Gender Equality Plan

Legal entity	Lodestone Labs AS, org. no. 937 731 515, Norway
Effective date	1 September 2026
Valid until	31 December 2028, then reviewed and reissued
Permanent URL	https://lodestone-labs.com/gender-equality-plan
Contact	Eric Stein-Beldring, Chief Operating Officer and Gender Equality Officer, eric@lodestone-labs.com

1. Commitment and scope

1.1 Statement of intent

Lodestone Labs builds grounding infrastructure for AI systems used in high-stakes technical work, where a wrong answer carries real cost. That work depends on drawing from the widest possible pool of engineering and research talent. We are committed to a working environment characterized by equality, mutual respect, and the absence of discrimination.

This Gender Equality Plan is the company's official policy for the 2026 to 2028 period. It sets out how we remove gender barriers, how we resource that work, and how we hold ourselves to it in public.

1.2 Alignment with European standards

This plan is written to the structure of the Horizon Europe Gender Equality Plan criterion: the four mandatory process requirements and the five recommended thematic areas. It reflects the principles of the EU Gender Equality Strategy 2026 to 2030 and the European Research Area Policy Agenda.

1.3 How this plan meets the four mandatory requirements

Requirement	How it is met	Where
Public document	Published at a permanent public URL, signed by the CEO and the COO, and part of the onboarding pack for everyone who joins.	This page, and section 7
Dedicated resources	A named Gender Equality Officer with a defined share of working time, plus a committed cash budget that activates on first funding or revenue.	Section 2
Data collection and monitoring	Sex and gender disaggregated personnel data collected annually against five indicators, reported to the board and published.	Section 3
Training and capacity building	Annual unconscious bias and inclusive practice training, mandatory for all decision-makers.	Section 5

2. Governance, responsibility, and resources

2.1 Resourcing basis

A commitment the company cannot pay for is not a commitment. So this plan separates what it costs in time from what it costs in cash.

Until Lodestone Labs holds external funding or revenue, the plan is resourced in kind: allocated officer time, no-cost or low-cost tooling, and free or subsidized external training where it is available. This is sufficient to operate every measure marked as in force below, none of which requires a cash outlay.

From the first full financial year in which the company holds external funding or revenue, the cash measures in section 2.3 activate. Where a measure in this plan depends on funding, it says so and names the trigger rather than a date. We would rather publish a plan with honest triggers than one with dates we will miss.

The measures below are therefore of two kinds: those in force now, and those that activate at a named trigger, either the first hire or the first external funding. Each one says which it is.

2.2 The Gender Equality Officer

Phase 1, in force now. The Chief Operating Officer, Eric Stein-Beldring, is designated Gender Equality Officer. The company allocates an average of four hours per week of the COO's working time to managing, implementing, and tracking this plan. The GEO is reachable directly at eric@lodestone-labs.com.

Certification, on funding. Within six months of the company's first external funding or revenue, the GEO completes external certification in gender equality in research and innovation systems, and in unconscious bias in talent acquisition. Until then the GEO uses the freely published European Institute for Gender Equality GEAR tool as the working reference, which costs nothing and is the same underlying material.

Phase 2, on establishing a people function. When Lodestone Labs stands up a dedicated human resources function, triggered by reaching 15 full-time employees, the plan transfers to the person leading it, as a named responsibility of that role. The trigger is the headcount, not a date.

2.3 Budget

From the first full financial year in which Lodestone Labs holds external funding or revenue, the company ring-fences an annual operating budget of at least €5,000 for the activities in this plan:

1. External professional training on unconscious bias and inclusive leadership.
2. Subscription to an anonymous, secure third-party reporting channel.
3. Gender-neutral recruitment tooling.

Before that trigger is met, no cash budget is committed. The commitment is the allocation and the trigger that releases it.

3. Data collection and monitoring

We manage what we measure. Lodestone Labs collects and analyzes sex and gender disaggregated data on its personnel annually. That data forms the Annual Gender Equality Report, presented to the board and published on this website, at a maximum reporting interval of two years.

The first report establishes the baseline that later years are measured against, covering team composition and the recruitment funnel from the point hiring opens. Where an indicator rests on too few people to report without identifying someone, it is recorded as withheld for that reason rather than published.

3.1 Indicators

• 1. Headcount. Number and share of people by sex and gender, split across executive leadership and founders, technical research and engineering roles, and operational roles.
• 2. Recruitment funnel. Ratio of candidates by sex and gender at each stage: application, initial screen, technical interview, offer, acceptance.
• 3. Pay parity. Annual salary analysis to identify and close any unexplained gender pay gap for equivalent roles and experience. Activates on the second employee in any given role band.
• 4. Retention and progression. Average tenure by sex and gender, and the gender ratio of people receiving promotions or equity increases.
• 5. Research integration. Share of research proposals and active technical projects that record a sex and gender dimension analysis, including a documented finding of "not relevant" with its reasoning.

4. The five action pillars

4.1 Work-life balance and organizational culture

Objective: a flexible, supportive working environment that lets everyone, and particularly parents and caregivers, balance professional ambition against the rest of their life.

Core collaboration hours (in force). Synchronous meetings are scheduled between 10:00 and 15:00 CET. No mandatory internal meeting is scheduled before 09:00 or after 17:00. Exceptions for customer or investor availability are permitted and recorded.
Indicator: all internal meetings within core hours, exceptions logged with a reason. Responsible: CEO and COO.

Remote and asynchronous autonomy (in force). A hybrid-first policy permitting up to 80% remote work, with asynchronous schedule adjustment for caregiving or parental duties and no career penalty for using it.
Indicator: everyone has remote tooling and a flexible scheduling agreement. Responsible: COO.

Parental support (activates on first hire, subject to funding). Lodestone Labs tops up statutory parental leave to full salary for a minimum of 12 weeks, covering maternity, paternity, and adoption leave. This is a financial commitment, so it takes effect for employees hired once the company holds funding or revenue sufficient to carry it, and it is written into the employment contract at that point rather than promised in the abstract.
Indicator: all employees taking parental leave return to an equivalent position. Responsible: COO, then the people function.

4.2 Gender balance in leadership and decision-making

Objective: prevent gender imbalance in the places where decisions actually get made.

Balanced advisory and steering bodies (in force). Any steering committee, technical review board, or advisory panel the company forms targets at least 40% representation of the underrepresented gender. This applies from the next such body we convene.
Indicator: share of women on steering bodies and panels, target 40% minimum. Responsible: CEO.

External speaking (in force). Lodestone Labs declines all-male speaking panels at conferences where we are a sponsor or an invited keynote. Where we cannot field a speaker who changes the composition of a panel, we propose women researchers and engineers from outside the company for the slot rather than accepting it as offered.
Indicator: all-male panel invitations declined or redirected, recorded annually. Responsible: CEO and GEO.

4.3 Recruitment and career progression

Objective: remove gender bias from hiring, evaluation, and progression. This is the pillar that matters most at our stage, because our whole team is still ahead of us.

Bias-free job adverts (in force from first opening). Every job advertisement is checked for gendered language before publication, using a de-biasing tool, and describes the role in terms of technical requirements rather than personal attributes.
Indicator: all postings checked and recorded before release. Responsible: COO.

Structured interviews (in force from first opening). Technical interviews are structured and scored against a written rubric. Panels include at least one woman in a technical role, drawn from outside the company where an internal panelist is not available. Where that is not possible for a given panel, the exception is recorded with its reason.
Indicator: all hiring decisions backed by a completed rubric; panel composition recorded per hire. Responsible: hiring manager and GEO.

Objective progression (activates on first hire). A competency matrix for every engineering and research level, with performance assessed on output rather than office presence or availability outside working hours, so that parents and remote workers are not quietly penalized.
Indicator: annual pay equity review completed; promotion rates proportional to representation. Responsible: CEO and COO.

4.4 Gender dimension in technology and research

Objective: that what we build is examined for bias, and that sex and gender analysis is considered by default rather than on request.

Gender dimension relevance analysis (in force from Q1 2027). Every research proposal and technical project records an explicit analysis of whether biological sex or socio-cultural gender is relevant to it, and if so how that is handled in the design. A documented finding of "not relevant, for these reasons" is a valid and expected outcome, and is recorded rather than skipped.
Indicator: all proposals and projects carry a completed analysis. Responsible: technical co-founder and GEO.

Bias review of what we ship (in force from Q1 2027). Systems we release carry a documented bias review before deployment, scoped to what that system does. The review records whether any demographic attribute reaches a decision path, and, where a system involves demographically relevant training data, whether that data is representative and has been tested for bias. The scope and the findings of each review are archived.
Indicator: all released systems carry a completed and archived review. Responsible: technical co-founder.

4.5 A safe workplace and measures against harassment

Objective: zero tolerance for gender-based violence, sexual harassment, bullying, or digital misconduct.

Code of Conduct (in force from Q4 2026). Lodestone Labs adopts the principles of the EU Code of Conduct on countering gender-based violence in research and innovation, and integrates anti-harassment, anti-bullying, and digital conduct rules into the onboarding pack.
Indicator: everyone who joins signs the Code of Conduct. Responsible: CEO.

Confidential reporting (interim now, third-party channel on trigger). A third-party anonymous reporting platform, independent of the management line, is deployed on first hire or within six months of first funding, whichever comes first, because it carries a subscription cost. Until then, reports can be made directly and in confidence to the GEO at eric@lodestone-labs.com, and to the CEO at pd@lodestone-labs.com where the report concerns the GEO. We name the interim route rather than describe a channel that is not yet running.
Indicator: a confidential reporting route is documented and available at all times. Responsible: GEO.

Investigation procedure (in force). Complaints are handled under a written procedure guaranteeing confidentiality, acknowledgement of the report within three working days, protection of the reporting person against retaliation, and disciplinary action where a complaint is upheld. Investigations conclude within 30 working days, or the reporting person is told in writing why more time is needed and when to expect a conclusion.
Indicator: every report acknowledged within three working days and closed under the written procedure. Responsible: CEO and GEO.

5. Training and capacity building

Unconscious bias training. Interactive annual training on unconscious gender bias, inclusive language, and bystander intervention. Mandatory for all decision-makers, meaning founders, board members, and anyone running a hiring process. At least 85% participation across all staff.

Externally led certified training is a cash cost, so the first externally led session runs within 12 months of first external funding or revenue. Before that point the GEO runs an annual internal session from the EIGE GEAR materials, which are free, and the fact that it was internally led is recorded as such rather than presented as external certification.

Curricula, materials, invitations, and attendance registers are archived in company records for audit.
Indicator: share of staff trained annually, target 85% or above. Responsible: GEO.

6. Implementation, review, and disputes

6.1 Roadmap

Action	Target
Formal adoption and signing of this plan by the CEO and the COO	Q3 2026
Publication of the plan at its permanent public URL	Q3 2026
Code of Conduct adopted and added to the onboarding pack	Q4 2026
Baseline sex and gender disaggregated data record established	Q4 2026
Gender dimension relevance analysis built into the R&D project checklist	Q1 2027
First Annual Gender Equality Report	Q1 2027
Annual review of this plan, and every year thereafter	Q4 2027
External GEO training and certification completed by the COO	Within 6 months of first external funding or revenue
Anonymous third-party reporting channel deployed	On first hire, or within 6 months of first funding, whichever comes first
First external unconscious bias training session	Within 12 months of first external funding or revenue
Handover of the GEO role to a dedicated people function	On establishing an HR function (trigger: 15 FTE)

6.2 Disputes and interpretation

Questions about the interpretation or execution of this plan go to the Gender Equality Officer at eric@lodestone-labs.com. The GEO issues binding guidance and resolves internal disputes together with executive leadership. Where a question concerns the GEO, it goes to the CEO at pd@lodestone-labs.com instead. Equality and non-retaliation take precedence in any interpretation.

6.3 Revision

This plan is reviewed annually and updated on the recommendation of the Annual Gender Equality Report. Changes are decided by the CEO and the COO. Each revision is published at this URL with an incremented version number, and the previous version is retained on request. This is version 1.0, effective 1 September 2026.

7. Adoption

Adopted and in force from 1 September 2026, signed on behalf of Lodestone Labs AS by:

Per Daniel M. Thorsrud Chief Executive Officer Lodestone Labs AS

Eric Stein-Beldring Chief Operating Officer, and Gender Equality Officer Lodestone Labs AS

A signed copy of this document is held in company records and is available on request from eric@lodestone-labs.com.