Gender Equality Plan

This document has been formally reviewed and approved, and is signed off by the CTO and Co-founder.

1. Introduction and Statement of Commitment

Lens Health Technologies Ltd ("Lens" or "the Company") is committed to fostering a working environment built on equality, fairness, inclusion, and respect for all individuals, regardless of gender, gender identity, sexual orientation, ethnicity, disability, age, religion, or any other protected characteristic.

This Gender Equality Plan ("GEP" or "the Plan") sets out the Company's strategic commitment, current practices, and planned actions to promote gender equality, diversity, and inclusion (EDI) across all aspects of its operations, in line with the requirements of the European Innovation Council (EIC) and the Horizon Europe Gender Equality Plan eligibility criterion.

Lens recognises that gender equality is not only a legal and ethical obligation but a driver of innovation, better decision-making, and organisational performance. This Plan applies to all employees, contractors, consultants, board members, and other individuals engaged in the Company's activities, and covers recruitment, career development, pay, governance, work-life balance, and organisational culture.

2. Scope, Purpose and Regulatory Context

This document serves as Lens' formal Gender Equality Plan, satisfying the EIC/Horizon Europe requirement that participating organisations demonstrate a structured, resourced, and monitored approach to gender equality.

The Plan meets the four mandatory process-related requirements defined by the European Commission for GEPs under the Horizon Europe Framework Programme (2021–2027):

  • Publication — a formal document, publicly available and endorsed by senior management (see document control table above).
  • Dedicated resources — commitment of resources and expertise for implementation (Section 4).
  • Data collection and monitoring — sex/gender-disaggregated data on personnel, reported annually against defined indicators (Section 7).
  • Training — awareness-raising and training on gender equality and unconscious bias for staff and decision-makers (Section 8).

In addition, this Plan addresses the five thematic areas recommended by the European Commission:

  • Work-life balance and organisational culture
  • Gender balance in leadership and decision-making
  • Gender equality in recruitment and career progression
  • Integration of the gender dimension in research, innovation, and product development
  • Measures against gender-based violence, harassment, and bullying

3. Current Workforce Composition (Baseline)

The following baseline figures, as of [date], form the starting point against which progress under this Plan will be measured. This table will be updated annually as part of the monitoring cycle described in Section 7.

IndicatorCurrent figure
Total headcount6
Gender split — overall (%)33%
Gender split — leadership/Board (%)25%

4. Dedicated Resources

Lens commits the following resources to ensure effective implementation of this Plan, satisfying the EIC's mandatory dedicated-resources requirement:

  • Executive sponsorship from the CTO, with formal accountability for the Plan's implementation and outcomes.
  • Nominated People lead — at current company size this responsibility sits with Thomas Broomhead; a dedicated People/HR function will be established once headcount reaches 25 employees.
  • Annual budget allocated for training, awareness campaigns, and EDI initiatives.
  • Access to external expertise (EDI consultants, legal advisors, or EIC/Horizon Europe guidance materials) as required.
  • A defined internal reporting channel for raising concerns related to gender equality, harassment, or discrimination — see Section 9.

5. Objectives and Planned Actions

Section 5 outlines the organisation's approach to advancing gender equality across key areas, in line with Innovate UK guidance. Rather than prescribing fixed actions or targets at this stage, it sets out the priority themes that will guide ongoing development and implementation.

These themes include fostering a supportive and inclusive organisational culture, promoting balance in leadership and decision-making, ensuring fairness in recruitment and career progression, and considering gender dimensions within research, innovation, and product development activities. In addition, the organisation recognises the importance of maintaining a safe and respectful working environment, with appropriate measures to prevent and address harassment, bullying, or gender-based misconduct.

Actions within these areas will be developed iteratively, taking into account organisational growth, workforce needs, and evolving best practice. Where appropriate, proportionate measures will be introduced to support flexibility, inclusivity, transparency, and accountability across all levels of the organisation.

This section should therefore be read as a framework for continuous improvement, rather than a fixed set of commitments, with further detail to be defined and implemented over time.

6. Current Practices Supporting Equal Opportunities

The organisation maintains a set of policies, practices, and procedures that form the baseline for this Plan. These existing measures provide the foundation upon which the actions outlined in Section 5 will build.

This includes, but is not limited to:

  • Policies relating to equality, diversity, and inclusion
  • Workplace practices such as flexible working and leave arrangements
  • Recruitment, progression, and pay review processes
  • Any relevant training or awareness initiatives already delivered

Where actions in Section 5 reference policies or practices that are not yet in place, these are identified as "in development" rather than assumed to already exist.

7. Data Collection and Monitoring

In line with the EIC's mandatory data collection and monitoring requirement, Lens will collect and analyse sex/gender-disaggregated data annually across the following indicators, building on the baseline in Section 3:

  • Overall workforce gender composition (headcount and %)
  • Gender composition by seniority level (junior, mid, senior, leadership/Board)
  • Gender composition of new hires and applicants (recruitment funnel)
  • Gender pay gap analysis, where applicable
  • Uptake of flexible working and parental leave, by gender
  • Number and nature of harassment/discrimination reports, and resolution outcomes
  • Training completion rates for gender equality and unconscious bias training

Data will be reviewed annually and summarised in an updated version of this Plan, published alongside the review date noted in the document control table.

8. Training and Awareness-Raising

In line with the EIC's mandatory training requirement, Lens will implement the following:

  • Mandatory gender equality and diversity awareness training for all employees, delivered at onboarding and refreshed annually.
  • Unconscious bias training for all staff involved in recruitment, performance evaluation, and promotion decisions, including senior management.
  • Periodic awareness campaigns and internal communications reinforcing the Company's commitment to gender equality and inclusion.
  • Guidance and training on the confidential reporting procedure for harassment or discrimination (see Section 9).

Training completion will be tracked and reported as part of the annual monitoring cycle described in Section 7.

9. Reporting Concerns and Governance

Lens provides a confidential channel for raising concerns related to gender equality, harassment, or discrimination:

  • Reporting route: contact@lenstechnologies.ai
  • Case handling: Concerns are reviewed by Amar Dhanda under the Company's Policies, with confidentiality maintained throughout.
  • Escalation: Where a concern involves the reporting individual's direct line, escalation is available via admin@lenstechnologies.ai

This Plan is reviewed annually by Amar Dhanda, per the document control table above. Material changes to Company structure, headcount, or policy will trigger an off-cycle review.