POLICY AGAINST VIOLENCE
AND HARASSMENT
AT WORK
- The Company complies with all measures and obligations regarding the implementation of the provisions of Part II of Law 4808/2021 on the prevention and tackling of all forms of violence and harassment.
- The purpose of this policy is to create and establish a working environment that respects, promotes, and ensures human dignity and the right of every person to a world of work free from violence and harassment. The Company declares that it recognizes and respects the right of every employee to a work environment free from violence and harassment and that it does not tolerate any such behavior, in any form and by any person. Every measure is taken to minimize the risks of violence and harassment at work, and a commitment is made to provide a work environment free from violence, bullying, and sexual harassment among employees, between employees and management, as well as between employees and third parties.
- This policy is adopted in accordance with Articles 9 and 10 of Law 4808/2021 and the implementing regulatory legislation, and covers the persons referred to in paragraph 1 of Article 3 of Law 4808/2021. 4808/2021.
A. Prevention and Combating of Violence and Harassment at Work
a) Assessment of the risks of violence and harassment at work.
The Company assesses that risks of violence and harassment may arise under the following circumstances:
– Interaction with customers/suppliers/the public: Employees, with the exception of reception staff, do not come into direct contact with third parties. To enter other areas of the business, third parties must provide their details at the reception and be specifically invited by an employee. Regarding reception staff, they face an increased risk from third parties compared to other personnel; however, this risk is drastically limited by the existence of a surveillance system at the entrance.
– Working in isolated areas: Employees are mostly located in common workspaces or in offices with transparent glass walls.
– Working during non-social hours: The majority of the Company’s employees work during social hours (indicatively from 09:00 or 10:00 AM to approximately 07:00 PM at the latest), when daylight and the number of employees on-site provide security. An increased risk arises for employees working during dark hours or when most of their colleagues have already departed/have not yet arrived; however, this is significantly limited by 24-hour surveillance of the entrance and outdoor areas, as well as the guarding of the workplace and the indoor parking area during night hours until the first employees arrive in the morning.
– Risks during commuting to and from work: The vast majority of employees work during social hours and commute to work by private vehicle. Both open parking space around the business building and indoor, electronically monitored parking space are provided, resulting in the minimization of risk.
– Access to safe sanitary facilities: In the business premises, there are permanent sanitary facilities (toilets) on every floor, separate for men and women, with easy access and located in non-isolated areas.
b) Measures to prevent, control, limit, and address these risks, as well as to monitor such incidents or forms of behavior.
– The Company regularly provides training programs to staff, supervisors, and managers. These training programs are evidence-based and demonstrate previous social impacts on reducing harassment.
– There is an open channel of communication between the Human Resources department and the employees, so that their suggestions for improving working conditions regarding violence and harassment can be heard.
c) Information and awareness-raising actions for staff
– Information is provided to staff regarding their rights in cases of violence and harassment at work.
– This Company policy is posted in prominent places within the workplace and is sent via email to the staff.
– Senior management assures staff that the Company demonstrates zero tolerance for acts of violence and harassment at work.
d) Information on the rights and obligations of employees and the employer, as well as persons exercising managerial authority or representing the employer, to the extent of their responsibility, in the event of an occurrence, report, or complaint of such incidents, and the relevant procedure.
Employees and persons exercising managerial authority or representing the Company are obliged to refrain from any violent or harassing behavior.
In the event that an employee is the recipient of such behavior, they are entitled to report it to the competent persons designated by the employer for the receipt and investigation of complaints. They also have the right to request assistance and access to competent services, administrative or judicial authorities, including the Labor Inspectorate, the Public Prosecutor’s Office, or the Police. Furthermore, they are entitled to request that protective measures be taken for them during the investigation of the incident.
The Company, as well as persons exercising managerial authority or representing the Company, are obliged to receive, investigate, and manage every complaint or relevant report with confidentiality and in a manner that respects human dignity, demonstrating zero tolerance. They must provide assistance and access to any competent public, administrative, or judicial authority during the investigation of such an incident if requested, and provide employees with information regarding potential risks of violence and harassment in the workplace and the relevant prevention and protection measures.
e) Designation of a reference person (“liaison”) for guiding and informing employees regarding the prevention and tackling of violence and harassment at work.
The Head of the Human Resources Department is designated as the employees’ “liaison.” Employees may contact the aforementioned person for guidance and information regarding the prevention and tackling of violence and harassment at work, as well as to submit relevant complaints.
f) Protection of employment and support for employees who are victims of domestic violence, as far as possible, by any appropriate means or reasonable accommodation.
Employees who are concerned about potential risks of domestic violence in the workplace and employees who have restraining orders or protection against a partner or former partner are encouraged to contact the “liaison” to develop a practical safety plan. Examples include being assigned a specific parking space closer to the Company entrance or, to the extent possible, differentiating their work duties for a specific period of time.
B. Procedure for Receiving and Investigating Complaints
a) Communication channels – competent persons
The Head of the Human Resources Department is responsible for the initial receipt and examination of complaints. Should it be deemed necessary to report to the competent authorities, the complaint will also be disclosed to the Company’s Legal Department, adhering to the rules for the protection of confidentiality and the personal data of both the victims and the accused.
b) Investigation and examination of complaints with impartiality and protection of confidentiality and personal data of victims and the accused.
Every employee complaint will be examined and investigated with impartiality, and the confidentiality and personal data of the complainants will not be violated.
In the event that disclosure of (certain) details of the complaint or the identity of the complainant is necessary, they will be informed and their approval will be requested. However, if the complaint involves the commission of crimes prosecuted ex officio (automatically by the state), it may be forwarded to the competent authorities without the victim’s prior approval, although the victim must be compulsorily notified of such transfer.
c) Prohibition of retaliation against the aggrieved person
The Company explicitly prohibits retaliation against the aggrieved person. Specifically, the termination or dissolution of the legal relationship underlying employment in any way, as well as any other adverse treatment of the victim, is prohibited and void if it constitutes retaliatory behavior or a countermeasure for an incident of violence and harassment.
d) Description of consequences upon finding of violations
Upon the finding of violations, the Company shall take the necessary, appropriate, and proportionate measures on a case-by-case basis against the accused, in order to prevent and ensure the non-recurrence of a similar incident or behavior. These measures may include a compliance recommendation, a change of position, working hours, place or mode of work, or the termination of the employment or cooperation relationship, without prejudice to the prohibition of the abuse of rights under Article 281 of the Civil Code (CC). Additionally, disciplinary proceedings may be initiated in parallel as follows:
Disciplinary authority is exercised by the CEO, the General Manager, or the Manager of each department in which the person under disciplinary review is placed. For disciplinary offenses, the following disciplinary penalties are imposed at the discretion of the aforementioned authorized persons:
- Oral or written warning.
- Written reprimand.
- Mandatory suspension – temporary discharge from work for a period of one day up to one month. An employee serving a temporary suspension is not entitled to work and shall be deprived of their total remuneration.
All penalties are recorded in the employee’s personal file.
At the same time, the aggrieved person has the right to leave the workplace for a reasonable period, following written notification to the employer, without loss of salary or other adverse consequence, provided that in their reasonable belief there is an imminent serious risk to their life, health, or safety. This applies particularly when the employer is the perpetrator of such behavior, or when the employer fails to take the necessary appropriate measures to restore labor peace, or when such measures are insufficient to stop the behavior of violence and harassment.
e) Cooperation and provision of all relevant information to the competent authorities, upon request.
If the incident has been reported to the competent authorities, the Company shall cooperate with them whenever requested and shall provide all relevant information without delay.