UN Universal Declaration of Human Rights, UN Guiding Principles on Business and Human Rights, and UN Global Compact.
• Human rights due diligence is in place within the company. As an ISO 9001:2015 certified organisation, Metasite periodically assesses its suppliers and partners, and advises them to improve working conditions of their employees if any risks or inadequacies are identified.
• • 2.3.1 Freedom of association and collective bargaining
  • Association of co-workers is imprinted in Metasite’s organisational structure, where services are carried out by self-organising teams. Individual or collective feedback and suggestions to the management are also encouraged. Company’s employees are free to discuss with their colleagues any matter not regulated by confidentiality agreements. All the routines are documented in ISO 9001:2015 certified quality management system and other internal policies and procedures.
  • 2.3.2 Anti-slavery
  • No child labour or forced labour has ever occurred at Metasite. The company have a zero-tolerance approach to modern slavery in its own activities and through the business relationships. The management monitors and ensures proper employment practices are set in place for all the employees.

3. Governance
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Below there is an overview of Metasite’s position regarding the corporate governance topics. The aim is to build trust and ensure smooth and transparent operations of the company, and to create value for stakeholders at all levels. Metasite is committed to governance transparency and therefore works thoroughly to ensure the alignment of workplace culture with the corporate strategy, COVID-19 response, effort to shape its corporate culture and talent acquisition. Metasite strives to integrate the management team and employees to ensure transparent communications and open pathways for both ways of feedback.

• 3.1 Ethics and compliance
• Metasite ensures that internal ethics and compliance principles are meeting the European regulatory guidelines. Ethical organisational values are set in place through effective employee engagement and communication. The organisation is committed to governance transparency, integrity and ethical values throughout the business and expects the same level of understanding from its clients and suppliers. Metasite embraces good governance by striving to hold the highest ethical standards in all business interactions and operations.
• 3.2 Risk management
• The organisations’ primary list of risks is defined and evaluated scoring their probability and likely impact at least on an annual basis, the same evaluation techniques are applied consistently. All members of the management are included in the evaluation process.
• Risks are being evaluated and updated periodically, following ISO/IEC 27001:2013 standard requirements: mitigating high probability – high impact risks, monitoring low probability or low impact risks and defining actions in case lower priority / probability risks would occur. The management’s role in risk oversight is consistent within the leadership structure.
• The management team has a consistent responsibility to assess Metasite’s exposure to risks on a day-to-day basis and manage the risk exposure focusing on the ones that are potentially the most significant.
• 3.3 Policy influence
• Metasite remains neutral when it comes to involvement in political activities and lobbying. When relevant the company does get involved in trade unions helping escalate industry related issues.
• 3.4 Competitive behaviour
• Metasite is committed to ensuring its operations are led with integrity and in a manner that is consistent with laws and business practices that are aimed at fostering an open, competitive and fair market environment.
• 3.5 Supplier management
• ISO 9001:2015 quality management standard is in place, which ensures businesses’ ability to consistently provide products and services that meet customer and regulatory requirements.
• Internal processes are set in place to ensure sustainable supplier and supply chain management. The organisation assesses a number of suppliers annually and monitors various aspects of their operations providing advice to partners/suppliers on the potential improvements. If the immediate adjustments are not made, Metasite will reassess the continuation of work.
• 3.6 Anti-corruption and bribery
• Metasite operates according to the highest industry standards based on values that support anti-corruption and anti-bribery policies.
• Metasite does not tolerate any forms of corruption irrespective of the form or degree of their occurrence. Any employee who has committed a corrupt act, regardless of his/her current position, functions or merits to the company, shall be held liable in the manner prescribed by law.
• Metasite strives for the trust of its business partners, customers, employees, as well as for good reputation, and therefore does not tolerate any actions and forms of corruption that may adversely affect or damage the reputation of the company.

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