equal opportunities
plan.

Employer's details

1statement of principles

Seyu Solutions Kft. (hereinafter: the Employer) is a technology company operating as a micro-enterprise with a presence on the international market. We are convinced that collaboration between employees of different ages, genders, cultural backgrounds and life experiences is not merely a legal requirement, but also a business imperative: a diverse team understands its users more comprehensively and creates better products.

At no stage of the employment relationship shall the Employer practise or tolerate discrimination against an employee on the grounds of their gender, race, skin colour, nationality, ethnic origin, mother tongue, disability, state of health, religious or philosophical beliefs, political or other opinions, marital status, maternity or paternity, sexual orientation, gender identity, age, social background, financial circumstances, the part-time nature or fixed-term duration of their employment relationship, membership of a trade union, or any other situation, attribute or characteristic.

This plan constitutes a unilateral, voluntary and public commitment by the Employer, which was adopted following consultation with employees.

2purpose of the plan

1. To set out the fundamental principles and procedural safeguards that ensure compliance with the requirement of equal treatment.
2. To assess the employment situation of groups of employees employed by the Employer who are considered to be at a disadvantage in terms of equal opportunities.
3. On the basis of the assessment, to define specific, measurable and time-bound objectives and measures to compensate for any disadvantages.
4. To designate the person responsible for implementing the measures, as well as the procedures for measuring and reviewing their implementation.
5. To ensure a transparent complaints-handling procedure, known to all, in the event of an alleged breach of equal treatment.
6. To provide documented evidence of the implementation of the above to employees, business partners and evaluators participating in tender and public procurement procedures.

3legal framework

• The Fundamental Law of Hungary, in particular Article XV (equality before the law, prohibition of discrimination, equality between women and men);
• on equal treatment and the promotion of equal opportunities: Act CXXV of 2003 (Ebktv.), in particular Section 5(d), Sections 7–11 and Section 63;
• on the Labour Code: Act I of 2012 (Labour Code), in particular Section 12 (equal treatment, equal pay for work of equal value), and its provisions on parental rights and protection against dismissal;
• Act XXVI of 1998 on the rights of persons with disabilities and on ensuring equal opportunities for them;
• provisions relating to the employment of persons with reduced working capacity;
• the Regulation (EU) 2016/679 (GDPR), in particular Article 9 (special categories of personal data), and Act CXII of 2011 (the Information Act);
• the provisions on the right to privacy in the Civil Code (Act V of 2013);
• the European Union's directives on equal treatment in employment, as well as Directive (EU) 2023/970 on pay transparency and its transposition into national law.

3.1 The legal nature of the plan

Section 63 of the Ebktv. makes the adoption of an equal opportunities plan mandatory for budgetary bodies employing more than fifty people and for legal entities in which the State holds a majority stake. The Employer is not a public body and is not majority state-owned; therefore, the adoption of the plan on its part is a voluntary commitment.

However, this does not affect the binding nature of the plan: by adopting the plan, the Employer undertakes, in respect of itself, to implement the measures set out therein, and shall report on the fulfilment of this undertaking in accordance with point 13. Regardless of this, compliance with the requirement of equal treatment – pursuant to Section 5(d) of the Equal Treatment Act and Section 12 of the Labour Code – is a statutory obligation incumbent on the Employer, irrespective of the size of its workforce.

4definitions

5scope of the plan

Personal scope

The plan applies to all employees in an employment relationship with the Employer, without distinction as to job role, working hours, duration of the employment relationship or place of work. The fundamental principles – in particular the prohibition of harassment and retaliation, as well as the complaints procedure – shall be applied accordingly to contributors working under a contract of mandate, a contract for services or any other civil law relationship, to trainees and to candidates participating in the recruitment process.

Period of validity

The plan came into force on 10 August 2026 and shall remain in force until it is revoked or until a plan replacing it comes into force. The Employer shall review the plan annually.

Material scope

The plan covers the entire life cycle of the employment relationship: from determining staffing requirements and drafting job advertisements, through selection, the establishment of the employment relationship and induction, to the shaping of working conditions, remuneration and benefits, training and career progression, performance appraisal, the organisation of working hours, benefits designed to facilitate a work-life balance, and the termination of the employment relationship.

6our commitments

The Employer undertakes to:

1. draft job advertisements in a neutral manner, without any requirements referring to protected characteristics, and to make selection decisions solely on the basis of pre-defined and documented professional criteria necessary for filling the post;
2. apply the principle of equal pay for equal work or work of equal value to all elements of remuneration – basic pay, pay supplements, performance-related pay, bonuses, profit-sharing, employee share ownership schemes (ESOPs) and all other direct or indirect benefits;
3. announce opportunities for training, further training and conference attendance on the same terms for all employees, including those employed on a part-time or remote basis;
4. carry out performance appraisals in a documented manner, based on a set of criteria known in advance and linked to the job role, and inform the employee concerned of the outcome;
5. support the reintegration of employees returning from unpaid leave, maternity or parental leave, or a prolonged period of incapacity for work, and not view the period of absence unfavourably when assessing career progression;
6. not tolerate any form of workplace harassment, sexual harassment, discrimination or retaliation, and investigate all reports of such incidents;
7. apply equal opportunities principles in its relationships with suppliers and partners, and make its expectations in this regard known to its contractual partners;
8. provide the necessary human and financial resources for the implementation of the plan, within the framework of the annual business plan.

7situation analysis

The Employer carries out an annual analysis of the employment situation. The analysis is based on data from labour and payroll records, as well as on voluntary self-reports from employees, and covers the analysis of headcount and composition (gender, age, childcare), remuneration by job category, training and career progression, as well as working conditions and accessibility.

7.1 Review of remuneration

The review of remuneration is not carried out by comparing individual wages, but at the level of job categories (pay bands), within groups of jobs considered to be of the same or equivalent value. When assessing equal value – in accordance with Section 12 of the Labour Code – we take into account the nature, quality and quantity of the work performed, working conditions, the necessary professional qualifications, physical or mental effort, experience, responsibility and labour market conditions. In the event of a deviation reaching five per cent that cannot be explained by objective professional criteria, we will initiate corrective measures in the next pay review round.

8objectives and measures

Unless otherwise specified, the equal opportunities officer is responsible for the measures; the source of funding for their implementation is the Employer's annual business plan.

8.1 Women

Objective: to promote balanced gender representation in all job categories and to eliminate unjustified pay gaps.

8.2 Employees aged over forty

Objective: to retain experience, prevent age-based exclusion and ensure the continuous development of digital skills.

8.3 Employees of Roma origin

Objective: to eliminate discrimination based on origin and to ensure the selection process is open. With regard to this group – given the sensitive nature of data relating to ethnic origin – we do not set a numerical target but commit to procedural safeguards.

8.4 Employees with disabilities and reduced working capacity

Objective: to ensure an accessible and inclusive working environment, and to consciously open up employment opportunities.

8.5 Employees raising young children and single parents

Objective: to support the work-life balance, with a particular focus on employees raising two or more children under the age of ten, or those raising a child under the age of ten as a single parent.

8.6 Career starters and trainees (voluntarily selected target group)

In addition to the groups specified by law, we have also set ourselves the voluntary objective of improving opportunities for career starters entering the labour market.

9horizontal measures

9.1 Recruitment and selection

• The job advertisement shall contain only objective requirements necessary for filling the post; it must not contain any conditions or wording referring to a protected characteristic.
• The job advertisement shall – unless the nature of the post precludes this – indicate the possibility of flexible working arrangements and part-time work.
• The interview is based on a pre-determined set of questions asked in the same order to all candidates. No questions may be asked regarding a candidate's marital status, plans to have children, state of health, ethnic origin, religion, political views or sexual orientation.
• The selection decision is documented in writing, specifying the assessment based on professional criteria.
• Rejected candidates will, upon request, receive feedback on the professional grounds for their rejection.

9.2 Remuneration and transparency

• We apply pay bands linked to job categories, and we set out in writing the criteria for pay decisions (professional level, experience, responsibility, performance, market conditions).
• We inform the candidate of the pay band for the advertised post in the job advertisement or, at the latest, during the first interview.
• At the employee's request, they shall be provided with information on their own remuneration, as well as on the average remuneration level of those performing the same or equivalent work, broken down by gender, in a manner that precludes individual identification.
• We do not impose any restrictions that prevent an employee from obtaining information about their own remuneration or from disclosing such information.
• We carry out an analysis of the gender pay gap annually.

9.3 Training, career progression, performance appraisal

• We draw up an annual training plan which includes development opportunities for all employees.
• Training courses are available to part-time and remote workers, as well as – subject to their consent – to those on extended leave.
• We publicise internal promotion and job rotation opportunities to all employees.
• Part-time work, absences and flexible working arrangements must not, in themselves, result in a lower performance rating.

9.4 Work-life balance, atypical employment

• We support remote working and flexible working hours in all roles where this does not jeopardise the performance of duties.
• Meetings are normally scheduled during core working hours so that employees who rely on childcare can also attend.
• We do not expect staff to be available outside working hours; contact outside working hours is limited to justified, exceptional cases.
• When granting leave, we take into account requests linked to school holidays, and assess competing requests according to a pre-established, objective order of priority.

9.5 Inclusive workplace culture

• We inform all new recruits of this plan, the requirement for equal treatment and the complaints procedure within 30 days of their start date.
• At least once a year, we hold awareness-raising sessions on recognising and dealing with discrimination and harassment.
• In our internal and external communications, we avoid stereotypes relating to gender, ethnicity, age and disability.
• At least once a year, we provide an opportunity – including anonymously – for employees to express their views and raise their concerns.

9.6 Suppliers and partners

We require our contractual partners to comply with the requirement of equal treatment, and we make this plan available to them on request. In the case of new, long-term service contracts, we endeavour to ensure that the contract includes a commitment to equal treatment.

10complaints handling and redress

10.1 The equal opportunities officer

The person designated to coordinate the implementation of the plan and to receive reports is Tamás Vecsernyés, Managing Director. If the report concerns the equal opportunities officer or a close relative of theirs, the report may be submitted to the general meeting or to an external expert appointed by the Employer.

What the report should include

None of the details are mandatory, and reports with incomplete information will still be investigated. The following details will assist in a swift and thorough investigation:

• the subject of the report: discrimination, harassment, unlawful segregation, retaliation or other;
• the date and place of the incident, and a brief description;
• the persons involved or implicated;
• the protected characteristic concerned, if known and if the complainant wishes to disclose it;
• any available evidence or witnesses;
• the action requested by the complainant;
• contact details for feedback – if the complainant requests that their name be withheld, please indicate this.

10.2 The internal procedure

1. The equal opportunities officer shall register the complaint without delay, but no later than 3 working days, and shall inform the complainant accordingly.
2. The investigation shall be concluded within 30 days of the date of the complaint. This deadline may be extended once only, by a further 30 days, provided the complainant is informed at the same time.
3. During the investigation, the parties concerned must be heard and given the opportunity to make their comments. The identity of the complainant and the party concerned must not be disclosed to anyone other than those involved in the investigation.
4. The complainant and the person concerned shall be informed in writing of the outcome and the measures taken.
5. If the investigation finds that a requirement has been breached, the Employer shall remedy the breach, redress the disadvantage – where possible – and draw the necessary conclusions under employment law.
6. The person making the report shall not suffer any detriment as a result of it. Retaliation constitutes a separate and serious breach of duty.
7. We keep a record of reports and their outcomes – in a manner that does not identify the individuals concerned – and evaluate the aggregated data from this record during the annual review.

10.3 External remedies

The use of the internal procedure is neither a prerequisite for nor a barrier to seeking external remedies. Irrespective of the internal procedure – before, during or after it has been conducted – the person concerned may avail themselves of the following avenues:

• they may turn to the Commissioner for Fundamental Rights, who is competent to conduct proceedings concerning breaches of the requirement of equal treatment (the responsibilities of the Equal Treatment Authority were transferred here with effect from 1 January 2021);
• they may turn to the employment supervisory authority to monitor compliance with the rules governing employment relationships;
• they may enforce their labour law claims before a court, and, in the event of a breach of their personal rights, may enforce claims under the Civil Code – including a claim for compensation for non-pecuniary damage;
• if the conduct constitutes a criminal offence, they may initiate criminal proceedings.

11data processing

• We process only the personal data necessary for the implementation of the plan, whilst adhering to the principles of purpose limitation, data minimisation and limited storage.
• Special categories of data as defined in Article 9 of the GDPR – in particular data relating to ethnic origin, health status and disability – shall be processed solely on the basis of the data subject's explicit, written, voluntary consent, which may be withdrawn at any time without detriment, and shall be obtained by means of self-declaration.
• Refusal to provide data or the withdrawal of consent shall not result in any disadvantage to the employee and shall not affect their employment relationship.
• We primarily use aggregated, statistical data for the situation analysis. We do not disclose data relating to groups of fewer than five people, as this could lead to the identification of the data subjects.
• Data generated during the complaints-handling procedure is processed separately with restricted access; access to such data is limited exclusively to the equal opportunities officer and the designated persons involved in the investigation.
• Detailed information is set out in the employee data processing notice, which we update in accordance with this plan.

12public disclosure

• We made the plan available to employees within 15 days of its adoption, and we document their acknowledgement of it by means of a written declaration.
• We provide the plan to all new recruits as part of their induction.
• The plan is publicly available on this page. The internal annexes – the voluntary data disclosure statement, the annual monitoring table and the acknowledgement statement – contain personal data and are therefore not publicly available; they are made available on request to bodies authorised by law, as well as to the contracting authority in tendering and public procurement procedures.

13monitoring and review

13.1 Allocation of responsibilities

13.2 Annual review

Each year, by 31 August, the equal opportunities officer shall prepare a written report for the managing director, which shall include updated data from the situation analysis, the fulfilment of measures based on the specified indicators, summary data on reports received, and proposed amendments for the following year.

13.3 Review and amendment

We review the plan annually, and also on an ad hoc basis if there is a significant change in the number or composition of the workforce, if changes in legislation so require, if the objectives are not being met, or if a substantiated report gives cause to do so. Any amendments shall be made following prior notification to and consultation with the employees, and shall come into force simultaneously with their notification, in a unified version bearing a new version number.

14final provisions

1. This plan constitutes a unilateral undertaking by the Employer, which does not restrict employees from exercising their rights under legislation or their employment contracts, and does not contain any provisions less favourable than those guaranteed by law.
2. In matters not regulated by this plan, the provisions of the Equal Treatment Act, the Labour Code and other relevant legislation referred to shall apply. Should any provision of this plan conflict with legislation, the provision of the legislation shall apply in its place; this shall not affect the validity of the other provisions of this plan.
3. The annexes to this plan form an integral part thereof.
4. The Employer consulted with the employees prior to the adoption of this plan. There is no works council or trade union operating at the Employer; should employee representation be established whilst this plan is in force, the plan will be reviewed in consultation with such representation.