Nortegas LGTBI Equality Plan: What the New 2026 Collective Agreement Requires

Key data

Nortegas Group now has its LGTBI equality plan operational: as of June 3, 2026, the II Collective Agreement of the group includes as Annex VIII an equality and non-discrimination plan for LGTBI persons together with a protocol for action against harassment. The agreement was signed on December 2, 2025 between the company and the unions ELA, CC.OO. and UGT, and has been registered and published by the General Labor Directorate through a resolution of May 21, 2026.

This modification responds to the obligations established by Organic Law 4/2023 and Royal Decree 1026/2024 on LGTBI equality in employment, which require companies with more than 50 employees to have planned measures in this area.

What does this regulation establish?

The partial modification of the II Collective Agreement of Nortegas Group incorporates two differentiated instruments within the new Annex VIII:

• Equality and Non-Discrimination Plan for LGTBI persons: establishes concrete measures to guarantee equal treatment and non-discrimination on the grounds of sexual orientation, gender identity, gender expression, and family diversity in the group's work environment.
• Protocol for action against harassment: defines the procedure for action in situations of harassment in all its forms.

The protocol explicitly covers the following types of harassment:

The plan's validity coincides with that of the collective agreement itself, so it does not have an independent expiration date.

Economic and operational impact

This modification does not introduce direct salary costs, but it does have relevant operational implications for people management:

• Adaptation of internal procedures: the anti-harassment protocol must be known and applicable in all work environments, including remote work and digital environments.
• Extension to third parties: the obligation extends to interns and subcontracted or collaborative companies, which implies reviewing contracts and clauses with service providers.
• Training and internal communication: the effective implementation of the plan requires awareness and training actions for the entire workforce.
• Risk of non-compliance: failing to apply the protocol in response to a harassment complaint can result in corporate liability, both in the labor sphere and in the sanctioning sphere, under Organic Law 4/2023.

Who does it affect?

• All workers of the Nortegas Group, regardless of contract type (permanent, temporary, part-time...)
• Workers in remote work modality
• Workers operating in digital environments
• Interns linked to the group
• Personnel from subcontracted or collaborative companies providing services to the group

Practical example

A subcontracted company providing maintenance services for Nortegas Group has several workers deployed at the group's facilities. As of June 3, 2026, those workers fall under the umbrella of the anti-harassment protocol of Annex VIII of the collective agreement. If one of them suffers harassment on grounds of gender identity at a Nortegas workplace, the protocol is applicable and the main company has the obligation to activate the action procedure provided, regardless of whether the worker is employed by the subcontractor and not by Nortegas directly.

Similarly, an intern who carries out internships in the group—even though they do not have a formal employment relationship—is equally protected by the LGTBI equality plan and the anti-harassment protocol from the same date.

What should companies do now?

1. If you are Nortegas Group: verify that Annex VIII is formally incorporated into the collective agreement and that all HR managers know its content and procedures.
2. Communicate the protocol to the entire workforce: including remote workers and those in digital environments. Mere publication in the Official Gazette does not exempt the obligation of internal dissemination.
3. Review contracts with subcontractors: include clauses that guarantee knowledge and compliance with the protocol by external personnel operating in the group's facilities or projects.
4. Extend coverage to interns: ensure that internship programs expressly contemplate the application of the LGTBI equality plan and the anti-harassment protocol.
5. Plan internal training: design awareness actions on LGTBI equality and anti-harassment procedures for middle management and general workforce.
6. Review compliance with Royal Decree 1026/2024: if your company has more than 50 employees and does not yet have an LGTBI equality plan, this resolution is a clear signal that the Labor Inspectorate may require it.

Official source

Consult complete regulation in official source

Notice: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://www.boe.es/diario_boe/txt.php?id=BOE-A-2026-11927