INTRODUCTION AND DEFINITIONS

Context and history

TMCOMAS and Comastech with their long tradition of respect and care for their employees had already put in place non-discrimination policies and were working to make it easier to reconcile professional, personal and family life long before it was necessary to have a Code of Ethics or an Equal Opportunity Plan like this one.

For several years now, Comas Group has had a Code of Ethics and now an Equal Opportunities Plan which will help to consolidate, improve and broaden the policies already in place on equality, fairness and reconciling work and family life.

In April 2021, the management of TMCOMAS and Comastech sent out an internal press release expressing their firm commitment to creating their first Equal Opportunities Plan.

Once staff had been informed of this decision, a negotiating committee was set up.

Once the Equality Plan negotiating committee had been set up, the process got under way, with the participation of the company’s management on the one hand, and specially appointed staff representatives on the other.

Negotiations began with the collection of data, including the breakdown of staff by gender, occupational groups, types of working day, different types of contracts, aspects relating to training and the reconciliation of work and family life. This data, provided by the company in the form of a qualitative and quantitative compilation, together with the survey carried out on each employee, was discussed and analysed at Commission meetings with a view to drawing up the diagnosis.

Finally, the newly created diagnostic model was unanimously approved and attached as an appendix. It becomes the starting point for determining the areas of intervention on which the Equality Plan will have to act.

Definitions.

Several concepts are then defined to ensure that the Equality Plan is properly implemented.

In accordance with the provisions of Organic Law 3/2007, of 22 March, and Law 17/2015, of 21 July, both approved by the Parliament of Catalonia and referring to effective equality between women and men, the main objective is to guarantee real and effective equality of treatment between women and men in the professional sphere, avoiding any type of discrimination in the workplace.

In line with our main objective, we have drawn up the following definitions:

Sex: set of biological characteristics (anatomical and physiological) according to which individuals of a species are divided into males and females (sexual organs, reproductive function, hormones, among others).

Gender: set of social, cultural, political, psychological, legal and economic characteristics attributed by society to individuals, to differentiate them on the basis of their sex; by establishing the female category for women and the male category for men.

Gender stereotypes: set of psychological and physical qualities and characteristics that differentiate men and women.

Gender role: set of tasks and functions, as well as behaviours, that are specific to men or women simply because they belong to one sex or the other. The gender role includes all the roles and different expectations that are socially associated with women and men, regulating and guiding these models in all areas of society.

Discrimination: According to the International Labour Organisation, “discrimination in the workplace means treating people differently and unfavourably because of certain characteristics such as gender, skin colour, religion, political ideas or social origin, irrespective of the requirements of the job”.

The functions performed by women are unfortunately socially invisible and are not considered, since patriarchal society considers that they are not of a very serious nature. In addition, men hold most of the positions of power and decision-making in the public and private spheres, reflecting the needs and preferences of men, not women.

Direct discrimination: situation in which any person has been treated less favourably than another in a similar situation, on the grounds of sex or gender.

Indirect discrimination: Discrimination which occurs when an apparently neutral provision, criterion or practice places persons of a particular sex or gender at a disadvantage compared with others, unless that provision, criterion or practice can be objectively justified by a legitimate aim and the means of achieving that aim were necessary and appropriate.

Intersectionality in the discrimination based on sex and gender: Discrimination based on gender, which exists in both horizontal and vertical productive work, is even more pronounced with membership of an ethnic or religious group that differs from the traditional European and Catalan referent model. Origin, religion and skin colour further limit access and progression in the professional sector. When gender, work and ethnicity are taken together, it becomes even clearer that poverty has a woman’s face, because inequality affects women more than men and that they occupy more of the lowest socio-economic level.

Horizontal segregation. Glasse ceiling:

This refers to the difficulties encountered by certain people in gaining access to specific professions. It can be seen in the predominance of women in traditionally feminised sectors and the difficulty for women to access positions generally defined as « masculine ».
The glass ceiling is made up of invisible obstacles that prevent women from progressing in their professional careers at the same rate as men. Although it is less common, men also encounter difficulties in accessing professions or positions considered typically feminine, such as nursing, office work or being recognised as househusbands.

Vertical segregation. Sticky floor:

« Vertical segregation » is the concept that refers to the non-uniform distribution of men and women across different levels of activity. Vertical occupational segregation means that women are concentrated in jobs with less responsibility, as are the working conditions that affect them: they are more likely to work part-time, flexible hours or continuous working days. Women are often paid less than men for the same job and duties. The sticky floor is the context that traps many women in low-quality, much more precarious jobs in sectors dominated by women.

Wage gap:

This is defined as the relative difference between the average gross hourly earnings of women and men in all sectors of the economy.

Sexual harassment:

This is any verbal or physical behaviour of a sexual nature intended to have the effect of violating a person’s dignity, particularly when it occurs in an intimidating, degrading or offensive environment. At the same time, any behaviour based on a person’s sex that is intended to undermine their dignity.

Principle of equal treatment between men and women:

This implies the absence of any discrimination, direct or indirect, on the grounds of sex and, for the purposes of maternity, considering family obligations and marital status.

Equal treatment and opportunities as regard access to work, professional training and promotion, and working conditions.

The principle of equal opportunities for women and men, applicable in the professional sector, whether public or private, will be guaranteed under the terms of the regulations in force, as regards access to employment, including self-employment, professional training, professional promotion, working conditions, as well as remuneration and dismissals, and membership and participation in trade union organisations and/or any organisation whose members carry on a given profession.

Promotion of equality in collective bargaining:

Through collective bargaining, it will be possible to take positive action to promote women’s access to employment, effectively applying the principle of equal treatment and non-discrimination in working conditions between women and men.

Reconciling personal, family and professional life:

The possibility for a person to make their personal, family and social life compatible with their professional life and to be able to develop their skills in different areas.

Co-responsibility at work:

Balanced participation of men and women in all the tasks and responsibilities of family life, from domestic work to caring for dependents.

Sexist language:

When the masculine gender is used as a generic term in a compulsory and imposed manner, and only the feminine for certain categories or professions. The use of non-sexist language is that which reflects social diversity and breaks with sexist stereotypes and clichés.

Gender perspective:

It involves considering the diverse needs of women and men in the analysis, planning and implementation of policies and actions, in all their biological, psychological, historical, social and cultural dimensions.

Positive action:

To give effect to the constitutional right to equality, natural and legal persons in the private sector will be able to adopt specific measures in favour of women to correct situations of de facto inequality in relation to men.

 CHARACTERISTICS OF THE EQUALITY PLAN.

Concept and content of the Equality Plan.

Organic Law 3/2007 defines the Equality Plan as follows:

“(…) an organised set of measures adopted following a diagnosis of the situation, aimed at achieving equal treatment and opportunities for women and men in the company and eliminating sexual discrimination”.

This definition is subsequently supported by Law 17/2015, of 21 July, on effective equality between women and men, approved by the Parliament of Catalonia.

This plan, as referred to in the index, includes: the introduction and definitions, the characteristics, the diagnosis, the objectives, the concrete actions to be developed, the timetable and the appendices.

Scope of application:

This Equality Plan will be applied to all TMCOMAS and Comastech staff, encompassing all employees without exception. The territorial scope of application is the Girona area.

Validity:

In the Equality Plan, the measures are grouped together in a package aimed at achieving the objectives, some of which will be achieved before others, and whose entry into force may be different and gradual without altering the previously stipulated deadlines. The plan will be valid for four years, during which time it will be essential to work in a committed manner to successively achieve the objectives. The content will have to be reviewed during this period and renewed and updated after the four-year period from the date of signature.

DIAGNOSTICS.

Diagnostic results.

During the various sessions of the Negotiating Committee for the Equality Plan project, a diagnosis of the company’s current situation was drawn up, from which we will proceed to determine the results and conclusions to identify the measures to be taken in the short and long term.

Firstly, it is important to point out that from the outset, the tendency was considered that the company was in “good health” as far as gender equality was concerned and that, at first sight there were no cases of decisive concern. However, ongoing into more detail in the analysis, certain aspects were identified as requiring improvement, which will then be converted into objectives in the Equality Plan.

The main areas for improvement were:

• Reviewing the language and communications issued by the company to avoid any expression that is sexist or evokes discrimination. TMCOMAS and Comastech’s communications policy could undoubtedly be described as impeccable in terms of equality, given that both the texts and the images used for it is advertising and promotion apply parity and gender-neutral language. Despite this, management and the Equality Committee are committed to continuing in this direction to achieve excellence in this area, paying particular attention to the material used for advertising and internal and external communication.
• The revision or creation, as appropriate, of access and professional promotion processes in terms of gender equality in the company, encouraging a selection policy that promotes greater professional diversification.
• Designing training programmes to raise awareness of equal opportunities.
• The company’s commitment to disseminating information on mechanisms for reconciling work and family life.
• The prevention of sexual harassment, with a review of the action protocol for dealing with this type of situation.
• Other measures such as health and safety at work. Proposal to strengthen the company’s existing Occupational Health Committee to monitor staff health and safety.

The above points make no mention of the pay gap or inequalities identified during the pay audit, since TMCOMAS and Comastech make no such distinction in their workforce. On the contrary, it is one of those companies where the issue of pay is very important in the sense that all employees are treated equally: the same work and the same professional category equate to the same economic remuneration without distinction between women and men. In addition, it makes sure that the work of its employees is valued economically.

This conclusion is reached by checking the company’s quantitative data. At the time this Equal Opportunities Plan was drawn up, TMCOMAS had 54 employees: 44 men and 10 women.

All the jobs in this company are obviously occupied by more men than women, since the sector is heavily male-dominated and for this reason it is currently difficult to achieve parity. One of the objectives is therefore to attract more women to the sector. TMCOMAS is working in this direction, which is why there are a few women in the workshop.

As far as professional categories are concerned, women are represented in almost all of them, particularly in those where greater academic training is required: officers, technicians, graduates, draughtsmen, sales staff and office assistants. Men, on the other hand, are more numerous and are present in all departments.

All staff are employed on permanent contract or on conversion to permanent contracts. Only two men are on temporary contracts.

This is a balance and proportionality between women and men in occupational groups, pay levels and salaries. Salaries are higher than the collective agreement for the sector because the company’s policy is to retain and reward talent.

GENERAL OBJECTIVES OF THE EQUALITY PLAN.

The objectives of the Equality Plan can be divided into three categories: long-term, medium-term and short-term objectives. This difference between these types of objectives is that the first will set a frame of reference throughout the process of implementing the Equality Plan, while the medium -and short-term objectives will be concrete and specific actions that are aligned with the general objectives.

The fields of action on which the diagnosis is based and on which the research has been structured are also intended to be the areas in which the measures defined in this plan will be implemented.

• Ensuring that gender mainstreaming is progressing in the policies, procedures and actions of the various sectors of the company.
• Increasing the presence of women in those sectors where they are under-staffed, by encouraging positive discrimination towards them when the necessary conditions are met, considering the supply and demand of the labour market.
• Working to improve the personal, family and work-life balance as much as possible and finding solutions that satisfy both parties through dialogue and constructive understanding.
• Ensuring the necessary internal conditions to combat cases of sexual harassment and discriminatory attitudes and treatment.
• Facilitating the full development of individuals within a framework of equal opportunities.

 ACTIONS TO BE DEVELOPED AS PART OF THE EQUALITY PLAN.

Action 01.01	To ensure that gender mainstreaming progresses in the policies, procedures and actions of the various different sectors of the company.
Description	Review of all internal documentation to ensure the use of inclusive language.
Responsible	Equality Commission
Application deadline	Second half of 2022
Action 01.02	To ensure that gender mainstreaming progresses in the policies, procedures and actions of the various sectors of the company.
Description	Creation of an action protocol on occupational and psycho-social risks, including the gender perspective.
Responsible	Equality Commission
Application deadline	First quarter of 2023
Action 01.03	Ensuring that gender mainstreaming is progressing in the policies, processes and actions of the different areas of the company.
Description	Creation of an action protocol to deal with possible cases of sexual harassment or discrimination on the grounds of sex or gender.
Responsible	Equality Commission
Application deadline	First quarter of 2023
Action 02.01	Increasing the presence of women in those sectors where they are under-staffed by considering the supply and demand of the labour market.
Description	To continue to promote education both inside and outside the metalworking sector and vocational training to attract more women into its professions. Our aim is to awaken vocations and attract talent
Responsible	Equality Commission
Application deadline	Second half of 2023
Action 02.02	Increasing the presence of women in those sectors where they are understaffed, by taking account of labour market supply and demand.
Description	Continuing to stimulate the company’s internal and external communication on equal footing, by making the women in the team visible in order to create female role models in the sector.
Responsible	Equality Commission
Application deadline	First quarter of 2024
Action 03	Facilitating the reconciliation of personal, family and professional life.
Description	Although the company allows and facilitates the reconciliation of personal, family et professional life, it undertakes to examine each case as closely as possible so that its staff can take advantage of this service without detriment to the company, the rest of the workforce or the work of its customers.
Responsible	Equality Commission
Application deadline	First quarter of 2024
Action 04.01	Ensuring the internal conditions required to combat cases of sexual harassment and discriminatory attitudes and treatment.
Description	Training: What is Gender Equality? What is an Equality Plan and why is it necessary? What are micro-machisms?
Responsible	Equality Commission
Application deadline	Second quarter of 2024
Action 04.02	Ensuring the internal conditions required to combat cases of sexual harassment and discriminatory attitudes and treatment.
Description	Creation of an internal promotion protocol which, as a preventive measure, avoids futures situations of mistrust regarding equal conditions for internal promotion within the company.
Responsible	Equality Commission
Application deadline	First half of 2025

 SCHEDULE OF EQUALITY PLAN.

	2022	2023	2024	2025
Action 01.01	2 half
Action 01.02		1r half
Action 01.03		1r quarter
Action 02.01		2n half
Action 02.02			1r quarter
Action 03			1r quarter
Action 04.01			2n half
Action 04.02				1r quarter
Start of preparation of the new plan				2n half

 MONITORING, EVALUATION AND PERIODIC REVIEW SYSTEM

To ensure the effective implementation of this plan, the Negotiating Committee undertakes to become the Monitoring Committee.

This committee will be made up of four people: one person representing the Human Resources department, one person representing management, one person representing the company’s Trade Union Committee and one person representing staff. These representatives must always be equitable (two women and two men). This model was chosen as being the most appropriate to the reality of the company, since it represents management, office staff, the union and shop floor staff.

The Monitoring Committee undertakes to meet every six months to review and assess the situation and the progress made in implementing the actions.

In view of the very good relationship that exists between the parties and the great willingness and mutual trust about the application of the plan, the monitoring committee undertakes that all actions and/or modifications will be taken unanimously or, failing that, by an absolute majority. If no agreement is reached, the participation of a technical and expert person from outside the company will be requested to help resolve the disagreement, which will again be resolved unanimously.