Gender Equality Plan

Chapter 1. Scope and purposes

Article 1. Institutional commitment

TRAILAB is committed to gender equality as a fundamental component of responsible research, good institutional governance and scientific excellence.

TRAILAB's mission is to promote, develop and coordinate scientific, legal, ethical and social research concerning Trustworthy and Reflective Artificial Intelligence, with particular attention to human agency, fundamental rights, accountability and the public interest. Gender equality, equal opportunity and the prevention of discrimination are integral to this mission.

This Gender Equality Plan, hereon referred to as “GEP” or “the Plan”, establishes TRAILAB's institutional objectives, responsibilities, measures and monitoring mechanisms for advancing gender equality during the period 2026–2029. It is designed to produce meaningful and proportionate institutional change while recognising the realities of TRAILAB as a newly established and comparatively small research organisation.

The Plan has been adopted by TRAILAB's Board of Directors and signed by its President. It shall be publicly available on TRAILAB's website and communicated to members, employees, researchers and collaborators. The Board of Directors assumes ultimate responsibility for implementation of the Plan.

Article 2. Scope

This Plan applies, as appropriate to their relationship with TRAILAB, to:

association members;
members of the Board of Directors;
employees;
researchers and other personnel paid through TRAILAB projects;
association members participating in TRAILAB activities;
collaborators in TRAILAB projects;
external professionals and contractors working within TRAILAB projects;
persons participating in recruitment, promotion, evaluation or other institutional decision-making processes; and
participants in conferences, workshops, research activities, fieldwork, online environments and other activities organised by TRAILAB.

Employment-specific provisions apply to employees and, where appropriate, other categories of paid personnel according to their legal relationship with TRAILAB.

TRAILAB will also seek to promote the principles of this Plan in research consortia, partnerships and other collaborative activities in which it participates.

Article 3. Principles

The implementation of the GEP is guided by the following principles.

Article 3.1. Equality and non-discrimination. No person shall receive less favourable treatment on grounds of sex, gender identity or expression, sexual orientation, pregnancy, maternity, paternity, family or caring responsibilities, or any other protected characteristic.

Article 3.2. Substantive equality TRAILAB understands gender equality as extending beyond formally identical treatment. Rules and procedures that appear neutral can still produce unequal effects. TRAILAB will therefore consider both how institutional processes are designed and the outcomes they produce.

Article 3.3. Intersectionality Gender does not operate independently from other characteristics and social positions. TRAILAB will consider, where relevant, interactions between gender and factors including disability, age, racialisation or ethnicity, nationality and migration background, socioeconomic circumstances, sexual orientation, neurodiversity, family responsibilities and other sources of structural advantage or disadvantage.

Intersectionality will be considered both in institutional policies and in research design where scientifically and ethically relevant.

This commitment does not imply indiscriminate collection of sensitive personal information. Any collection or processing of personal data must have a defined purpose and comply with applicable data-protection requirements, in particular the European Union's General Data Protection Regulation (GDPR).

Article 3.4. Evidence and proportionality Measures adopted under this Plan should respond to identifiable problems, risks or objectives and be proportionate to TRAILAB's size and activities.

Article 3.5. Individual dignity, privacy and self-identification TRAILAB will not infer a person's gender identity from their name, appearance or other indirect characteristics. Gender information will be based on voluntary self-identification where collection is necessary and appropriate.

Where gender information is collected, individuals will normally be offered the categories:

woman;
man;
non-binary;
prefer not to say.

Where information concerning sex is required for a distinct legal, statistical or scientific purpose, it will be collected separately and will not be conflated with gender identity.

Article 3.6. Shared responsibility Gender equality is an institutional responsibility rather than solely the responsibility of women, gender-diverse persons or the Gender Equality Officer.

Chapter 2. Governance and resources

Article 4. The Board of Directors

The Board of Directors has ultimate responsibility for the GEP. The Board of Directors shall:

formally adopt this Plan and subsequent revisions;
ensure that adequate resources are available for its implementation;
receive and review annual monitoring reports;
approve corrective measures where objectives are not being met;
ensure that gender-equality considerations are integrated into relevant institutional policies and procedures; and
ensure that the Gender Equality Officer can perform their functions with sufficient independence and access to relevant information.

Article 5. The Gender Equality Officer

The Board shall appoint a Gender Equality Officer (GEO) responsible for coordinating implementation of the Plan. The Gender Equality Officer shall:

coordinate and monitor the implementation of GEP measures;
maintain the GEP action and indicator register;
coordinate training and awareness activities;
identify areas requiring external expertise;
coordinate gender-equality data collection and monitoring;
prepare the annual Gender Equality Monitoring Report;
advise project leaders and management on implementation;
make recommendations to the Board;
propose corrective measures where monitoring identifies shortcomings; and
act as one point of contact for questions concerning the GEP.

The GEO shall have direct access to the Board of Directors when necessary for the performance of these functions.

The role does not confer responsibility for investigating complaints where doing so would create a conflict of interest or require specialist expertise.

Dedicated time

TRAILAB shall allocate the Gender Equality Officer a minimum of 60 working hours per calendar year specifically for implementation, monitoring, training coordination and development of the GEP. This allocation is a minimum and may be increased where organisational growth, research projects or identified equality issues create additional needs.

Article 6. Financial resources and expertise

The Board of Directors shall approve annually a dedicated budget sufficient to implement the actions scheduled under this Gender Equality Plan for the corresponding year. The amount shall be determined in light of the activities planned, TRAILAB's organisational size and available resources, and shall be separately identifiable for monitoring purposes.

The allocation may be used for:

accessibility and inclusion measures;
external training;
review of recruitment and employment procedures;
development and operation of anti-harassment procedures;
specialist gender-equality advice;
external review of the GEP;
training or methodological assistance concerning sex, gender and intersectional analysis in research.

Where permitted by funding conditions, TRAILAB projects may additionally allocate resources to gender-equality measures directly connected to project implementation.

Because TRAILAB does not currently possess specialist institutional gender-equality expertise, the organisation will obtain external expertise when required rather than treating appointment of the Gender Equality Officer alone as sufficient expertise.

Chapter 3. Data collection, monitoring and reporting

Article 7. Baseline assessment

TRAILAB is a newly established organisation. Within three months of adoption of this Plan, the Gender Equality Officer shall establish a verified baseline assessment, including clear definitions of personnel categories and avoidance of double counting between employment, research and membership categories.

Article 8. Annual monitoring

The GEO shall prepare an annual Gender Equality Monitoring Report for consideration by the Board.

The report shall normally cover:

gender distribution across organisational categories;
recruitment applications, shortlists, interviews and appointments, where data are available;
career level and progression;
leadership and decision-making roles;
contract type and working-time arrangements;
salary bands and compensation;
participation in professional development and training;
use of work-life balance measures where suitable aggregate information can be obtained;
participation in research projects and project-leadership roles;
completion of gender-equality training;
implementation status of GEP actions;
incorporation of sex/gender and intersectionality assessments in research projects; and
anonymised information concerning complaints of gender-based discrimination, harassment or violence, where disclosure is compatible with confidentiality.

Small-number protection

TRAILAB recognises that its small size creates a significant risk of re-identification, despite anonymisation. Detailed internal data may therefore be available to the GEO and Board for legitimate monitoring purposes without being publicly disclosed.

Where data are suppressed, the public report should state that the indicator was monitored but cannot be disclosed because of small-number confidentiality. As a general rule, public reports shall not disclose disaggregated cells containing fewer than five persons where disclosure could reasonably identify individuals.

Annual reporting cycle

An initial Gender Equality Monitoring Report baseline shall be established within three months of adoption of this Plan. Thereafter:

data will be reviewed annually;
the Board will consider the annual monitoring results;
a concise public monitoring update will be published;
implementation measures may be amended where indicators reveal persistent or emerging inequalities.

Chapter 4. Work-life balance and organisational culture

Article 9. Measures for work-life balance

TRAILAB recognises that working practices can have different effects according to caring responsibilities, family circumstances, disability and other personal conditions, and that these effects frequently interact with gender.

TRAILAB already supports remote work, flexible schedules and rules concerning meeting times. During the first year of this Plan, these practices will be formally documented to ensure that they are transparent and consistently available.

TRAILAB shall:

maintain reasonable access to remote and hybrid working where compatible with the nature of the role and project;
maintain flexible working arrangements where compatible with operational requirements;
codify its existing meeting-hours practice and avoid routinely scheduling mandatory meetings outside normal working periods;
avoid unnecessary expectations of availability outside agreed working hours;
respect statutory rights relating to pregnancy, birth, parental leave, caring responsibilities and work-life reconciliation;
ensure that use of lawful flexible-working or family-related measures does not disadvantage career progression, access to projects or participation in decision-making;
periodically assess organisational culture and perceived inclusion; and
consider accessibility, disability and caring responsibilities alongside gender when reviewing working practices.

Remote participation shall not disadvantage staff in access to institutional information, decision-making processes, project opportunities or professional development.

Chapter 5. Gender balance in leadership and decision-making

Article 10. Measures to improve gender balance in leadership

TRAILAB's Board is currently composed of three men. The organisation therefore identifies representation in leadership as an area requiring improvement.

Appointments and elections must remain based on competence and the procedures established in TRAILAB's statutes. At the same time, TRAILAB recognises that candidate identification, nomination networks and institutional visibility can affect who is in a position to compete for leadership responsibilities.

TRAILAB will therefore:

monitor the gender composition of the Board, project leadership, committees, working groups and other significant decision-making structures;
examine barriers to progression into leadership positions;
provide equal access to opportunities that build leadership experience;
actively seek qualified women and gender-diverse persons when identifying candidates and constituting leadership bodies, advisory groups, committees and working groups; and
avoid relying exclusively on existing personal and professional networks when broader searches are reasonably possible.

Representation objective

By the end of the Plan, TRAILAB aims to change the exclusively male composition of its Board, whether through future Board renewals or by expanding the Board to include additional members.

For a three-member Board, the operational objective is that at least one member be a woman by the end of the Plan, subject to the democratic procedures established in the statutes and the availability of eligible candidates.

If the Board expands to five or more members, TRAILAB will aim progressively towards a composition in which neither women nor men account for more than 60% of members, while recognising non-binary representation separately.

The organisation shall not achieve these objectives by compromising applicable requirements of competence, democratic election or non-discrimination. Where an objective cannot be achieved, TRAILAB will document the measures undertaken and the factors preventing achievement.

Chapter 6. Recruitment, selection and career progression

Article 11. Recruitment principles

TRAILAB's first employees were recruited from a pre-existing research group. As the organisation grows, recruitment practices should progressively broaden beyond existing personal and academic networks in order to reach a wider and more diverse pool of candidates.

TRAILAB will therefore establish a formal recruitment procedure during the first year of this Plan. For paid vacancies, TRAILAB shall progressively implement the following rules:

vacancies will normally be publicly advertised where the nature and duration of the position make this proportionate;
exceptions for direct or network-based appointments must have a legitimate project or organisational justification;
vacancy descriptions will use inclusive and gender-neutral language;
essential and desirable criteria will be specified before assessment;
evaluation criteria shall be related to the requirements of the position;
unnecessary requirements that could indirectly exclude suitable candidates shall be avoided;
research vacancies will be disseminated, where reasonably possible, through channels capable of reaching candidates beyond TRAILAB's existing networks;
recruitment records shall permit subsequent equality monitoring;
where more than one assessor is used, TRAILAB will seek gender diversity among assessors;
where a qualified applicant pool contains candidates of different genders, single-gender shortlists should be avoided unless justified by the assessment results.

TRAILAB shall not lower academic, scientific, technical or professional standards in pursuit of gender balance. The objective of this Plan is to broaden access to opportunities and reduce avoidable bias in how candidates are reached, evaluated and selected.

Recruitment monitoring

For each substantive recruitment process, TRAILAB will record where legally and practically possible:

number of applicants;
gender distribution of applicants;
candidates shortlisted;
candidates interviewed;
candidate appointed.

Data will be analysed in aggregate and subject to the privacy safeguards established in this Plan as part of the Gender Equality Monitoring Report.

Article 12. Equality in career progression

As TRAILAB develops a research career structure, it shall establish transparent criteria for progression between research grades.

Career evaluation will recognise relevant contributions according to the responsibilities of each role, potentially including but not limited to:

research outputs;
methodological and technical contributions;
project development;
research leadership, supervision and mentoring;
institutional service;
knowledge transfer;
societal impact;
policy contribution;
research software, datasets and other research outputs.

Periods of maternity, paternity, parental leave or other protected absence shall not be treated as evidence of lower commitment or productivity, and shall be considered appropriately in the assessment of career progression.

Article 13. Pay equality

TRAILAB uses standard salary bands and shall maintain them as an important safeguard against arbitrary compensation differences.

The annual Gender Equality Monitoring Report will examine:

salary band;
professional level;
contract type;
working time;
additional paid responsibilities; and
other material compensation where applicable.

Any material unexplained gender-related difference identified between comparable positions shall be investigated and, where unjustified, corrected.

Because of TRAILAB's small workforce, detailed individual salary information will remain confidential.

Chapter 7. Sex, gender and intersectionality in research and innovation

Article 14. Mandatory relevance assessment

Integration of sex and gender analysis into research content is particularly relevant to TRAILAB's mission concerning trustworthy, accountable and socially responsible Artificial Intelligence.

TRAILAB will institutionalise considerations of sex, gender and intersectionality at the level of individual research projects.

Every new TRAILAB research project shall include, during project planning, an explicit assessment of whether sex and gender, as well as relevant intersectional factors, could materially affect:

the research question;
theoretical assumptions;
populations studied;
datasets;
data generation and sampling;
model development;
evaluation procedures;
system users;
affected persons or communities;
distribution of benefits and harms;
interpretation of results;
deployment context; or
other social, cultural, legal, or ethical impacts.

This assessment shall be integrated into TRAILAB's Standard Work Plan or equivalent project-planning documentation.

Relevance

TRAILAB does not assume that sex or gender is relevant to every research question. Where the project team determines that sex/gender analysis is not relevant, the project plan shall contain a brief reasoned justification.

Where it is relevant, the project shall specify how it will be incorporated into research design, analysis, evaluation or interpretation. The objective is to ensure that relevance is consciously assessed rather than implicitly assumed away, without artificially introducing gender variables into every project.

Project-specific considerations

Where relevant to a project, researchers should consider questions including, but not limited to:

whether training or evaluation data adequately represent relevant populations;
whether model performance differs by sex, gender or relevant intersecting characteristics;
whether proxies may reproduce gendered or intersectional inequalities;
whether system outputs produce different allocative or representational effects across groups;
whether assumptions embedded in labels, categories or benchmarks reproduce stereotypes;
whether interfaces or deployment conditions affect users differently;
whether uncertainty, error rates or failure modes vary across relevant groups;
whether affected communities should participate in research design or evaluation.

Collection of demographic characteristics shall not be undertaken merely because subgroup analysis is technically possible. Scientific relevance, proportionality, ethics, privacy and applicable data-protection law shall be considered.

Intersectionality

When scientifically relevant, project teams shall consider whether analysis restricted to gender alone could obscure important differences produced by the interaction between gender and characteristics such as disability, age, ethnicity or racialisation, socioeconomic circumstances, migration status or other contextually relevant factors.

Intersectional analysis should be methodologically justified and should avoid creating statistically unreliable conclusions from inadequately sized subgroups.

Chapter 8. Gender-based violence, sexual harassment and discriminatory conduct

Article 15. Prohibition of gender-based violence, sexual harassment and discriminatory conduct

TRAILAB prohibits sexual harassment, harassment on grounds of sex or gender, gender-based violence, discriminatory conduct and retaliation against persons who raise concerns in good faith.

These principles apply not only at TRAILAB premises but also to conduct connected with TRAILAB activities, including but not limited to:

online communications;
conferences and workshops;
research meetings;
work-related social events;
fieldwork and travel;
consortium and partner activities;
remote working environments.

Article 16. Prevention and response protocol for gender-based violence, sexual harassment and discriminatory conduct

Within six months of adoption of this GEP, TRAILAB shall adopt a dedicated procedure for prevention of and response to sexual harassment, gender-based harassment and gender-based violence.

The procedure shall establish:

accessible reporting channels;
confidentiality requirements;
safeguards against retaliation;
procedures for conflicts of interest;
impartial preliminary assessment and investigation;
reasonable procedural timeframes;
appropriate interim protective measures;
rights of all persons involved;
available support and referral options;
documentation requirements;
potential institutional consequences;
interaction with statutory, administrative or judicial procedures where applicable.

Monitoring

The annual Gender Equality Monitoring Report shall record, in strictly anonymised form where possible:

number and general category of complaints;
whether procedures were activated;
implementation of preventive measures;
completion of relevant training.

No public reporting requirement shall override confidentiality, privacy, procedural fairness or the safety of affected persons.

Article 17. Independent reporting route

No person shall be required to report alleged misconduct exclusively to someone who may be implicated in the complaint or have a significant conflict of interest.

TRAILAB shall therefore maintain at least two confidential reporting routes and establish procedures for the recusal and substitution of any person affected by a conflict of interest.

During the initial implementation of this Plan, the Board shall designate appropriate persons within the Association to receive sensitive reports.

Where a complaint requires formal investigation, TRAILAB may constitute an ad hoc Investigating Committee composed of persons without conflicts of interest, in accordance with the mechanisms established in its Statutes and the specific procedure governing harassment and gender-based violence.

TRAILAB shall prioritise the constitution of its Ethical Committee. Once constituted, the Committee's role in receiving, overseeing or advising on sensitive complaints shall be defined in the corresponding institutional protocol, subject to appropriate safeguards for independence, confidentiality and conflicts of interest.

The Gender Equality Officer shall not receive, assess or investigate a matter where doing so would compromise impartiality.

Chapter 9. Training and awareness

Article 18. Gender-equality training and awareness

Gender-equality training is a core element of this Plan. During the first year, TRAILAB shall provide introductory training on gender equality and on bias awareness to:

all Board members;
employees;
project and research leaders;
the Gender Equality Officer; and
all persons materially involved in recruitment and career decisions.

Training shall address, as appropriate:

gender equality and non-discrimination;
conscious and unconscious gender bias;
intersectionality;
inclusive recruitment and evaluation;
work-life balance and organisational culture;
prevention of harassment and gender-based violence;
integration of sex/gender analysis into research;
gender and intersectional issues relevant to AI research.

At least one refresher or specialised awareness activity shall be offered annually.

New Board members, employees, project leaders and persons undertaking recruitment responsibility shall receive appropriate introductory material or training within a reasonable period after assuming their responsibilities.

Specialist external trainers shall be used where TRAILAB does not possess the necessary internal expertise.

Chapter 10. Final provisions

Article 19. Communication

The current version of the GEP shall be:

publicly accessible on TRAILAB's website;
communicated internally after adoption;
provided or signposted to new employees and relevant collaborators;
forwarded at the constitution of new research-project leadership;
referred to in relevant institutional procedures.

Previous versions and public monitoring reports should remain accessible or otherwise appropriately archived to permit evidence of continuous implementation.

Article 20. Review and continuous improvement

This Plan is intended to be a living institutional instrument.

The Gender Equality Officer may propose amendments in response to:

monitoring results;
growth or structural changes in TRAILAB;
changes in employment arrangements;
new research activities;
identified equality problems;
changes in Spanish or European law;
modifications to Horizon Europe or successor-programme requirements;
developments in recognised good practice for gender equality in research.

Material revisions shall be approved by the Board and made publicly available.

At the end of the three-year period, TRAILAB will conduct a full evaluation examining:

implementation of each SMART action;
trends in representation;
recruitment and progression outcomes;
pay-equity findings;
work-life and organisational-culture indicators;
effectiveness of training;
integration of sex, gender and intersectionality into research;
functioning of harassment-prevention and reporting mechanisms;
adequacy of dedicated resources; and
priorities for the successor GEP.

The evaluation shall inform adoption of a new Gender Equality Plan.

Formal adoption

This Gender Equality Plan was approved by the Board of Directors of TRAILAB – Trustworthy and Reflective Artificial Intelligence Lab.