PRESS RELEASES
POLICIES FOR THE PREVENTION AND COMBAT OF VIOLENCE AND HARASSMENT AT WORK AND THE MANAGEMENT OF RELATED INTERNAL COMPLAINTS
The company has adopted the following policies to prevent and combat violence and harassment at work and to manage related internal complaints. Analytically:
1. Purpose of policies
The purpose of the policy is, on the one hand, to prevent and combat any form of discrimination based on personal characteristics and choices, as well as any violence and harassment that occurs during work, whether connected to it or resulting from it, and on the other hand, the management of relevant internal complaints. The employer is committed to supporting employees who have been exposed to or witnessed work-related violence.
2. Scope of the policies
The employer adopts the Policies as best practice across its range of activities for the Prevention and Combating and also the Management of internal complaints concerning all forms of violence and harassment, including violence and harassment based on gender and sexual harassment manifested in the course of the work, either connected with it or arising from it. The employer undertakes to operate in accordance with the rules of ethics and the applicable legislative and regulatory framework for labor protection, seeking to maintain high standards of professional and ethical behavior.
The persons subject to the Policies are employees and employees, regardless of their contractual status, project contract, independent services, salaried mandate, employed through third party service providers, persons attending training, trainees, volunteers, employees whose employment relationship has expire, job seekers, workers in the informal economy for incidents occurring in the context of their work.
The Policies are in place to prevent and combat and also manage internal reports of incidents of violence and harassment, including gender-based violence and harassment and sexual harassment that are caused in the course of work, whether related to it or arising out of it and manifested by:
- In the workplaces of the employer and in any other place where the employees attend in the context of their work.
- During their movements to and from the place of work, other movements, as well as during work-related events and social activities (company events, seminars, business trips, etc.).
- During work-related communications, including those made through information and communication technologies (email, sms, etc.).
3. Zero tolerance statement for discrimination, violence and harassment - risk assessment
The employer expresses its commitment to address and eliminate discrimination, violence and harassment in the workplace, with the aim of ensuring a working environment where respect for human dignity prevails and discrimination based on personal characteristics and choices will not be allowed .
It is expressly and unequivocally stated that any form of violence and harassment in the workplace is strictly prohibited and the employer undertakes to make every effort to deal with such incidents and eliminate them immediately, in order to ensure a safe working environment for its employees. Any form of violence, abusive behavior, psychological or physical abuse, intimidation, harassment, including sexual harassment against any employee will not be tolerated by the employer.
4. Definitions
4.1 Violence and harassment
By violence and harassment is meant the forms of behavior, acts, practices or threats thereof, which are intended, lead or may lead to physical, psychological, sexual or financial harm, whether they occur individually or repeatedly.
Harassment also means forms of behavior that have the purpose or effect of violating a person's dignity and creating an intimidating, hostile, humiliating, humiliating or aggressive environment, regardless of whether they constitute a form of discrimination, and include harassment based on gender or other grounds of discrimination.
Harassment prohibited by this Policy includes, but is not limited to:
- Verbal harassment, including e.g. abusive comments, insult or accusation.
- Physical harassment, including e.g. of physical interference with normal work or movement.
- Visual forms of harassment, e.g. posters, cartoons, cartoons, photographs or designs that are derogatory based on characteristics protected by law.
- Retaliation or intimidation for reporting or threatening to report any of the aforementioned forms of harassment or for cooperating with an investigation of a harassment incident.
4.2 Gender based harassment
Harassment due to gender means forms of behavior linked to a person's gender, which have the purpose or result of violating the dignity of that person and creating an intimidating, hostile, humiliating, humiliating or aggressive environment (Law 4808/21) . These forms of behavior include sexual harassment (Law 3896/2010) as well as forms of behavior linked to the person's sexual orientation, expression, identity or gender characteristics.
In particular, sexual harassment is defined as unwanted behavior of a sexual nature that includes unwanted sexual proposals, requests for sexual favors and any other unwanted physical or verbal act of a sexual nature. Such conduct may be expressed by a person of any gender and includes harassment of a person of any gender. For example, sexual harassment includes:
- Offering benefits (eg, promotion or salary increase) in exchange for sexual favors or creating an environment that promotes "sex" as a means of professional development in the workplace.
- Retaliating or threatening retaliation after rejecting sexual advances.
- Visual Conduct: obscene gestures, display of sexually offensive graphic materials in electronic and printed form (eg e-mail, voice mail, books, files, photographs, etc.), cartoons, posters or any material with obscene or sexual innuendo.
- Verbal behavior: derogatory comments, sexual innuendo, use of sexual "language" or sexual "jokes".
- Verbal sexual harassment or suggestions.
- Verbal abuse of a sexual nature: sexual comments about a person's body, use of sexually derogatory comments in describing a person, sexually suggestive or obscene comments in chat, letters, invitations, notes or other comments, epithets.
- Physical contact: touching, pinching, gestures of a sexual nature, hitting, grabbing, pushing, etc.
The above acts are indicative and do not constitute an exclusive list of prohibited acts. The employee or third party who engages in such prohibited conduct should and will bear full responsibility for their actions.
4.3 Discrimination
Discrimination, direct or indirect, in accordance with the provisions of Law 4443/2016 on the prohibition of discrimination in the field of employment, means the unfavorable treatment suffered by a person, for reasons of race, color, national or ethnic origin, genealogy, religious or other beliefs , disability or chronic condition, age, family or social status, sexual orientation, identity or gender characteristics.
4.4 Cyberbullying at work
Cyberbullying at work is defined as any form of aggressive behavior against an individual or group of individuals through online information and communication in the context of work.
5. Policy to prevent and combat incidents of violence and harassment
The employer complies with all the measures and obligations set out in Law 4808/2021 and implements the appropriate practices and procedures to prevent and combat any form of violence and harassment, including gender-based violence and harassment and sexual harassment.
In this context, the employer also ensures the information and awareness of the employees in order to perceive and recognize violence and harassment behaviors in a timely manner, as well as encouraging them to report them to the Reporting Person referred to in paragraph 2.
5.1 Assessing the risks of violence and harassment at work.
The employer identifies the relevant risks of violence and harassment, taking into account, among other things, any inherent risk arising from the nature of its activities, jobs, factors such as gender and age or other characteristics that constitute grounds for discrimination, as well as risks which concern special groups of workers, such as night workers, new hires, people with special needs and people with fixed-term contracts.
5.2 Measures to prevent, control, limit and address the risks of violence and harassment.
Measures and administrative practices to prevent and control the risks of violence and harassment include:
1. Encouragement to maintain a working environment where respect for human dignity, cooperation and mutual assistance are core values.2. Open communication with the management of the employer and direct supervisors and colleagues.
3. Procedure for managing reports / complaints within the employer's premises.
4. Ensuring that employees have the necessary training / information in order to perform their duties, especially in jobs that have a higher risk of incidents of violence and harassment.
5. Measures of a technical nature, such as installation of an emergency notification, improvement of lighting, etc.
6. Actions to raise employees' awareness of healthy behavior patterns such as avoiding addictions, other issues concerning vulnerable groups of employees.
7. Guidance and support for victims of violence and harassment or victims of domestic violence to reintegrate into the workplace.
8. Training of employees in the procedures for managing incidents of violence, under the responsibility of the employer.
9. Assessing on a regular basis the effectiveness of applied preventive measures and countermeasures and reviewing / updating the risk assessment and measures.
5.3 Actions to inform and raise employee awareness.
The employer provides the staff with information and information, depending on the case, on the risks of violence and harassment, as well as on the related prevention and protection measures, on the procedures that exist and on the possibilities given by law in case of such incidents.
In particular, the employer trains employees to recognize discrimination, violence and harassment at work and to provide the required support to its staff and colleagues. Indicative:
1. Organizes targeted staff meetings to discuss relevant issues to address potential risks in a timely manner.2. Conducts seminars with mental health specialists or counseling service providers, representatives of voluntary organizations, etc.
3. Encourages the participation of employee representatives and management executives in training programs and educational seminars on the recognition and management of the risks of violence and harassment at work.
The employer encourages its employees and any third parties associated with it (such as customers, suppliers, contractors) to report incidents of discrimination, violence and harassment in the workplace that come to their attention.
5.4 Information on the rights and obligations of employees and management.
The employer informs its employees that, in the event that a person is affected by an incident of violence and harassment during access to employment, during the employment relationship or even if the contract or employment relationship in the context of which the incident allegedly occurred or the conduct has ended, he has the right to:
1. Judicial protection.2. Appeal.
3. Submitting a complaint and application for a labor dispute to the Labor Inspectorate, within the framework of its legal powers,
4. Reporting to the Ombudsman, within the framework of his statutory powers.
5. Contact the SOS line at 15900.
6. Internal Complaint.
Furthermore, any person who is affected by an incident of violence and harassment against him has the right to leave the workplace for a reasonable time, without loss of wages or other adverse consequence, if in his reasonable belief there is an imminent serious danger to life, his health or safety. In this case, the person leaving must inform the employer in writing in advance, stating the incident of violence and harassment and the incidents that justify his belief that a serious risk to his life, health or safety is imminent. As long as the risk does not exist or has ceased to exist and the affected person refuses to return to the workplace, the employer may appeal to the Labor Inspectorate with a request to resolve the dispute.
In any case, when there is a report or complaint of such behavior within the employer, the affected person retains every right to appeal to any competent administrative and judicial Authority.
5.5 Concept and definition of Reference Person.
The employer's Reference Person means the person responsible for guiding and informing employees about the prevention and treatment of specific incidents of violence and harassment at work.
The Whistleblower's role is informational and consists of guiding and informing employees, regardless of whether or not they come to them about an incident or complaint about an incident of violence and harassment. Employees' access to the Reporting Person is easy and immediate and for this purpose the means / channels of communication with him are provided.
It is the obligation of the Reporting Person, but also of all persons/parties and recipients involved in an incident, to ensure the protection of Personal Data, which may come to their knowledge in any way during the exercise of their roles and duties.
5.6 Employment protection and support for working victims of domestic violence.
The employer takes measures that demonstrate in practice its social responsibility towards the phenomenon of domestic violence, such as employment protection, the provision of special leave or flexible work arrangements at the request of the employee victim of domestic violence, with the aim of supporting him in maintaining his work and in his smooth reintegration after such incidents, especially in cases where there are minor children or children with disabilities or serious illnesses.
6. Related internal complaints management policy
6.1 Communication channels - Competent persons
Every employee who experiences an incident of violence against them has the right, if they wish, to contact the Reporting Person and report the incident and also to be informed of their rights, as well as to be informed of all the possibilities and support available to them provided, both by the employer's Policies and by applicable legislation.
In any case where any employee becomes the recipient of violent or harassing behavior in the workplace or becomes aware of such behavior towards a third employee within the work environment, they have the right to immediately make a formal complaint to the employer's Contact Person.
The Reporting Person has the obligation to immediately inform the head of the employer's Human Resources Department of any incident of violence or harassment in the workplace so that he can take the appropriate management and investigation actions, in accordance with the employer's Policies and the provisions of this legislation.
The persons who submit reports / complaints will be informed immediately by the Reporting Person about the receipt of the report / complaint as well as, at regular intervals, about the course of its examination.
6.2 Investigation of complaints
The head of the employer's Human Resources Department is obliged to immediately and thoroughly investigate any relevant report or complaint, taking into account all the data that will be collected during its action, with the aim of reaching reasonable conclusions as to whether an incident of violence or harassment took place within the workplace, demonstrating the employer's zero tolerance for violence and harassment so that legal sanctions are imposed.
When investigating the report / complaint, the persons authorized by the employer must act impartially and confidentially.
In the event that, from the investigation to be conducted, it emerges that the complaint was ultimately malicious and no incident of violence or harassment took place, the motives of the malicious complaint will be investigated in order to impose the corresponding sanctions, in accordance with the applicable legislation.
6.3 Prohibition of retaliation and further victimization at the expense of the affected person.
Termination or in any way the termination of the legal relationship on which the employment is based, as well as any other adverse treatment of the affected person, is prohibited and invalid, as long as it constitutes retaliatory behavior or a countermeasure for incidents of violence and harassment.
It is expressly pointed out that retaliatory actions (retaliation) against the person of the complainant are strictly prohibited and the prescribed disciplinary penalties will be imposed, in accordance with the current legislation.
6.4 Consequences of finding violations.
In the event of a violation of the prohibition of violence and harassment, the employer is obliged to take the necessary appropriate and proportionate measures on a case-by-case basis at the expense of the person complained of, in order to prevent and prevent a similar incident or behavior from recurring.
These measures may include recommending compliance, changing the position, time, place or method of providing work, or terminating the employment or partnership relationship, subject to the prohibition of abuse of rights.
In addition, the employer may apply the disciplinary provisions of the Staff Regulations, if moral damage is caused to the employee who is affected by the violation of the prohibition of violence and harassment and/or to the employer.
In any case, the violator may also be subject to criminal or civil liability, according to applicable law.
6.5 Cooperation and provision of all relevant information to the competent authorities, if requested.
The employer is obliged to cooperate with every competent administrative and judicial authority, to which it will provide assistance and access in any way or means and will disclose any information requested from them about any incidents of violence and harassment in the workplace.
7. Confidentiality & privacy compliance
During the process of investigating any report/complaint and dealing with incidents of violence and harassment at work, the terms of confidentiality and confidentiality will be strictly observed both in the person of the complainant and in the person of the person complained of.
Furthermore, strict confidentiality will be maintained regarding the incident and the content of the report/complaint, as well as any information that could lead to the identification of those involved.
8. Protection of personal data
In the context of the above Policies, the employer processes personal data in accordance with Law 4808/2021 applying the current legislation on the protection of personal data and the Policy on the Protection of Personal Data of Employees.
9. Final provisions
The employer undertakes to monitor the requirements of the regulatory framework and to proceed, if necessary, to amend the above Policies.
The head of the employer's Human Resources Department is responsible for the implementation of the above Policies, as well as for suggesting the necessary modifications to improve the measures to strengthen the protection of victims of violence and harassment at work.
The above Policies come into effect immediately after their approval by the employer's board of directors, while the full text is permanently posted in the notice area and on the employer's website.
