Gender Equality Plan

COMENTIC GmbH (i.G.) - Version 1.0, adopted July 2026. Review cycle: every two years (next review: July 2028).

1. Introduction and Commitment

COMENTIC GmbH (i.G.) ("COMENTIC") is committed to gender equality, diversity, and inclusion in all aspects of its work - recruitment, career development, leadership, research and product development, and organisational culture. This Gender Equality Plan (GEP) is a formal, public document. It is published on our website, has been adopted and signed by the company's top management, and applies to all employees, contractors, and collaborators of COMENTIC. This GEP fulfils the four minimum process-related requirements defined by the European Commission for participation in Horizon Europe: publication and adoption by top management, dedicated resources, data collection and monitoring, and awareness raising and training.

2. Dedicated Resources

The Managing Director is directly responsible for the implementation, monitoring, and revision of this GEP and acts as the company's Gender Equality Officer. Working time of the Managing Director and, where relevant, other staff is explicitly allocated to GEP implementation, including data collection, reporting, and organisation of training. A budget line is reserved in the annual company budget for gender equality measures, including external training, expert advice, and inclusive recruitment practices. Where internal expertise is insufficient, COMENTIC will engage external gender equality experts or recognised training providers.

3. Data Collection and Monitoring

COMENTIC collects and maintains sex/gender-disaggregated data on its personnel, including headcount by gender across roles and levels, gender distribution in recruitment (applications, interviews, hires), compensation data by gender and role, and gender distribution in leadership and decision-making positions. This data is reviewed at least every two years against defined indicators. A monitoring report is prepared by the Gender Equality Officer, discussed by management, and used to update the objectives and measures in this plan. Monitoring reports and data can be provided upon request, in compliance with data protection law (GDPR).

4. Awareness Raising and Training

COMENTIC commits to gender equality awareness raising and training for all staff and decision-makers, including: an introduction to this GEP as part of onboarding for all new staff; training on unconscious gender bias for all staff and specifically for decision-makers involved in recruitment, evaluation, and promotion, at least every two years; and awareness of gender dimensions in our research, AI, and product development work, including bias in data and algorithms. Attendance is documented, and training plans, curricula, and attendance records can be provided upon request.

5. Objectives and Measures

Work-life balance and organisational culture: flexible working hours and remote work arrangements for all employees; full support for parental leave for all genders in accordance with, and beyond the minimum of, German law; zero tolerance for discrimination in any form.

Gender balance in leadership and decision-making: target of gender-balanced representation in leadership and decision-making bodies as the company grows; gender balance considered in the composition of any advisory board, hiring panel, or committee.

Gender equality in recruitment and career progression: gender-neutral, inclusive language in all job advertisements; structured, criteria-based interviews to reduce bias; active encouragement of applications from underrepresented genders, particularly in technical roles; equal pay for equal work, monitored through the data collection described in Section 3.

Integration of the gender dimension into research and product development: consideration of sex, gender, and diversity dimensions in our research and in the design, training data, and evaluation of our AI systems; assessment of potential gender bias in datasets and model outputs as part of our development process.

Measures against gender-based violence and sexual harassment: zero tolerance for gender-based violence, sexual harassment, and bullying, in line with the German General Equal Treatment Act (AGG); a clear, confidential reporting channel with documented follow-up of every report.

6. Implementation, Monitoring, and Review

The Gender Equality Officer monitors the implementation of the measures above using the indicators in Section 3. This plan is reviewed and updated at least every two years, or earlier if organisational changes require it. All versions of this GEP remain available on our website.

7. Adoption

This Gender Equality Plan was adopted and signed by the management of COMENTIC GmbH (i.G.) and is binding for the organisation. A signed copy of this document is kept on file and can be provided upon request.