Gender Equality Plan

Gender Equality Plan (GEP) 2024-2026

Gender Equality Plan enacted by:

AcrossLimits’ Top Management

1. Introduction

AcrossLimits Ltd is a dynamic company primarily based in Malta, offering European solutions for technology, innovation, funding, networking, commercialisation and more. The company’s experience with EU opportunities makes it the go-to partner for specialist consultancy services for clients all over Europe.

The company’s core team consists of the Managing Director who oversees the work of 5 departments: HR, Finance and Administration; IT and Digital Media; Partnerships; EU Funding and Proposal Development; and EU Projects. The company also collaborates with a network of external experts around the world, who are professionals in their field and participate in European projects when their expertise is needed.

This Gender Equality Plan (GEP) was created for AcrossLimits Ltd by its management. At present, AcrossLimits Ltd has already committed to following the five main thematic areas covered by GEPs and has practices in place which are fully aligned with Maltese Legislation. The extent of these practices will be discussed throughout this document. AcrossLimits’ 2024-2026 GEP presents our commitment towards the values and principles of inclusion and equality, going beyond what is legally required and looking into the specific context and needs of AcrossLimits’ staff, and integrating good practices observed from other initiatives and entities.

Prior to the COVID-19 pandemic, AcrossLimits operated exclusively from an on-site office. The company always believed in encouraging employees to be independent and proactive, and nurtured an open-door culture, where employees were encouraged to communicate with management about any queries or issues. In 2020, AcrossLimits’ management decided to permanently transition the company to fully remote working, and these values also transitioned and were adapted to fit this change. Post-pandemic, the challenges and opportunities now facing AcrossLimits in the sphere of guaranteeing equality at the workplace relate to ensuring we keep abreast with emerging best practices as well as the continuously evolving makeup of the company. At present, AcrossLimits is experiencing a growth phase, having substantially increased its permanent staff over the past 2 years, and now having 19 staff members working virtually from 5 countries. As the company has grown and changed, the GEP now needs to reflect our current realities and look towards the future.

Gender equality has always been a core value determining AcrossLimits’ work externally as well as its internal operations and work culture. AcrossLimits is a value-driven company; in all we do, we seek to contribute to the achievement and protection of EU values, both within the internal environment we foster and the way we treat each other, and in our external operations.

Our values, coupled with our female leadership, means that our status quo naturally meets and respects the metrics by which organisations’ commitment to gender equality are typically measured. As is outlined in further detail below, we have in place policies for work-life balance, maintain an inclusive organisational culture, have attained gender balance in leadership and decision-making, ensure gender equality in recruitment and career progression, seek the genuine integration of gender dimension into research and training content, and strong measures against gender-based violence.

This update to our GEP represents a process of critical analysis and engagement with these existing policies, and as a result identifying areas where we can do even better, going beyond minimum requirements to ensure an even more productive and safe working environment for all. This is particularly important at this juncture in the company’s story; as we have grown to expand more people, we seek to celebrate all their diversity and make sure that everyone feels equally safe, welcomed and appreciated for who they are and what they bring to the table. This GEP also reflects our continuous learning process as a company. As we ourselves continue to interact with an ever-growing network and involve ourselves in more and more projects related to gender equality, we keep expanding our understanding of what it means to be a forward-looking European organisation.

In the next section, we analyse AcrossLimits’ current performance with regards to gender equality in the recommended five thematic areas for GEPs as highlighted in the Horizon Europe Guidance on Gender Equality Plans:

Work-life balance and an inclusive organisational culture
Gender balance in leadership and decision-making
Gender equality in recruitment and career progression
Integration of gender dimension into research and training content
Measures against gender-based violence.

The challenges and objectives for the coming 2 years are then presented.

2. Analysis of Status Quo via Thematic Areas

2.1 Work-life balance and organisational culture

AcrossLimits strongly believes in the provision of good working conditions for all staff, allowing the flexibility for a healthy work-life balance.. Staff retention is a key priority for AcrossLimits, a policy which is reflected in our low rate of employee turnover, and we believe that in prioritising work-life balance for all we enable employees to thrive both personally and professionally while maintaining optimal performance levels. AcrossLimits Ltd offers the below to all employees, regardless of gender identity:

Fully remote working;
Annual leave;
Sick leave;
Flexible working time arrangements and time off in lieu, including how departmental processes, procedures and practices impact on staff with caring responsibilities or full-time reduced workers – this is a ;
Workload management, including how different tasks are allocated and distributed;
Advice and support on work-life balance, including a pro-active approach by company management and department heads to continuously ensure that staff are not burnt out and that they are making full use of flexible work arrangements where they can.
Option to work reduced hours, where possible;

All staff are able to and encouraged to avail of the above arrangements. It is made explicitly clear to staff that making use of flexible or reduced working arrangements, for any purpose be it for caring responsibilities or other personal exigencies, will not negatively impact their career progression within the company.

2.1.1 Diversity and inclusion

At AcrossLimits Ltd, we recognise the importance of diversity in our fully remote workforce, which includes employees from Malta, the United Kingdom, Ireland, Italy, and Cyprus. A large part of our team consists of women, and we embrace individuals with various sexual orientations, gender expressions, and backgrounds. Our open and inclusive culture ensures that everyone feels welcome and respected, regardless of age, disability, ethnicity, or any other characteristic. By valuing diverse perspectives, we aim to foster a collaborative environment that supports gender equality and drives our success as a company. AcrossLimits has integrated this value-based approach in the company’s Mission, Vision and Value statements.

In its internal and external communication, AcrossLimits always uses gender neutral language across all communication. This ensures that all internal and external communication (emails, calls, recruitment efforts, website content, social media content etc) are gender neutral in both their intention and the language used.

In addition to the above, AcrossLimits Ltd follows all regulations as outlined in the Employment and Industrial Relations Act (Cap. 452 of the Laws of Malta) and subsidiary legislation (Organisation of Working Time Regulations – SL 452.87), and subsidiary legislation (Work Place (Minimum Health and Safety Requirements) Regulations – SL 424.15).

2.1.2 Gender Equality Officer

A new measure being enacted by this 2024 update to AcrossLimits’ GEP is that of the formal establishment of the Gender Equality Representative (GER). The GER is to act as the company’s point of reference on gender equality and sexual harassment issues. It is the GER’s responsibility to:

Provide a gender perspective on any new internal policies, measures, and conditions enacted by the company, as well as any funding & tenders proposals and external projects undertaken by AcrossLimits, thereby ensuring gender is mainstreamed at all levels of company action;
Provide training and guidance to staff on matters relating to gender equality and AcrossLimits’ policies, and ensure that all staff are aware of the relevant policies and reporting mechanisms and where to access them;
Ensure the timely and effective implementation of AcrossLimits’ GEP and Sexual Harassment Policy, as well as ensure monitoring and gathering of data is taking place accordingly;
Advise company management on gender equality concerns and ensure that this remains a top level concern at all times.
Act as an additional avenue for staff wishing to report concerns outside of the established formal reporting mechanisms to top management, so as to provide protection and guarantee anonymity to those lodging concerns.

For the period of 2024-2026, AcrossLimits’ GER will be Ms Rebecca Zammit.

2.2 Gender balance in leadership and decision making

In the diagram below one may see the staff making part of AcrossLimits Ltd. The company has a core team of full-time and full-time reduced hours’ employees, as well as a global network of experts who participate in projects when their expertise is needed. The diagram represents only those who form part of our core full-time and full-time reduced staff.

Figure 1: Staff gender composition

AcrossLimits’ top management consists of Ms Angele Giuliano as Managing Director, with input provided by the 5 Department Heads. The gender balance within the Management team is represented in the figure below.

Figure 2: Gender composition in Leadership

Department heads are continuously in touch with their respective team members, consulting and taking feedback on company progression and needs. A virtual ‘open door’ policy is enacted, wherein team members can always approach their department head, Head of HR, or Managing Director on any issue affecting decision-making. Moreover, management regularly requests feedback from all staff on important company-wide issues, such as establishing departmental strategies or company policies. This represents equal opportunity being given to all staff, regardless of gender, to influence company decisions. When it comes to day-to-day decision-making, participation and tasks are solely based on the individual’s role within the context of the project and their relevant qualifications

2.3 Gender equality in recruitment and career progression

AcrossLimits recognises that gender balance in recruitment and career progression for all staff ensures equal opportunities, both at the stage of recruitment and subsequent career progression.

AcrossLimits’ main recruitment strategy includes word of mouth, internal recommendations, as well as posting open calls on social media.
AL has standardised its process to recruit and select candidates – such process ensures that recruitment and selection is based solely on qualification, skills, and experience relevant to the role, ensuring that candidates are evaluated impartially, without discrimination based on gender or other protected characteristics. In brief, the process includes (i) identifying and making known to applicants the the list of tasks and responsibilities associated with the role, and the required and preferred skills and background; (ii) applicant CVs are reviewed against the required profile; (iii) shortlisted candidates are given a short task, tailored to the role, to test applicants’ skills; (iv) if performed adequately, individuals are called for interview; (v) the interview panel is made up of the respective Head of Department and the Head of HR. In cases of requiring further discussion, a second interview is called with the Managing Director also present. The interview panel will have pre-prepared a list of interview questions
- AL also prefers to receive a standardised curriculum vitae in Europass format, further equalising the interpretation of curriculum vitae. This recognised format allows for a clear structure for presenting qualifications and experience, minimising bias and ensuring that hiring decisions are based on merit only.
- The interviewing process involves fair and consistent assessment of all candidates, as interview panels are trained to recognise and mitigate bias, creating a respectful environment that values diverse perspectives and experiences.
- Department Heads, who along with the Head of HR are jointly responsible for hiring decisions in their respective departments, are well-versed in equality legislation and ensure that the criteria established for recruitment, application forms and interview questions only refer to what is essential for the performance of the job.
Equal access to training and development opportunities are provided for all employees as part of our gender equality plan. Training programmes are designed to empower all staff, supporting their professional growth without bias and encouraging diverse talent to thrive.
AcrossLimits has also standardised its performance appraisal system – again in the interest of ensuring fair and transparent evaluation for all. All employees are evaluated based on their performance and contributions, with clear criteria in place (personal KPIs) to ensure fairness and objectivity, eliminating any potential bias related to gender. Department Heads establish each person’s personal KPIs and development plan jointly with the concerned individual, and monitor achievement of KPIs at key points to ensure that they are met by the year’s deadline. By following this process, this ensures that promotion decisions are made with a commitment to fairness and removing any bias based on gender, sex, or any protected characteristic. All employees thus have equal opportunities for advancement, and promotions are awarded based on merit and suitability for the role, ensuring that gender or other personal characteristics do not influence these decisions.
Disciplinary procedures uphold our commitment to gender equality by ensuring that all disciplinary actions are applied consistently and fairly. Any necessary actions when needed are based on objective criteria, maintaining respect for all employees and ensuring that the characteristics of employees do not affect the process.
All new employees are given the same terms, introduction and relevant training when joining the company. In terms of career progression, any employee is judged based on their performance in their current role, their understanding of the company and the way they conduct themselves with all colleagues, as well as external stakeholders such as clients, consultants and partners.

AcrossLimits Ltd follows the principles that are highlighted in the Employment and Industrial Relations Act (Cap. 452 of the Laws of Malta) and subsidiary legislation (Equal Treatment in Employment Regulations – SL 452.95).

2.3.1 Equal Pay

AcrossLimits Ltd is committed to equal pay for equal work, adhering to guidelines set by the National Commission for the Promotion of Equality (NCPE) to ensure that all employees receive fair and equitable compensation regardless of gender or other protected characteristics.

To further enshrine this into practice, AcrossLimits has standardised its staff designations into those of junior officer; officer; senior officer; manager; department head; managing director. Each grade has been allocated a corresponding pay grade. These can be found in the company’s internal HR policy.

2.4 Integration of gender dimension into research and teaching content

AcrossLimits Ltd is committed to ensuring that all its processes and communication are gender neutral in both intention and the language used. The purpose of gender neutral language is to encourage employees to give due consideration to the issue of gender sensitivity in language whenever writing or speaking, in both intention and the type of language used This practice is in place for all internal and external communication (emails, calls, recruitment efforts, website content, social media content etc). Where necessary, we use gender positive language, seeking to challenge gender norms and assumptions in our communication by bringing bias to the audience’s attention.

In the past 2 years, AcrossLimits has gone further in its commitment to gender equality by seeking new and innovative ways to ensure the integration of a gender dimension in the EU-funded projects that we are part of. This includes:

Mandating the use of gender neutral or gender positive language in EU project communication in all projects where we are leading communication;
Implementing EU project R&I gender equality strategies;
Developing and giving gender equality training, tailored to the sectors of the project.

Moreover, the EU Projects team is continuously seeking to improve its operations in this regard, and is currently in the process of implementing further operational measures to allow for a more holistic gender dimension to be undertaken in our projects. These are outlined in the challenges section below.

2.5 Measures against gender-based violence including sexual harassment

AcrossLimits Ltd believes in non-discriminatory treatment based on the grounds of religion or religious belief, disability, age, sex, sexual orientation, political orientation and racial or ethnic origin. We are fully committed to ensuring a safe and respectful workplace for all, and to this end, the Company has adopted an internal Sexual Harassment Policy (SHP) which clearly outlines a network of reporting mechanisms for gender equality and sexual harassment issues.

As a fully remote company with employees who communicate for the most part through video calls, email and business platforms, the focus is to encourage respect, trust and camaraderie amongst colleagues. At the same time, our staff routinely travel to international events such as conferences or project meetings to meet internal and external colleagues, and measures are in place to ensure their safety in such cases.

AcrossLimits Ltd enforces a zero-tolerance approach towards gender-based violence and sexual harassment. Any behaviour that undermines the safety and dignity of employees will not be tolerated. This policy applies not only to our employees, regardless of their position within the company, but also to our partners and clients. If partners or clients engage in such behaviour, AcrossLimits reserves the right to terminate business relationships with immediate effect. This will be formally written into our standards terms of reference for service provision as part of our challenges for the upcoming GEP action timeframe.

The concept of allyship will be a core tenet of the SHP, maintaining the important role that colleagues play in protecting each other and being actively engaged in preventing harm for their colleagues. Any staff member who observes such behaviour from any colleague, client, or partner is to immediately report this through the reporting procedures outlined immediately, to safeguard themselves and their colleagues. This commitment is fully aligned with our aim to foster a respectful and inclusive environment for all parties involved.

In our policies, AcrossLimits follows principles highlighted in the Employment and Industrial Relations Act (Cap. 452 of the Laws of Malta) and subsidiary legislation (Equal Treatment in Employment Regulations – SL 452.95), the Equality for Men and Women Act (Cap. 456 of the Laws of Malta), and the Gender Identity, Gender Expression and Sex Characteristics Act (Cap. 540 of the Laws of Malta).

2.5.1 Reporting procedures, Investigations and Support for Victims

Employees are encouraged to report any incidents they experience or witness, whether these involve colleagues, project partners, or clients. Everyone is responsible for maintaining a respectful environment, and any behaviour that raises concerns should be promptly reported through the designated channels.

AcrossLimits takes all reports of gender-based violence, including sexual harassment, with the utmost seriousness. Upon receiving a complaint, a thorough and impartial investigation is conducted by designated personnel, ensuring confidentiality and fairness throughout. The investigation is handled in a timely manner, and if the claims are substantiated, appropriate disciplinary action will be taken. Disciplinary measures may include formal warnings, suspension, or termination of employment, depending on the severity of the incident. Retaliation against individuals who report such incidents in good faith is strictly prohibited.

Reports are handled confidentially, and those who come forward in good faith will be protected from retaliation. When considering remedial actions, utmost care will always be taken to protect the victim and their needs, as is outlined in the SHP.

2.5.2 Training and awareness

AcrossLimits recognises the importance of ensuring that all staff are aware of the GEP and SHP, as well as the equality concepts underpinning both. Ad hoc training has been implemented when needed and/or when requested by staff. Going forward, the GER is to ensure that training is given to all current staff as well as ensuring that incoming staff are similarly trained on these policies.

3. Challenges and Objectives

Following the analysis undertaken above of the status quo of AcrossLimits’ performance in all 5 gender equality dimensions outlined, the company’s challenges and objectives relating to gender equality and diversity are presented below. These challenges have been identified by AcrossLimits’ Managing Director, Department Heads and Gender Equality Representative, and presented for feedback and input to all staff members. This therefore presents a holistic overview of targets across all departments.

3.1 Challenge 1: Encouraging employees to use all their annual leave in order to have a better work-life balance

Thematic Area	Goal	Challenge	Target Date	Person Responsible
Work-life balance & organisational culture	Ensuring all employees use all their annual leave	Due to flexible work arrangements, our system of time off in lieu, and fully remote working, annual leave tends to accumulate.	Yearly, end Q4. Review point at end Q2)	Jacqueline Bugeja, respective Department Heads

Action Plan: Head of HR, Finance and Administration to keep tabs on employees’ vacation leave. Department Heads are alerted when their team members have a large amount of outstanding leave, so that they can remind their team members to make use of their annual leave and ensure a proper work-life balance.

3.2 Challenge 2: Ensuring staff are more aware of unquestioned bias, social norms, and assumptions, and challenging these ingrained behaviours to ensure our organisation is a safe and welcoming space for all

Thematic Area	Goal	Challenge	Target Date	Person Responsible
Work-life balance & organisational culture	Helping staff to identify and actively challenge unquestioned norms and their socially learned behaviours that could potentially cause harm or discomfort to colleagues, clients, or partners	Due to the targeted issues being subconscious assumptions or behaviours, it is often difficult for an individual to realise that they are perpetuating harmful bias. Staff need to be supported by bringing these issues to their attention in a safe learning space, where they are guided in understanding why it is an issue, and how to prevent it in future. The challenge here is also recognising that such actions are often a result of lack of awareness and understanding of different lived realities, rather than being rooted in a lack of goodwill or a genuine desire to exclude or belittle. Therefore, it needs to be addressed in a way that does not alienate staff or cause them frustration and confusion, or perpetuate a culture where colleagues are afraid to speak with each other lest they unknowingly offend.	Training by Q4 2024 Ongoing monitoring to continuously assess organisational culture and address issues as they come up. Follow-up training to be organised if required	Rebecca Zammit

Action Plan: A company-wide training is to be organised by the Gender Equality Representative that will focus on the role of subconscious bias and gendered assumptions. Training will introduce the staff to various concepts such as unconscious gender bias and stereotyping, assumed heteronormativity and cisnormativity, gender identity and expression. We will explore our individual role in perpetuating potentially harmful bias in a day-to-day context, especially practical examples within the work environment, and discuss why this can be harmful to colleagues. Training material is to be made available to all current staff and integrated into the new employee induction programme for incoming staff.

GER is to continuously monitor organisational culture and address any issues and harmful language or actions, using a constructive learning approach rather than harsh disciplinary action, unless the latter is deemed warranted.

Follow-up trainings can be organised yearly at the all-hands in-person meetings.

3.3 Challenge 3: Achieving NCPE Equality Mark Certification

Thematic Area	Goal	Challenge	Target Date	Person Responsible
Work-life balance & organisational culture	To apply for the NCPE Equality Mark Certification	The National Commission for the Promotion of Equality awards a national certificate to organisations that demonstrate a commitment towards best practices in the area of gender equality. AcrossLimits seeks to apply for the Equality Mark because it is committed to all the principles the Equality Mark enshrines.	Application to be submitted by Q3 2025 Target achievement of Quality Mark by end 2026	Rebecca Zammit Angele Giuliano Jacqueline Bugeja Alim Sancar

Action Plan: Ensure that all necessary internal policies required for application are updated. Submit application for Equality Mark by Q3 2025. Work with NCPE to amend or adjust policies if need be. Timeline and length of certification process is uncertain, target achievement date is estimated for end 2026.

3.4 Challenge 4: Integrate the collection and use of gender disaggregated data in all EU projects

Thematic Area	Goal	Challenge	Target Date	Person Responsible
Integration of gender dimension into research and teaching content	Ensure that in all projects, gender disaggregated data is being collected where possible (e.g. participants attending or participating in events, where such data is collected). This allows accurate reporting and understanding of our activities, and allows the team to identify and address any issues of gender imbalance	Ensure that the EU project team standardises its activity organisation so as to collect gender disaggregated data for participant, where such data is collected.	Q1 2025, with ongoing action	Rebecca Zammit and EU Projects Team

Action Plan: Update standard EU project templates and forms to gather gender disaggregated data by Q1 2025. Ongoing monitoring to ensure this is being implemented.

3.5 Challenge 5: Integrate a gender dimension in the writing of EU proposals

Thematic Area	Goal	Challenge	Target Date	Person Responsible
Integration of gender dimension into research and teaching content	Ensure that in all proposals written by AcrossLimits, a forward-looking gender dimension is integrated into the workplan.	EU proposals already require certain minimum requirements of applicants. Our goal is to go beyond these minimum requirements and ensure a genuine and effective commitment to gender equality is holistically integrated in future funded projects.	Ongoing action	Alexander Camilleri and EU Funding and Proposal Development Team.

Action Plan: Proposal writing team is to assess and adapt what gender dimension measures should be written into each proposal on a case by case basis. GER feedback can be provided.

3.6 Challenge 6: Be an actively engaged participant in the EU gender equality ecosystem.

Thematic Area	Goal	Challenge	Target Date	Person Responsible
Integration of gender dimension into research and teaching content	Ensure that AcrossLimits is keeping up to date with emerging good and best practices at a national and EU level in the field of gender equality, via networking and ecosystem building, ongoing research and policy monitoring, and our participation in relevant initiatives and projects.	Gender studies is a constantly evolving and dynamic field, and we must ensure that we remain dynamic and engaged within the field to avoid falling behind the times. Moreover, good and best practices are continuously emerging in our wider network and it is our responsibility to ensure that we are active participants and contributors in this field.	Ongoing action	Angele Giuliano Alexander Camilleri Senfer Usman Alim Sancar Rebecca Zammit

Action Plan: This is a multi-pronged action that involves various dimensions of AcrossLimits’ work:

Partnerships: identifying and, where possible and financially feasible, sending representatives to major gender equality forums and conferences. A target of 1 gender equality event attended by an AcrossLimits representative per year in 2025 and 2026 is being set by this GEP. Partnerships is to actively seek building connections with other organisations that are working in the field of gender equality.
EU Funding and Proposal Development Team, EU Projects Team: Monitoring national and European gender equality policy updates and developments, and monitoring of emerging good and best practices from other national and EU initiatives and projects. Identifying any updates or actions that can be integrated into our own work as a result.

3.7 Challenge 7: Review and Update AcrossLimits’ internal Sexual Harassment Policy

Thematic Area	Goal	Challenge	Target Date	Person Responsible
Measures against gender-based violence including sexual harassment	Review and update our internal sexual harassment policy, particularly to ensure clear and practical lines of reporting	AcrossLimits’ sexual harassment policy has not been updated in recent years, and changes in company structure (introduction of heads of department and of GER) means that we should update it to reflect the new company organisational structure. All current and future staff should be made aware of its existence and where to access it.	Update policy by Q2 2025 Update staff meeting by Q3 2025	Angele Giuliano Rebecca Zammit Jacqueline Bugeja

Action Plan: Identify responsible persons to review and update sexual harassment policy and ensure that there are clear lines of reporting. Target completion date is Q2 2025. A separate update meeting will be held with all the company as soon as it is finalised to ensure all are aware of its existence, and where to access it, to be done by latest Q3 2025. Once complete, it will be integrated within the existing new employee induction programme.

3.8 Challenge 8: Updating AcrossLimits’ Terms of Reference to Protect Staff

Thematic Area	Goal	Challenge	Target Date	Person Responsible
Measures against gender-based violence including sexual harassment	Update our terms of reference for clients, partners, external experts, and other external contract-based relationships to ensure that AcrossLimits has the right to terminate relationships for breach of our harassment policy.	Sexual harassment can occur not just internally between colleagues, but also from external individuals with whom we have a contractual relationship. This can cause added stress and harm to our staff, who feel pressured to keep silent or allow unacceptable behaviour to continue because they think the company is bound to these third parties. By updating our terms of reference, AcrossLimits ensures that we can legally protect our staff from such actions.	Q2 2025	Angele Giuliano Rebecca Zammit Jacqueline Bugeja

Action Plan: Update terms of reference in all our standard contracts. Make our terms of reference public on our website.

3.9 Challenge 9: Set up an anonymous reporting mechanism

Thematic Area	Goal	Challenge	Target Date	Person Responsible
Measures against gender-based violence including sexual harassment	Set up an anonymised form that can submit complaints, issues or concerns from staff to the GER’s inbox.	There can be cases where an individual, for various reasons, is not comfortable with reporting a concern to their Department Head or to the Head of HR, or would like to make a report but maintain their anonymity.	Q2 2025	Rebecca Zammit Emanuele Pristera'

Action Plan: Set up an anonymised form that is directed to the GER’s inbox, who can take action on any concerns identified. Ensure staff are aware of where to find it.

4. Data Collection

Challenge	Data collection strategy
Challenge 1: Encouraging employees to use all their annual leave in order to have a better work-life balance	Use the company’s leave booking system to monitor leave taken and download reports, which HR Manager uses to report to Department Heads of any imbalances.
Challenge 2: Ensuring staff are more aware of their unquestioned bias, social norms, and assumptions, and challenging these ingrained behaviours to ensure our organisation is a safe and welcoming space for all	Register staff attendance Update company's internal training log
Challenge 3: Achieving NCPE Equality Mark Certification	NCPE Equality Mark application submitted and process is followed through until certification is awarded
Challenge 4: Integrate the collection and use of gender disaggregated data in all EU projects	Updated registration sheet templates Taking random samples of registration sheets to ensure that gender disaggregated data is being collected
Challenge 5: Integrate a gender dimension in the writing of EU proposals	Taking random samples of written proposals to check inclusion of gender equality dimension
Challenge 6: Be an actively engaged participant in the EU gender equality ecosystem.	Number of events, fora or networks joined or attended relating to gender equality
Challenge 7: Review and Update AcrossLimits’ internal Sexual Harassment Policy	Updated Sexual Harassment Policy by target date Training on new policy to be tracked on internal training log
Challenge 8: Updating AcrossLimits’ Terms of Reference to Protect Staff	Updated T&Cs on project website by target date
Challenge 9: Set up an anonymous reporting mechanism	Form available by target date

5. Monitoring, Reporting and Evaluation

The GEP will be monitored using the above outlined data collection methods. A review point is set for November 2025. The GEP will need to be fully updated in November 2026. The responsible individuals are Angele Giuliano, Jacqueline Bugeja, and Rebecca Zammit.

The below framework is to be utilised for the mid-term evaluation.

Challenge	Achieved? Y/N	Evidence	Progress	Comments
Challenge 1: Encouraging employees to use all their annual leave in order to have a better work-life balance
Challenge 2: Ensuring staff are more aware of unquestioned bias, social norms, and assumptions, and challenging these ingrained behaviours to ensure our organisation is a safe and welcoming space for all
Challenge 3: Achieving NCPE Equality Mark Certification
Challenge 4: Integrate the collection and use of gender disaggregated data in all EU projects
Challenge 5: Integrate a gender dimension in the writing of EU proposals
Challenge 6: Be an actively engaged participant in the EU gender equality ecosystem.
Challenge 7: Review and Update AcrossLimits’ internal Sexual Harassment Policy
Challenge 8: Updating AcrossLimits’ Terms of Reference to Protect Staff
Challenge 9: Set up an anonymous reporting mechanism

A review or update of the Gender Equality Plan can also be undertaken should pertinent and relevant updates be requested by any member of staff, such as to integrate new and more innovative ideas, policies or actions that they come across, or to address a lacuna in our current policy. This request for revision can be made to the GER at any point in time of the GEP’s implementation.