DIVERSITY, EQUITY
AND INCLUSION

Publication and communication

This policy is published on the Brightbeam website at www.brightbeam.com and is freely accessible to all staff, associates, and learners. All new employees and associates are briefed on this policy at induction. This policy is reviewed at least annually by the CEO and Head of Operations.

1. OVERVIEW

Brightbeam AI Limited ("Brightbeam") is an AI consultancy, headquartered in Ireland and operating across Ireland, the United Kingdom, Romania, and the United States. Brightbeam is committed to creating a working environment in which every employee, contractor, associate, client, and learner is treated with dignity and respect, and in which diversity is recognised as a source of strength and innovation.

This policy sets out how Brightbeam meets its legal duties under the Equality Act 2010 (UK), the Employment Equality Acts 1998-2015 (Ireland), and equivalent legislation in the other jurisdictions in which Brightbeam operates. It replaces the previous Diversity and Inclusion Strategy (version 1.0, first approved September 2023) and is issued as a mandatory policy applicable to all Brightbeam people.

Brightbeam's diversity, equity and inclusion (DEI) goal is to achieve balanced representation across all levels of the organisation, reflecting the diverse communities in which we operate, and to foster a culture where everyone feels respected, valued, and able to contribute and progress on merit.

2. SCOPE

This policy applies to all employees, contractors, associates, and learners engaged by or participating in programmes delivered by Brightbeam, across all jurisdictions in which Brightbeam operates. It covers every stage of the employment and engagement lifecycle, including recruitment and selection, terms and conditions of employment, promotion, training and development, performance management, disciplinary and grievance matters, and termination.

This policy applies equally to remote working environments, in-person workshops, and all forms of Brightbeam-organised interaction, including video conferencing, written communication, and social events.

3. COMPANY STATEMENT

3.1 General policy

Brightbeam is committed to eliminating discrimination and encouraging diversity and equity across our workforce. We believe that a diverse workforce, supported by an inclusive culture, leads to enhanced innovation, better problem-solving, and a stronger reputation, which in turn helps us attract and retain top talent.

The leadership of Brightbeam accepts ultimate responsibility for the implementation of this policy and will ensure that it is communicated, resourced, and reviewed. No form of unlawful discrimination, harassment, or victimisation will be tolerated.

3.2 Legal and regulatory framework

• Irish legal framework: ensuring no employee, contractor, associate, client, or learner is discriminated against, whether directly or indirectly, on the grounds of age, disability, gender reassignment, marriage or civil partnership, pregnancy or maternity, race, religion or belief, sex, or sexual orientation, or any other protected characteristic under applicable law.

Brightbeam adheres to the Employment Equality Acts 1998-2015 and the Equal Status Acts 2000-2018, which prohibit discrimination on the grounds set out above in an Irish employment and services context.

Brightbeam adheres to the Equality Act 2010, which consolidates UK anti-discrimination law and imposes a duty on employers to make reasonable adjustments for employees and workers with disabilities.

Brightbeam has regard to international standards, including the UN Global Compact and the standards set forth by the International Labour Organization, and monitors equivalent legislation in Romania and the United States as it applies to our operations there.

3.3 Our responsibilities

Brightbeam will, so far as is reasonably practicable:

• Provide equality of opportunity to all employees, contractors, associates, and learners

• Create a working environment free of bullying, harassment, victimisation, and unlawful discrimination

• Make decisions on recruitment, promotion, training, and terms of employment based on merit, skills, and experience alone

• Review employment practices and procedures to ensure equality of opportunity, updating them where necessary to remove discriminatory effects

• Make reasonable adjustments for employees, associates, and learners with disabilities

• Take seriously and address promptly any complaints of discrimination, harassment, or bullying

4. OBJECTIVES

Brightbeam's diversity, equity and inclusion objectives for the current policy year are to:

• Conduct a baseline survey to understand current workforce demographics and inclusion perceptions, and benchmark these against industry standards

• Increase the representation of underrepresented groups in hiring, with progress reviewed annually

• Provide DEI-related training and briefings to all employees and associates as necessary

• Ensure all new employees and associates are briefed on this policy at induction

• Establish and maintain clear channels for raising DEI concerns and feedback

• Communicate progress on DEI initiatives to all stakeholders at least bi-annually

• Review and update this policy at least annually, or sooner following feedback, an incident, or a change in legislation

5. HOW THIS POLICY IS UPHELD

5.1 Recruitment and selection

Brightbeam is committed to fair and transparent recruitment. Job descriptions, advertisements, and selection criteria will be based solely on the genuine requirements of the role. Brightbeam will:

• Partner with diverse recruitment agencies, schools, and universities to widen the pool of applicants

• Ensure recruiters and interviewers are briefed on this policy and on avoiding unconscious bias

• Use structured, criteria-based interviews and selection processes

• Where AI or automated tools are used to support recruitment, ensure that they are monitored for bias and do not produce discriminatory outcomes

• Make reasonable adjustments to the recruitment process for candidates with disabilities on request

5.2 Promotion

Promotion and career progression decisions will be based on objective assessment of performance, skills, and potential, applied consistently to all employees. Brightbeam will maintain mentorship and leadership development programmes with a focus on supporting underrepresented groups into leadership roles, and will monitor promotion outcomes for any indication of disparate impact.

5.3 Terms and conditions of employment

All employees and associates in equivalent roles will be offered terms and conditions of employment, including pay, benefits, and working arrangements, on a fair and non-discriminatory basis. Brightbeam will periodically review pay and benefits data to check for unexplained disparities linked to protected characteristics, and will correct any such disparities identified.

5.4 Training and development

Brightbeam will provide ongoing DEI training, including unconscious bias training and inclusive leadership training, to all employees and associates. Training and development opportunities, including access to courses, conferences, and stretch assignments, will be offered on an equitable basis and will not be limited by protected characteristics.

5.5 Performance

Performance management, including objective-setting, appraisals, and feedback, will be conducted consistently and objectively across the workforce. Managers will be trained to recognise and avoid bias in performance assessment, and performance outcomes will be periodically reviewed for any indication of disparate impact on particular groups.

5.6 Disciplinary measures

Disciplinary matters, including those arising from a breach of this policy, will be handled in accordance with Brightbeam's disciplinary procedure, applied consistently and proportionately regardless of the protected characteristics of the individual concerned. Substantiated cases of discrimination, harassment, bullying, or victimisation will be treated as serious matters and may result in disciplinary action up to and including dismissal.

5.7 Termination

Decisions relating to termination of employment or engagement, including in the context of redundancy or contract non-renewal, will be made on objective, non-discriminatory grounds, and will comply with applicable employment law in the relevant jurisdiction. Brightbeam will review selection criteria used in any redundancy or restructuring process to ensure they do not directly or indirectly disadvantage individuals with protected characteristics.

5.8 Harassment and bullying

Brightbeam will not tolerate harassment or bullying of any kind, whether related to a protected characteristic or otherwise, and whether it occurs in person, online, or via written communication.

Harassment includes unwanted conduct that has the purpose or effect of violating a person's dignity, or creating an intimidating, hostile, degrading, humiliating, or offensive environment. Bullying includes repeated inappropriate behaviour, direct or indirect, which could reasonably be regarded as undermining a person's right to dignity at work.

At the start of every Brightbeam-delivered session, workshop, or programme, the lead facilitator will confirm that the session is to be conducted in a respectful and inclusive manner, and will signpost the complaints procedure and welfare contacts where relevant.

6. HANDLING DISCRIMINATION, HARASSMENT AND BULLYING COMPLAINTS

Anyone who believes they have experienced or witnessed discrimination, harassment, bullying, or victimisation is encouraged to raise the matter promptly. Complaints may be raised informally in the first instance, or formally through Brightbeam's grievance procedure, at the individual's discretion, and no one will be penalised for raising a concern in good faith.

• Raising a concern: Report the concern to your line manager, the Head of Operations, or, for programme delegates, to go@brightbeam.com

• Acknowledgement: All complaints will be acknowledged within two working days

• Investigation: Complaints will be investigated promptly, fairly, proportionately, and in confidence, so far as is possible given the nature of the complaint

• Outcome: Where a complaint is upheld, appropriate action will be taken, up to and including disciplinary action under Brightbeam's disciplinary procedure

• Protection from victimisation: Anyone raising a complaint in good faith, or supporting another person to do so, will not be subject to victimisation or detriment as a result

7. EMPLOYEE ASSISTANCE

Brightbeam recognises that experiencing or witnessing discrimination, harassment, or bullying can affect a person's wellbeing. Employees and associates affected by such matters have access to Brightbeam's Employee Assistance Programme (EAP) or equivalent support resource, in addition to the formal complaints channels set out in Section 6.

• Confidential access to counselling and welfare support through the EAP or equivalent resource

• Signposting to relevant external support organisations where appropriate

• Support from the Head of Operations or line manager in agreeing any reasonable adjustments needed during or after an investigation

8. RELEVANT LEGISLATION

This policy has been prepared with reference to the following legislation and guidance. Brightbeam will monitor changes to applicable law and update this policy accordingly.

• Equality Act 2010 (UK) — Primary UK legislation prohibiting discrimination on the grounds of protected characteristics; requires reasonable adjustments for disability. Applies to all Brightbeam activities in the UK.

• Employment Equality Acts 1998-2015 (Ireland) — Prohibits discrimination in employment on nine protected grounds. Applies to Brightbeam's Irish-headquartered operations.

• Equal Status Acts 2000-2018 (Ireland) — Prohibits discrimination in the provision of goods, services, and education, relevant to Brightbeam's training and coaching programmes.

• Employment Equality (Complaints) legislation and equivalent EU directives — Underpins the framework for handling discrimination complaints across Brightbeam's EU operations.

• Protection of Employees (Fixed-Term Work) Act 2003 (Ireland) / equivalent UK provisions — Ensures fair treatment of fixed-term and contract workers relative to permanent staff.

• UN Global Compact / International Labour Organization standards — International best-practice framework informing Brightbeam's global approach to non-discrimination and fair labour practice.

9. NAMED RESPONSIBILITIES

The following sets out who is responsible for diversity, equity and inclusion matters within Brightbeam. These responsibilities are in addition to the general duty on all employees to treat colleagues, clients, and learners with dignity and respect.

• CEO - Brian Hanly — Overall accountability for diversity, equity and inclusion across Brightbeam. Signs and approves this policy and ensures sufficient resource is allocated to meet legal obligations. Reviews policy annually.

• Head of Operations - Marli van Sittert — Day-to-day operational responsibility for this policy. Maintains records of complaints and outcomes. Receives and coordinates the investigation of complaints. Acts as first point of contact for DEI queries from staff, associates, and learners.

• COO - Paul Savage — Second-line oversight of DEI matters. Deputises for the CEO on policy decisions where required.

• Managers and team leads — Apply this policy consistently within their teams. Complete training on recognising and preventing discrimination, harassment, and bullying. Model inclusive behaviour and address concerns raised by their teams promptly. Escalate complaints to the Head of Operations without delay.

• All employees and associates — Treat colleagues, clients, and learners with dignity and respect. Complete DEI-related training as required. Report any concerns of discrimination, harassment, bullying, or victimisation. Co-operate with any investigation carried out under this policy.

• Learners / programme delegates — Follow the standards of conduct set out at the start of each session. Report any welfare or conduct concerns to the session facilitator or to go@brightbeam.com.

10. COMMUNICATION

This policy is published on the Brightbeam website at www.brightbeam.com and is freely accessible to all staff, associates, and learners. It has been circulated to all colleagues and forms part of the induction briefing for new employees and associates.

• Communicate this policy, and any material updates to it, to all employees and associates via internal channels

• Signpost this policy and the complaints procedure at the start of relevant programmes and sessions

• Report on DEI progress and initiatives to stakeholders at least bi-annually

• Maintain feedback channels so employees, associates, and learners can contribute to the continuous improvement of this policy

11. SIGN-OFF

This policy has been approved by the Chief Executive Officer of Brightbeam AI Limited and is effective from the date of signature in the signed policy. It will be reviewed at least annually and updated as necessary.

Signed on behalf of Brightbeam AI Limited
Name: Brian Hanly
Document details
Policy reference: DEI-POL-001
Title: Chief Executive Officer
Version: 1.0
Date reviewed: July 2026
Next review due: July 2027