1. Purpose and business context

The way NSS Water builds its company is as important as the technologies it develops. NSS Water is a Swedish deep-tech company developing patented water purification technology for the semiconductor industry. Its Water Enhancement Technology platform addresses complex industrial challenges where scientific rigour, collaboration and responsible use of resources are essential.

NSS Water believes that equal opportunities strengthen innovation, decision-making and sustainable business performance. Diverse perspectives help teams challenge assumptions, identify risks and create better solutions. The company therefore treats gender equality and inclusion as core business values, not merely as compliance requirements.

This policy establishes how NSS Water will build and govern an inclusive workplace as the company grows. It also constitutes the company’s Gender Equality Plan for 2026-2029 and is designed to meet the process-related requirements and thematic expectations of Horizon Europe.

2. Scope

This policy applies to all employees, managers and members of the Board of Directors of NSS Water Enhancement Technology AB. Its principles also guide the company’s treatment of applicants, interns, consultants, contractors, advisers and other people working under NSS Water’s direction.

NSS Water expects suppliers, research partners, customers and consortium partners to interact with its people in a manner consistent with the principles of respect, non-discrimination and inclusion set out here. Contractual or governance measures may be used where proportionate and appropriate.

3. Policy foundations

This policy is grounded in:

NSS Water’s business strategy and its commitment to responsible, sustainable growth;
the Swedish Discrimination Act (2008:567), including the employer’s continuous work with active measures;
the Horizon Europe requirements for Gender Equality Plans and the European Commission’s related guidance; and
the principle that employment and business decisions should be based on objective, relevant and transparent considerations.

Gender equality is the central focus of the GEP. NSS Water recognises that gender can intersect with other characteristics and circumstances. The wider inclusion commitment therefore covers sex, gender identity or expression, ethnicity, religion or other belief, disability, sexual orientation and age, as well as other personal circumstances protected by applicable law.

4. Our principles

Equal opportunity. People should have fair access to employment, development, influence and recognition.

Merit and transparency. Recruitment, pay, promotion and other material decisions should use objective criteria connected to role requirements and business needs.

Inclusion and respect. Different experiences and perspectives should be welcomed, heard and treated with professional respect.

Safety and dignity. Discrimination, harassment, sexual harassment, bullying and reprisals are not accepted.

Proportionality. Measures should be meaningful, evidence-based and suited to the size, resources and operating context of a growing deep-tech SME.

Accountability and learning. Progress should be monitored, concerns addressed and practices improved over time.

5. Governance and responsibilities

5.1 Board of Directors

The Board adopts this policy, provides oversight and considers the annual management review. It holds the CEO accountable for implementation and for ensuring that resources remain proportionate to the company’s development and risk profile.

5.2 Chief Executive Officer

The CEO owns implementation, ensures that the policy is communicated and appoints a GEP Coordinator. The CEO integrates equality considerations into organisational planning, recruitment and management practice and escalates material issues to the Board.

5.3 GEP Coordinator and dedicated resources

The appointed GEP Coordinator coordinates the annual cycle, maintains implementation evidence, compiles indicators and supports training and policy communication. NSS Water will allocate at least 24 hours of accountable management or administrative time per calendar year to these activities, together with a proportionate annual budget for training, accessibility measures and external equality or legal expertise when required. This minimum allocation will be increased as headcount, recruitment activity or identified risks increase.

5.4 Managers and decision-makers

Managers and other decision-makers apply this policy in day-to-day decisions, create conditions for participation, challenge inappropriate conduct and act promptly when concerns are raised. A person who participates in recruitment, promotion, pay or project staffing decisions must use relevant and documented criteria.

5.5 Employees and collaborators

Everyone working with NSS Water shares responsibility for respectful conduct, inclusive collaboration and raising concerns in good faith. Employees will be invited to contribute to the company’s active-measures cycle and policy review.

6. Commitments in practice

6.1 Work-life balance and organisational culture

NSS Water will foster a working culture in which contribution is assessed by role-relevant outcomes and professional conduct, not assumptions about availability, family responsibilities or gender. The company will:

support flexible working arrangements where compatible with laboratory, production, customer and security requirements;
seek to make meetings, travel, training and important decisions reasonably accessible to employees with different working arrangements;
support employees in combining work with parenthood and other caring responsibilities in accordance with law and reasonable operational needs;
consider reasonable workplace adjustments and accessibility needs; and
use respectful and inclusive language in internal and external communication.

6.2 Recruitment and career progression

NSS Water recruits for competence, qualifications, potential and alignment with the responsibilities of the role. The company will, where proportionate:

define role requirements and evaluation criteria before reviewing candidates;
use inclusive wording and advertise roles broadly enough to reach a diverse pool of qualified applicants;
apply a consistent interview and assessment structure to candidates for the same role;
avoid criteria that are not necessary for successful performance;
include more than one perspective in material hiring decisions where practicable; and
offer equitable access to feedback, stretch assignments, mentoring, training and promotion opportunities.

NSS Water does not apply a fixed gender quota through this policy. It will actively examine underrepresentation and barriers and will seek a diverse candidate field. Any positive action will be applied only where lawful, relevant and supported by an objective assessment of qualifications.

6.3 Leadership and decision-making

NSS Water seeks meaningful gender balance in leadership, decision-making, technical roles and project teams. When appointing leaders, forming advisory groups or selecting representatives, the company will consider both competence and whether its processes provide fair access to qualified people of different genders. Management will periodically examine whose perspectives are present, heard and acted upon, not only the numerical composition of a group.

6.4 Pay and employment conditions

Pay and other employment conditions will be based on objective factors such as role scope, competence, responsibility, experience, performance and relevant market conditions. NSS Water will conduct the annual pay survey and analysis required by Swedish law to identify, remedy and prevent unjustified gender-related pay differences. Any identified difference that cannot be objectively explained will be addressed without unreasonable delay.

6.5 Awareness, training and capability

Employees and decision-makers will receive recurring awareness-raising or training on gender equality and inclusive working practices. The programme may be integrated into broader leadership, onboarding or workplace training, but records must show that both employees and decision-makers were addressed. Recruitment participants will receive practical guidance on objective evaluation and relevant bias risks before or during active hiring periods.

6.6 Harassment, sexual harassment and reprisals

NSS Water has zero tolerance for harassment, sexual harassment, gender-based violence, bullying and reprisals. Concerns will be taken seriously, handled promptly and as confidentially as circumstances permit, and assessed impartially. A person may report a concern to their manager or the CEO. If the concern involves the CEO, it may be reported to the Chair of the Board; if it involves the Chair, it may be reported to another Board member. Retaliation against anyone who raises a concern, supports another person or participates in an investigation is prohibited.

The company will take proportionate interim and corrective measures where appropriate. Support may include adjustments to working arrangements, access to an external adviser or occupational health support, and clear information about available legal or regulatory channels.

6.7 Research, innovation and project delivery

For each material research and innovation project, NSS Water will assess whether sex or gender is relevant to the research content, design, data, safety, deployment or user impact. Where relevant, the dimension will be integrated into project questions, methods, testing, analysis or stakeholder engagement. Where it is not relevant – as may often be the case for a purely technical water-treatment process – the project team will document a concise rationale rather than assume irrelevance without consideration.

6.8 Partnerships and external representation

When forming project consortia, advisory groups, conference panels or other external teams, NSS Water will encourage inclusive participation and consider gender balance where it has influence over selection. The company will not compromise technical competence or project quality, but will avoid relying on narrow networks when broader outreach can produce qualified alternatives.

7. Raising concerns and responding

A person may raise a question or concern verbally or in writing. No particular form is required. The recipient will acknowledge the concern, identify any immediate safeguarding need and determine an appropriate fact-finding process. The person concerned will be informed, to the extent appropriate, about the process and outcome. Information will be shared only with those who need it to address the matter or meet a legal obligation.

Nothing in this policy limits a person’s right to contact a trade union, the Swedish Equality Ombudsman, a work-environment authority, law enforcement or another competent body.

8. Data collection, privacy and reporting

NSS Water will collect and review sex/gender-disaggregated personnel data and implementation indicators, using lawful data sources and voluntary self-identification where appropriate. Gender identity will not be inferred. The internal review may cover:

workforce composition by organisational level and broad role category;
Board, management and material project-team composition;
applicants, interviewees and appointments where reliable data can lawfully be collected;
promotion, pay review, professional development and training participation;
parental or other relevant leave and uptake of flexible work measures, where appropriate;
reported concerns and response times, without disclosing personal details; and
completion of planned GEP actions and identified improvement needs.

The GEP Coordinator will prepare an internal monitoring summary annually. NSS Water will publish a non-sensitive implementation report at least every two years. Reporting will be aggregated and anonymised in accordance with data-protection requirements. Where small numbers could identify an individual, the public report will suppress the figure, combine categories or use a qualitative description while retaining adequate internal evidence.

9. Continuous active-measures cycle

NSS Water will use the four-step approach required under Swedish discrimination law as its practical improvement cycle:

1. Investigate: identify risks of discrimination, reprisals and other barriers to equal rights and opportunities across working conditions, pay, recruitment and promotion, skills development, and the reconciliation of work and parenthood.

2. Analyse: consider the causes of identified risks, patterns or barriers.

3. Act: select and implement reasonable prevention and promotion measures, with an owner and timetable.

4. Monitor and evaluate: assess whether the measure was implemented and effective, and use the learning in the next cycle.

Employees will be offered a practical opportunity to contribute to this cycle, directly or through a representative arrangement appropriate to the company’s size.

10. Action plan 2026-2029

The actions below are the initial minimum programme. Management may add or accelerate measures where monitoring, growth or a reported concern shows a need.

#	Area	Action	Owner	Timing	Evidence / indicator
1	Governance	Formally adopt and publish the policy; retain the Board resolution and public URL.	Board / CEO	At adoption	Resolution, signed/adopted policy and URL
2	Ownership	Appoint the GEP Coordinator and record annual time and budget allocation.	CEO	Within 30 days of adoption; annual renewal	Appointment and resource record
3	Baseline	Compile the first sex/gender-disaggregated personnel baseline and indicator register.	GEP Coordinator	Within 60 days of adoption	Baseline and indicator register
4	Active measures	Run the investigate-analyse-act-evaluate cycle with employee participation.	CEO / GEP Coordinator	Annually	Risk review, actions and evaluation
5	Pay	Complete the statutory annual pay survey and analysis; document any remedial action.	CEO	Annually	Pay-survey record
6	Recruitment	Use role criteria, structured assessment and a short equality check for each material recruitment.	Hiring manager	For each recruitment	Recruitment record and outcome data
7	Awareness	Deliver equality and inclusion awareness activity covering employees and decision-makers; provide hiring guidance when relevant.	GEP Coordinator	At least annually and during onboarding	Agenda, attendance and materials
8	R&I content	Record whether the gender dimension is relevant to each material R&I project and how it is addressed.	Project lead	At project design and major review	Project checklist or proposal section
9	Monitoring	Review indicators and implementation progress internally.	CEO / Board	Annually	Management summary and Board review
10	Public reporting	Publish a non-sensitive, anonymised implementation update.	CEO	At least every two years	Public report and URL

11. Review, amendment and document retention

The CEO will review this policy annually with the GEP Coordinator and present material findings to the Board. The Board will approve material amendments. A full formal review will take place no later than 31 December 2027 and again before the end of the policy period. Earlier review will occur if legislation, Horizon Europe requirements, organisational scale or identified risks change materially.

NSS Water will retain the versions of this policy that apply during any Horizon Europe grant, together with evidence of adoption, public availability, dedicated resources, data collection, reporting and awareness activities. Superseded public versions should remain accessible or otherwise retrievable for a potential ex-post eligibility check.

Appendix A – Horizon Europe compliance map

This appendix makes the relationship between NSS Water’s governance policy and the Horizon Europe GEP criteria explicit. It should be read together with the adopted policy and implementation evidence.

Criterion / thematic area	Policy location	NSS Water evidence or commitment
Mandatory: public document	Cover publication note; sections 10-11	Formal Board adoption or top-management signature, adoption date and public website URL. Policy must be implemented at grant signature and throughout the grant.
Mandatory: dedicated resources and expertise	Section 5.3; action 2	Named GEP Coordinator; at least 24 hours per year; proportionate budget; internal or external expertise as required.
Mandatory: data collection, monitoring and reporting	Section 8; actions 3, 9 and 10	Sex/gender-disaggregated personnel data; annual internal review; public reporting at least every two years; privacy safeguards.
Mandatory: awareness raising / training	Section 6.5; action 7	Recurring activity explicitly covering both employees and decision-makers; attendance and materials retained.
Work-life balance and culture	Sections 6.1 and 9	Flexible arrangements, parenthood/caring responsibilities, accessibility, inclusive communication and continuous active measures.
Leadership and decision-making	Sections 5 and 6.3	Board oversight, accountable leadership, process review and attention to voice as well as representation.
Recruitment and career progression	Section 6.2; action 6	Objective criteria, structured assessment, inclusive outreach and equitable access to development.
Gender dimension in R&I content	Section 6.7; action 8	Documented relevance assessment for material R&I projects and integration where relevant.
Gender-based violence and sexual harassment	Sections 6.6 and 7	Clear prohibition, reporting routes, protection from reprisals, response process and support.

Appendix B – Adoption and publication record

Complete this record when the Board adopts the policy. The adopted version should then replace this draft and be published on the NSS Water website.

Adopting body	Board of Directors, NSS Water Enhancement Technology AB
Adoption date	To be recorded in the adopted version
Resolution / minutes reference	To be recorded in the adopted version
Public webpage	To be recorded following publication
Effective version	Version 1.0 upon adoption

Finalisation checklist

Approve the policy through a recorded Board decision or top-management signature.
Enter the adoption date and resolution reference; update the cover to version 1.0 and remove the draft note.
Publish the adopted document on an easily searchable public page of the NSS Water website.
Appoint the GEP Coordinator and confirm the first year’s time and budget allocation.
Retain the adopted file, public URL and supporting records for the duration of relevant Horizon Europe grants.

References

European Commission, Horizon Europe guidance on gender equality plans (2025 edition).

European Commission, Gender Equality Plans (GEPs): How to be ready for ex-post checks (January 2026).

Swedish Equality Ombudsman, Active measures and Discrimination Act (2008:567).