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This document establishes the basic guidelines and lines of action regarding the LeverX Group’s ESG strategy which allow the formalisation and implementation of the concept of ESG within the framework of the organisation, its communication thereof to stakeholders and the progressive systematisation in all systems and operational processes of the Company.
Scope of application
This policy mandatorily applies to all companies controlled by LeverX Group – LeverX and Emerline – and is responsibility of its entire team.
LeverX Group

Companies in which LeverX Group possesses or may possess, directly or indirectly, the control, where control means:

  • the ownership of the majority of the voting rights
  • the ability to appoint or remove a majority of the members of the Board of Directors (or equivalent body)
  • the ability to hold, by virtue of any agreements concluded with third parties, the majority of the voting rights

This Policy is aligned with and complemented with LeverX Group's internal regulations and corporate policies.




LeverX Group’s companies are deeply immersed in the client's business and from the very first stages of cooperation we begin to share common goals. In this way, the Company ensures the successful completion of each project for each client.


Honesty and Integrity

It is honesty, transparency and integrity in our work that make companies worldwide regardless it’s large trust us.


Noteworthy & Professionalism

Before project launch, the LeverX Group Team carefully analyzes the business needs of each client and takes into account all expectations. Thus, we ensure the successful development and implementation of the product.


Open communication and collaboration

We practice cross-functional team discussions and group brainstorming, while being open to new ideas and innovative approaches to business cooperation. We support diversity by building teams with experience, knowledge and skill sets to speed up the problem-solving process and increase productivity.


Reducing global impact

We have already established a smooth process of providing high-quality IT-solutions and services on a remote basis to meet challenging global conditions, reduce environmental impact and contribute to a sustainable and prosperous business future.


The policy defined herein constitutes the minimum requirements in terms of ESG-related matters to be met by all companies that operate under the umbrella of LeverX Group.

The chief executive of each company of LeverX Group must ensure that internal regulations are developed and/or adapted in line with this policy and with any applicable legal regulations.

The ESG Policy is applicable to all the organisation's activities and in all countries in which it operates both directly and indirectly. It covers the entire life cycle of the LeverX Group’s activity and complements the Group’s companies’ commitment to comply with the requirements of the legal framework in each country.

This policy is implemented within the following international standards of reference, which it also undertakes and adopts as regulatory framework of the limits under which the activity of the company shall be carried out:

  • Principles of the United Nations Global Compact (UN Global Compact)
  • Guiding Principles on Business and Human Rights (United Nations)
  • Sustainable Development Goals (United Nations)
  • Paris Agreement on Climate Change
  • Task Force on Climate-related Financial Disclosures (TCFD)
  • International Labour Organization’s (ILO) Fundamental
  • OECD Guidelines for Multinational Enterprises (OECD)

In line with these standards, LeverX Group commits to comply with all requirements, which applies to all Company’s activity.

In accordance with these standards, LeverX Group recognises three basic principles which apply transversally to all lines of action and commitments and upon which the implementation thereof is based:



The protection and preservation of the environment, preserving the areas, and their biodiversity, in which the Company activities are carried out, using renewable energies, mitigating of and adapting to climate change, and contributing to sustainable development through an efficient use of resources


Gender Equality

The protection and preservation of gender equality in which all genders of LeverX Group are free to pursue whatever career, lifestyle choice, and abilities they want without discrimination. Their rights, opportunities, and access to society are not different based on their gender. The Company strives to avoid imbalances in the Company and builds conditions for gender equality.


Partnerships for the goals

The identification of the organisation's stakeholders, taking into consideration the entire value chain of the activity, the development of communications and participation channels and their direct and indirect involvement in the identification of material aspects and the assessment of the performance – everything what could be aimed to projects for enhance the use of enabling technology, in particular IT technologies


Based on the above basic principles, LeverX Group defines the following lines of action, within which are framed the strategic lines developed by the Company to achieve its objectives in terms of ESG-related matters.



People management:

“Boosting talent of employees, being diverse, inclusive and gender equal”


Integrity and transparency:

“Showing what we are, acting with integrity and transparency”


Sustainable development:

“Growing with a long-term sustainable environmental approach”

Based on the defined axes, and through the development of the strategic lines, the LeverX Group acquires the following commitments which, in turn, contribute to the achievement of various targets of United Nations Sustainable Development Goals (SDGs) 4, 5, 17:

Boosting talent of employees, being diverse, inclusive and gender equal

This document establishes the basic guidelines and lines of action regarding the LeverX Group’s ESG strategy which allow the formalisation and implementation of the concept of ESG within the framework of the organisation, its communication thereof to stakeholders and the progressive systematisation in all systems and operational processes of the Company.

  • Create and support a common corporate culture among the Group
  • Promote and foster talent attraction and retention
  • Define and implement our equity, diversity, inclusion and gender equel program
  • Create and support opportunities for new knowledge, professional skills enhancing
  • Respect health and safety of our employees at their workplace.
Showing what we are, acting with integrity and transparency
  • Act ethically, respecting compliance and regulation standards
  • Define and implement our equity, diversity, inclusion and gender equal program
  • Contribute to smart digitalization and enhancing of IT enviroment with high-quality solutions
  • Manage the risks and opportunities of our activity
  • Create and support strong relationships with all stakeholders and alliances with third parties, contribute to their growth
Growing with a long-term sustainable environmental approach
  • Plan and manage our environmental sustainability strategy, involve people to join it
  • Mitigate our impact to climate change inside and outside the Group by managing responsibly and circularly the use ofresources within LeverX Group
  • Respect and minimize our impact on natural spaces and biodiversity

The capacity to have an impact in the application of the policy, will vary on the basis of the existing management capacity, as well as on the stakeholders involved in each of the material aspects. Moreover, each Business Unit and Functional Area,

in coordination with the Marketing Department of LeverX Group, is responsible for implementing the corresponding actions for compliance with the commitments outlined in this policy, as well as the specific linked procedures and regulations.


    One of the responsibilities of the LeverX Group Board of Directors is the approval of the corporate policies, and as a consequence of the ESG Policy, as well as of any substantial modifications made to it.

    The Management Team of LeverX Group undertakes to review the ESG Policy periodically, adapting it to new organizational, environmental or market requirements which may arise, as well as to communicate it to the organization and to make it available to interested parties at all times. Likewise, the Management Team of LeverX Group.

    The objectives in terms of ESG defined by the Company are consistent with this Policy, aligned with LeverX Group's process model, reviewed annually by the Management Team and updated according to their evolution and environment. Likewise, all departments in LeverX Group participate directly and indirectly in the implementation of actions and the monitoring thereof, in accordance with the corresponding sphere of competence and the relationship thereof with the material aspects in ESG-related matters.

    Annually, the entire organisation will be involved in process of collecting data and evidence of progress in the field of ESG, which are reflected in the Integrated Annual Report in which the results of the performance analysis are collected for each of the economic, environmental, social and governance aspects.

    The Integrated Annual Report is of a public nature.

    It is prepared following the standards of such documents and can be reviews every year by LeverX Group’s ESG team.