GENDER EQUALITY PLAN

Double Break LTD (trading as Noverstock)

Version 1.0 · April 2026 · EIC Accelerator Open 2026

Prepared by: Lyubomir Slavilov, Founder & CEO

Contact: asen@doublebreak.eu · www.noverstock.com

EXECUTIVE STATEMENT

Double Break LTD was founded in December 2021 with a team built entirely on merit. Today, 5 of our 8 team members — including our CTO and 3 of 5 senior engineers — are women. This was not the result of a quota. It was the result of hiring the best people. This Gender Equality Plan formalizes what we already practice, and commits us to maintaining and strengthening these standards as we grow.

Lyubomir Slavilov — Founder & CEO, Double Break LTD

1. COMPANY PROFILE

1.1 About Double Break LTD (Noverstock)

Double Break LTD (trading as Noverstock) was founded in December 2021 in Varna, Bulgaria — a Horizon Europe Widening country. The company develops and operates an AI-driven commerce optimization engine for high-volume multichannel retailers across the European Union. Since inception, the company has invested €2.18M in R&D from founder capital alone, building and validating a technology now deployed with 13 enterprise clients across Bulgaria, Romania, Czech Republic, and Slovakia.

The company operates as a bootstrapped, founder-led technology company with 8 full-time team members. Double Break LTD has no external investors and has achieved self-sustaining commercial operations with €349,603 verified ARR in 2025.

1.2 Current Team Composition

Double Break LTD significantly exceeds EU technology sector gender balance benchmarks. The European technology sector average female participation is approximately 17–22%. Our team composition of 62.5% women, including 100% of the CTO role and 60% of senior engineering positions, represents a structural commitment to gender equality — not a target to be achieved, but a baseline to be maintained.

2. SCOPE AND LEGAL BASIS

2.1 Purpose of this GEP

This Gender Equality Plan (GEP) was developed for Double Break LTD in order to establish a formal framework for promoting and maintaining gender equality in employment, career development, compensation, decision-making, and organizational culture. The GEP is submitted as part of the EIC Accelerator Open 2026 application (NOVAOPT project) and is published publicly on the company website.

This GEP references and aligns with:

• European Commission Gender Equality Strategy 2020–2025
• Horizon Europe requirements for Gender Equality Plans (mandatory for legal entities from EU Member States and Associated Countries)
• Bulgarian National Strategy for Promoting Equality between Women and Men 2021–2030
• UN Women's Empowerment Principles
• EU Pay Transparency Directive (2023/970/EU)

2.2 Applicability

This GEP applies to all current and future employees, contractors, subcontractors, advisors, and volunteers engaged with Double Break LTD. It covers all stages of the employment and collaboration lifecycle: recruitment, onboarding, compensation, promotion, professional development, project assignment, and exit.

3. CURRENT SITUATION — ASSESSMENT

3.1 Strengths

• Team gender composition: 62.5% women (5 of 8 members) — industry-leading in the technology sector
• Leadership: The CTO position is held by a woman (Katerina Stankova). 3 of 5 Senior Engineer roles are held by women
• Equal pay policy: All team members at the same seniority level receive equivalent compensation regardless of gender
• Flexible working: The company operates fully remote-first, enabling equal access to work regardless of family obligations or location
• Merit-based recruitment: All hiring decisions are made based on technical competence and cultural fit, with no gender bias in the selection process
• Inclusive culture: The flat organizational structure ensures all team members — regardless of gender — have direct access to the founder and equal voice in technical decisions

3.2 Challenges and Gaps

• Founder/CEO and CPO roles are currently both held by men: as the company scales and adds leadership positions, active monitoring is required to maintain gender balance at the top
• No formal parental leave policy exists in writing — this is addressed as a target in this GEP
• No formal salary audit process is documented — this is addressed as a target in this GEP
• No external gender equality training has been conducted to date — this is addressed as a target in this GEP
• As the company grows and hires in DACH/Benelux markets, new recruitment processes must include explicit gender equality commitments

3.3 Key Data Points

4. OBJECTIVES AND MEASURES

Objective 1: Maintain Gender Balance as the Company Scales

Rationale

As Double Break LTD grows from 8 to 45+ team members by 2030 (as projected in the EIC grant plan), active measures are required to ensure that current gender balance is maintained — or improved — at all seniority levels, including in newly created leadership positions.

Measures

• All job postings will include explicit gender-neutral language and a diversity statement
• For every open senior or leadership position, the recruitment process will include at least one woman candidate in the final shortlist
• Annual gender composition review to be conducted each December, with results shared with the full team
• New DACH/Benelux sales hires and EU partnerships hires will be subject to the same gender balance targets
• Board/advisory gender composition to be monitored: at least 40% women in any advisory board formed

Targets

Objective 2: Equal Pay and Transparent Compensation

Rationale

While Double Break LTD currently applies equal pay at equivalent seniority levels, this policy is not formally documented. As the company grows and hires across multiple countries, a transparent compensation framework is required to prevent pay gaps from emerging.

Measures

• Develop and publish a written Compensation Framework by Q4 2026, with salary bands by role and seniority that apply equally regardless of gender, nationality, or location
• Conduct a formal pay equity audit annually, comparing compensation of women and men at equivalent roles
• All new employment contracts to include equal pay clause
• Salary bands to be shared with employees and candidates for senior roles

Targets

Objective 3: Work-Life Balance and Parental Support

Rationale

The company currently operates fully remote, which inherently supports work-life balance. However, no formal written policy exists for parental leave beyond Bulgarian statutory requirements. A written policy removes ambiguity and signals commitment.

Measures

• Formalize a written Parental Leave Policy by Q3 2026, applicable to all genders, covering primary and secondary caregivers
• Ensure that parental leave is not considered negatively in performance reviews or promotion decisions
• Offer flexible return-to-work arrangements for employees returning from parental leave
• Ensure all remote work tools and communication channels are equally accessible to team members with caregiving responsibilities

Targets

Objective 4: Awareness, Training and Inclusive Culture

Rationale

As the team grows internationally and the company engages with EU institutions through the EIC programme, it is important that all team members, partners, and contractors understand and actively uphold gender equality principles.

Measures

• Introduce the GEP to all current and new team members through a dedicated onboarding session
• Conduct at least one gender equality awareness session per year for all team members (online format)
• Include gender equality principles in all contractor and partnership agreements
• Ensure conference speaker selection for company-organized or company-sponsored events maintains gender balance (target: ≥40% women speakers)
• Apply gender-inclusive language in all internal and external communications

Targets

Objective 5: Integration of Gender Perspective in Research and Product Development

Rationale

As part of the EIC grant project (NOVAOPT), Double Break LTD will formalize its optimization algorithm as a publishable, cross-domain applicable computational framework. Ensuring that the research process and its outputs are designed with gender sensitivity — including avoiding algorithmic bias — is both a scientific and ethical requirement.

Measures

• Include gender dimension analysis in the formal algorithm specification phase (Phase 1, Months 1–8): assess whether the optimization engine's decision outputs could create or amplify gender-based biases in pricing, inventory allocation, or carrier selection
• Ensure that benchmark datasets used in Phase 1 are analyzed for potential gender-related biases in the underlying commerce data
• Include gender balance consideration in the selection of the EU academic partner for algorithm formalization
• Publish gender dimension analysis as part of the peer-reviewed publication (Phase 3)

Targets

5. MONITORING, REPORTING AND REVIEW

5.1 Monitoring Responsibility

The implementation and monitoring of this GEP is the responsibility of Lyubomir Slavilov (Founder & CEO) as primary GEP owner, and Katerina Stankova (CTO) as co-responsible for team-level implementation. Where external expertise is required for audit or training purposes, external consultants will be engaged.

5.2 Annual Review Process

The GEP will be reviewed annually each December, starting December 2026. The review will:

• Assess progress against all targets defined in Section 4
• Update gender composition data for the full team
• Report on pay equity audit results
• Review and update targets as the company grows
• Document any incidents, complaints, or challenges related to gender equality

5.3 Monitoring Indicators

6. REFERENCES AND LEGAL BASIS

1. European Commission Gender Equality Strategy 2020–2025
2. Bulgarian National Strategy for Promoting Equality between Women and Men 2021–2030
3. UN Women — Concepts and Definitions: Gender Equality
4. Horizon Europe Programme Guide — Requirements for Gender Equality Plans
5. EU Pay Transparency Directive (EU) 2023/970
6. EIC Accelerator Open 2026 — Work Programme

Lyubomir Slavilov — Founder & CEO, Double Break LTD

asen@doublebreak.eu · www.noverstock.com · January 2026