Violence and Harassment Report Form

POLICY:

1) FOR THE PREVENTION AND COMBATING OF VIOLENCE AND HARASSMENT

2) FOR THE MANAGEMENT OF INTERNAL COMPLAINTS REGARDING INCIDENTS OF VIOLENCE AND HARASSMENT

POLICY CONTENT

A. PREAMBLE

Article 1: Policy statement

Article 2: Policy content

Article 3: Policy objectives

B. PART ONE: GENERAL PROVISIONS

Article 1: Scope of application

Article 2: Prohibition of violence and harassment in the workplace

Article 3: Key terms and definitions

Article 4: Contexts in which prohibited behaviors of violence and harassment may occur

Article 5: Risk assessment for violence and harassment in the workplace

Article 6: Measures for the prevention, control, limitation, and handling of violent and harassing behaviors

Article 7: Actions for informing and raising awareness among staff and collaborators

Article 8: Rights of affected individuals in cases of violence and harassment

Article 9: Obligations of employees and others engaged in work

Article 10: Obligations of the company in cases of violence and harassment

Article 11: Prohibition of retaliation

Article 12: Victims of domestic violence

Article 13: Reporting contact – liaison person

C. PART TWO: MANAGEMENT OF INTERNAL COMPLAINTS

Article 1: Internal complaints handling policy

Article 2: Purpose and key principles of the Policy

Article 3: Subject of complaints

Article 4: Establishment of an independent Three-Member Committee

Article 5: Complaint submission procedure

Article 6: Complaint handling

Article 7: Measures taken
Article 8: Confidentiality, privacy, protection of personal data, impartiality, and objectivity

Article 9: Prohibition of retaliation

Article 10: Cooperation with competent authorities

Article 11: Governmental and independent bodies for filing complaints

Article 12: Personal Data

D. FINAL PROVISIONS

Article 1: Fraudulent or Malicious Complaints

Article 2: Posting of this policy

A. PREAMBLE

1. Policy Statement

The company under the name “EFARMOGES AYTOMATISMOY ETAIREIA PERIORISMENIS EYTHYNIS” and the distinctive title “TECHNOR ENGINEERING E.P.E.” (hereinafter referred to as the “company”) adheres to all measures and obligations concerning the implementation of the provisions of Part II of Law 4808/2021 for the prevention and addressing of all forms of violence and harassment, including gender-based violence and sexual harassment.

Furthermore, the company declares that it acknowledges and respects every employee’s right to a work environment free from violence and harassment and reaffirms its commitment to eliminating such behaviors due to its zero-tolerance policy towards such conduct of any form and by any person. It is committed to creating and maintaining a workplace environment in which respect for human dignity is upheld.

Lastly, it considers any behavior constituting harassment or sexual harassment as unacceptable and intolerable and commits to fully protecting the dignity of the individual and ensuring respect for each person’s personality. Equal opportunity policies are applied to all employees, with full respect for human rights.

2. Policy Content

This policy is adopted in accordance with Articles 9 and 10 of Law 4808/2021 and its implementing regulatory legislation. It applies to the individuals referred to in paragraph 1 of Article 3 of Law 4808/2021.

It includes the assessment of risks related to violence and harassment, measures for the prevention, control, limitation, and handling of these risks, and procedures for monitoring such incidents or behavioral patterns. It also includes actions to inform and raise awareness among staff, the rights and obligations of employees and the company, and those who exercise managerial authority or represent the company, to the extent of their responsibility in the event of occurrence, reporting, or filing of complaints regarding such incidents.

Furthermore, it details the appointment of a designated person (“liaison”) within the company, responsible for guiding and informing employees about prevention and handling of such incidents at work, protection of employment, and support for employees who are victims of domestic violence, through all appropriate means or reasonable accommodations.

The policy also outlines the process for managing internal complaints regarding the aforementioned incidents, safe and easily accessible channels for submitting complaints, and the identification of responsible individuals within the company for receiving, reviewing complaints, informing complainants, investigating, and examining complaints with impartiality, while protecting confidentiality and the personal data of both victims and the accused.

It explicitly prohibits retaliation and further victimization of the affected individual and describes the consequences of confirmed violations, as well as the collaboration with and provision of information to competent authorities, if requested.
3. -Objectives of the Policy

The objectives of this policy are:

1. The creation and establishment of a work environment that respects, promotes, and ensures human dignity and the right of every individual to a world of work free from violence and harassment.

2.The establishment of a coherent and modern framework for the prevention, management, and combatting of behaviors of violence and harassment, which will contribute to the creation of a workplace that respects, promotes, and ensures the right of every individual to a world of work free from violence and harassment, and more specifically:

3.The informing of the company’s employees regarding:

a) the concepts of “harassment” and “sexual harassment”,

b) the protection provided by the applicable legislation against behaviors that may constitute sexual harassment or harassment,

c) their rights in the event they are subjected to harassment or sexual harassment, and

d) the actions they should take when they believe they are victims of harassment or sexual harassment.

The promotion of employee education and training regarding the importance of preventing, addressing, and combatting harassment or sexual harassment.

The encouragement of employees to participate in and contribute to the prevention and handling of harassment and sexual harassment in the workplace, and to the formation of a friendly work environment for all employees, regardless of gender or sexual orientation.

The provision of immediate protection to any employee who believes they are subjected to harassment or sexual harassment, or who has experienced harassment or sexual harassment, as well as protection from potential retaliatory actions against them due to resisting harassment or sexual harassment or filing a complaint about harassment or sexual harassment.
B. PART ONE: GENERAL PROVISIONS

1. Scope of Application:

This policy applies to all employees and individuals working for the company, regardless of their contractual status, including those working under a project contract, independent service providers, those under salaried mandates, individuals employed through third-party service providers, as well as individuals undergoing training, including interns and apprentices, volunteers, former employees whose employment relationship has ended, and individuals applying for employment.

2. Prohibition of Violence and Harassment in the Workplace:

Any form of violence and harassment is strictly prohibited, whether it occurs during the course of work, is related to it, or arises from it. This includes violence and harassment based on gender and sexual harassment.

3. Key Terms and Definitions:

For the purposes of this section:

a) Definition of “violence and harassment”:

“Violence and harassment” refers to behaviors, acts, practices, or threats thereof, that aim at, lead to, or are likely to lead to physical, psychological, sexual, or economic harm, whether they occur as isolated incidents or repeatedly.

b) Definition of “harassment”:

“Harassment” refers to behaviors that have the purpose or effect of violating a person’s dignity and of creating an intimidating, hostile, degrading, humiliating, or offensive environment. This applies regardless of whether such behavior constitutes a form of discrimination, and includes harassment based on gender or other grounds of discrimination.

c) Definition of “gender-based harassment”:

“Gender-based harassment” refers to behaviors related to a person’s gender that have the purpose or effect of violating that person’s dignity and creating an intimidating, hostile, degrading, humiliating, or offensive environment, as per Article 2 of Law 3896/2010 and paragraph 2 of Article 2 of Law 4443/2016. These behaviors include sexual harassment as defined in Law 3896/2010, as well as behaviors linked to sexual orientation, gender expression, gender identity, or gender characteristics.
d) Definition of “sexual harassment”:

“Sexual harassment” refers to any form of unwelcome verbal, psychological, or physical behavior of a sexual nature, which results in the violation of a person’s dignity, especially through the creation of an intimidating, hostile, degrading, humiliating, or offensive environment around them. This definition also includes behaviors related to the individual’s sexual orientation, gender expression, gender identity, or gender characteristics.

4. Contexts in Which Prohibited Behaviors of Violence and Harassment Occur

The aforementioned forms of violence and harassment affecting individuals covered by this policy may take place, in particular:

(a) in the workplace, including both public and private spaces and any location where the employee provides work, receives remuneration, takes breaks—especially for rest or meals—in areas for personal hygiene and care, locker rooms, or accommodations provided by the company,

(b) during commuting to and from work, other work-related travel, training sessions, as well as events and social activities related to work, and

(c) during work-related communications, including those conducted via information and communication technologies.

5. Risk Assessment of Violence and Harassment in the Workplace

During the course of work, risks may arise that are associated with violence, harassment, and discrimination of any kind and form (as defined in this policy). These risks are assessed by taking into account, among other factors, the inherent dangers related to the nature of the company’s activity, the job position, as well as characteristics such as gender, age, or other traits that may be grounds for discrimination. Additional attention is given to risks affecting specific groups of employees (e.g., night workers, newly hired personnel). These risks are assessed within the Occupational Risk Assessment Study that has been prepared and is currently in force.

6. Measures for the Prevention, Control, Limitation, and Management of Behaviors of Violence, Harassment, Discrimination, and Breaches of Equal Opportunity

6.1 The company takes all necessary preventive measures to avoid occurrences of violence and harassment. It has informed and sensitized its staff and collaborators by all appropriate means, implemented monitoring and control procedures for such behaviors, and established accessible and simple communication channels between victims and the company itself. These efforts are guided by a zero-tolerance approach to violence and harassment, confidentiality, respect for human dignity, and the thorough investigation of complaints or reports of such conduct.

Through this policy, the company reaffirms its commitment to prevention and elimination of such incidents, aiming to ensure a work environment free from violence and harassment for all employees.
6.2 The company and specifically those in managerial positions or representing it, take measures and administrative practices for the prevention and control of the above risks. Specifically, they are obliged to:

a) Receive, investigate, and manage any complaint or related report of violence, harassment, discrimination, or violations of equal opportunity, showing zero tolerance for such incidents. They must handle these matters confidentially and in a way that respects human dignity, and must not obstruct the receipt, investigation, or management of complaints or reports of such behavior.

b) Provide assistance and access to any competent public, administrative, or judicial authority during the investigation of such incidents or behaviors, if requested by them.

c) Provide employees with information regarding the potential risks of violence and harassment in the workplace, as well as the related preventive and protective measures, including the obligations and rights of both employees and employers concerning such incidents.

d) Post information in the workplace and make it accessible regarding the procedures available at the company level for reporting and handling such forms of behavior, as well as contact details for the relevant administrative and judicial authorities according to the applicable regulations.

e) Continuously inform and sensitize the staff and collaborators with all appropriate means about the company’s zero tolerance for incidents of violence, harassment, discrimination, and violations of equal opportunity, the rights of victims, and the simple but safe procedures to follow if employees or third-party collaborators become victims of violence, harassment, or discrimination, or if they become aware of such incidents occurring during work.

f) Ensure that all employees:

• Understand the company’s commitment to preventing harassment and oppression.

• Understand their responsibilities and role in this process.

• Are informed and know how to seek advice and guidance.

• Know how to report their complaints and feel confident that their issue will be addressed promptly.

g) Continuously cooperate with the occupational physician and comply with their recommendations regarding the improvement of measures taken to prevent and combat incidents of violence, harassment, and discrimination, especially in the context of assessing psychosocial risks.

Πέραν των προαναφερομένων, η εταιρία:

η) The company has designated a contact person who serves as a liaison between itself and the individuals within the scope of this policy for matters related to violations of the prohibition of violence, harassment, discrimination, and equal opportunity. This person has been granted the authority to act with independence and objectivity, and their actions are regularly monitored by the company’s management for transparency, objectivity, immediacy, and speed, as well as for the accuracy and completeness of the guidance and directions provided.

θ) The company has established an independent three-member committee, responsible for reviewing complaints and reports of incidents involving violence, harassment, discrimination, and violations of equal opportunities.

ι) The company has introduced simple, direct, quick, and secure procedures for investigating any complaints related to violence, harassment, violation of equal opportunities, and discrimination violations, with the primary focus being respect for human dignity and confidentiality.

ια) The company has implemented measures to protect individuals who make complaints or reports about incidents falling within the scope of this policy.

ιβ) The company has introduced strict sanctions for those who engage in actions that constitute violence, harassment, violation of equal opportunities, and discrimination violations.

ιγ) The company provides assistance and access to any competent public, administrative, or judicial authority during the investigation of such incidents or behaviors, should they request it.

ιδ) The company applies the recommendations of health and safety inspectors and facilitates their work within the organization during inspections.

ιε) The company provides training for employees on the procedures for managing incidents of violence.

ιστ) The company regularly evaluates the effectiveness of the preventive measures and remedial actions implemented and revises/updates the risk assessments and measures as necessary.

ιζ) The company guides and supports victims of violence and harassment or victims of domestic violence in reintegrating into the workplace.

ιη) The company takes actions to raise employee awareness of healthy behavioral patterns (e.g., avoiding addictions), as well as issues related to vulnerable categories of employees.

ιθ) The company provides access, upon request of the affected individual, to psychological counseling support. 7. Actions for informing and raising awareness of staff and collaborators:

In order to inform and raise awareness among staff, the company is committed to providing information and details in accessible formats, depending on the case, regarding the risks of violence and harassment, as well as the related prevention and protection measures, the procedures in place at the company level, and the legal provisions available in case of such incidents. More specifically, in the context of raising awareness among staff, the company:

a) At regular intervals not exceeding three (3) months, trains management and directors to recognize violence and sexual harassment in the workplace, so they can support victims of such behaviors.

b) Organizes regular training sessions for staff to ensure that everyone is aware of the internal policies and procedures and knows where to turn in case they experience behavior that falls under the definition of violence or sexual harassment.

c) Provides staff and collaborators with special documents containing clear instructions on the steps to take if they fall victim to violence, harassment, discrimination, or violation of equal opportunities, or if they witness such incidents among others at work. These documents include, among other things, the contact details of the person appointed by the company as the liaison between the company and the victims, who will guide them, confidentially and respectfully, through every step, as well as the contact details of all public, administrative, and judicial authorities they can turn to at any time.

d) Organizes targeted staff meetings to discuss related issues and ensure the early identification and management of potential risks.

e) Holds seminars with mental health specialists or providers of counseling services, representatives of voluntary organizations, etc.

f) Encourages the participation of employee representatives and management staff in training programs and educational seminars related to recognizing and managing the risks of violence and harassment in the workplace.

g) Finally, the company has posted special informational documents in visible areas of the workplace about the possibility of reporting the above-mentioned behaviors, the contact details of the liaison person between the company and the victims, and the contact details of the relevant administrative and judicial authorities.
8. Rights of victims in case of incidents of violence and harassment, violation of equal opportunities, and discrimination prohibition.

Any person working or employed by the company who is affected by an incident of violence and harassment against them, even if the relationship under which the incident or behavior occurred has ended, has the right to:

a) Judicial protection before both criminal and civil courts.

b) Appeal to the relevant Labor Inspectorate and the Ombudsman as bodies for promoting and overseeing the principle of equal treatment, according to the law.

c) Submit a complaint within the company to the designated person for this purpose, so that all procedures foreseen in this policy are initiated promptly. In case of inability to locate the designated person, or if there is any delay, subjectivity, refusal to deal with the incident, or any other behavior by the designated person, the alleged victim may send an email to the company’s management.

d) In any case, when a report of such behavior is made within the company, the affected person retains the right to appeal to any competent authority.

Any person who experiences an incident of violence and harassment against them has the right to leave the workplace for a reasonable period of time, without losing their salary or facing any other negative consequences, if, in their reasonable belief, there is an imminent serious threat to their life, health, or safety, especially if a company representative is the perpetrator of such behavior or if the company fails to take appropriate measures to restore workplace peace, or if those measures are insufficient to stop the behavior of violence and harassment.

The person leaving the workplace is required to inform the company in writing in advance, stating the incident of violence and harassment and the events that justify their belief that there is an imminent serious danger to their life, health, or safety.

If the danger no longer exists or has ceased, and the person refuses to return to the workplace, the company may appeal to the Labor Inspectorate to resolve the dispute.
9. Obligations of employees or other persons employed under a different relationship:

Employees or persons employed under a different relationship are obligated not to violate the prohibition of violence and harassment. In the opposite case, the company is obliged to take the necessary appropriate and, where applicable, measures against the accused, in order to prevent and avoid the recurrence of similar incidents or behaviors.

These measures may include:

activation of the disciplinary code for employees,

issuing a compliance warning,

changing position,

changing working hours,

changing the location or method of work provision,

termination of the employment or collaboration relationship.

10. Obligations of the company in case of incidents of violence, harassment, discrimination, and violation of equal opportunities.

In the event of a complaint or report of incidents of violence, harassment, discrimination, and violation of equal opportunities, the company is obliged to take all appropriate and legal measures to protect the person who is alleged to be the victim of such behaviors, both in terms of preventing the continuation of these behaviors and ensuring the prohibition of retaliation and further victimization of the affected person.

If there is a probable imminent danger to the life, health, or safety of an employee due to an incident or behavior of violence and harassment, the company will take one or more of the following temporary measures, for a duration until it is proven that the imminent danger no longer exists:

a) removal of the complainant from the workplace with full payment of their wages,

b) changing the shift of the staff,

c) transferring the accused to another department of work,

d) assigning the accused to teleworking or remote work depending on the nature of their duties.

Additionally, if it is established, after following the legal procedure, that an employee or person employed under a different relationship has violated the prohibition of violence and harassment, the company is obliged to take the necessary appropriate and, where applicable, measures against the accused in order to prevent and avoid the recurrence of similar incidents or behaviors. Specifically, the disciplinary procedure provided for in the Regulation will be activated, with the corresponding disciplinary penalties. Beyond these, the appropriate measures may include a compliance warning, changing position, working hours, place or method of work provision, or the termination of the employment or collaboration relationship, as set out below.
11. Prohibition of Retaliation:

Any termination or dissolution of the legal relationship underlying employment, as well as any other adverse treatment of individuals covered by these policies, is prohibited and considered null and void if it constitutes retaliatory behavior or reprisal within the meaning of Article 14 of Law 3896/2010, in connection with incidents of violence and harassment as defined in this policy.

Specifically, any adverse treatment is considered retaliatory behavior or a reprisal when it occurs: a) due to gender or family status,

b) due to the employee’s refusal to submit to sexual or other harassment,

c) as a reaction by the employer or a person responsible for vocational training to a protest, complaint, testimony, or any other action taken by an employee, trainee, or their representative, within the workplace or training environment, or before a court or relevant authority, concerning the application of the provisions of this policy.

12. Victims of Domestic Violence:

The company protects the employment and supports employees who are victims of domestic violence by using all appropriate means or by providing reasonable accommodations where possible (e.g. granting unpaid leave upon request, adjusting work shifts, reducing working hours, etc.). Specifically, the company ensures the adjustment of working conditions in order to maintain a stable and supportive work environment for victims of domestic violence.
13. Reporting Person (Point of Contact):

The company designates a reporting person (“liaison”), who is a member of the Human Resources Department. This individual is appointed by decision of the General Assembly of the partners (see Annex A of this regulation). All individuals falling within the scope of this policy may contact the reporting person:

a) To receive guidance and information regarding the prevention and handling of violence, harassment, discrimination, and breaches of equal opportunities in the workplace, including all necessary information about their rights (both within the company and before judicial or administrative authorities), as well as the obligations of the company.

b) As the first point of contact for anyone who believes they have experienced an incident of violence, harassment, discrimination, or violation of equal opportunities, in accordance with the procedure outlined in this policy.

2.The reporting person is required to act promptly, independently, objectively, and confidentially. They are subject to regular evaluations by the company’s management to ensure transparency, objectivity, responsiveness, promptness, and the confidentiality with which they handle matters, as well as the accuracy and completeness of the guidance and directions they provide. The reporting person is strictly prohibited from disclosing any information regarding any incident to third parties who are not involved in the procedures set out in this policy.

3.In all cases, the reporting person is obligated to protect Personal Data (PD) that may come to their attention while performing their duties.
C. PART TWO: HANDLING OF INTERNAL COMPLAINTS

1. Policy for Managing Internal Complaints

The handling of internal complaints regarding incidents of violence and harassment is carried out in a manner that safeguards the victim’s dignity and respects human dignity overall. The company has established clear procedures for addressing harassment and sexual harassment. These procedures ensure the resolution of such issues in a prompt and effective manner. The investigation and review of complaints are conducted impartially, with the protection of confidentiality and the personal data of both victims and the accused.

2. Purpose and Key Principles of the Policy

2.1. This Policy sets out the principles and operational framework under which the company receives, processes, and investigates both signed and anonymous reports/complaints about incidents of violence and harassment. To serve this fundamental purpose, the Policy aims to establish a reliable mechanism for:

(a) supporting and protecting individuals who, in good faith, submit reports or complaints about matters they reasonably believe to constitute incidents of violence and harassment within the company, from malicious accusations, and

(b) effectively managing such reports and complaints, ensuring that they are taken seriously and remain confidential to the extent that this does not conflict with applicable law.

2.2. Specifically, in relation to supporting these individuals, the Policy:

(i) provides mechanisms allowing individuals to express their concerns and receive information on the outcome of each investigation, and

(ii) establishes a clear procedure for submitting and managing reports and complaints, with swift response times and clearly defined roles.

3. Scope of Reports/Complaints

Reports and complaints must be made under the condition of sincere and reasonable belief that an incident has occurred which falls under the definitions provided in Article 3 of Part One of this Policy. Individuals affected are encouraged to submit reports or complaints regarding such incidents. The company and all responsible individuals are committed to accepting and not obstructing the receipt of complaints, to investigating and handling every such complaint promptly, and to examining the matters reported with impartiality and respect for human dignity, while also taking immediate measures to protect the affected individual.
4. Establishment of an Independent Three-Member Committee

An independent Three-Member Committee is established, consisting of:

(a) the Operations Director,

(b) the Personnel Compliance Officer, and

(c) the company’s legal advisor.

The Committee is responsible for investigating complaints related to incidents of violence, harassment, discrimination, and violations of equal opportunities. Such investigations will be conducted thoroughly, promptly, and with confidentiality, ensuring the protection of privacy and the rights of both parties, while respecting human dignity. The investigation will be carried out sensitively and fairly for all involved parties, as specified in the following articles.

5. Complaint Submission Procedure

The following procedure aims to manage internal complaints related to incidents of violence and harassment:

5.1. Complaint Reception:

Any person falling under the scope of this policy who is affected by an incident of violence or harassment may file a complaint either verbally or in writing, following the procedure below. Complaints can be submitted through secure and easily accessible communication channels. Specifically, complaints may be:

(a) submitted verbally or in writing directly to the designated contact person (“reference person”),

(b) sent by email to hr@technor.gr,

(c) submitted in writing to the direct supervisor of the complainant,

(d) sent via postal mail to the company’s current address, attn: Human Resources Manager, marked “Confidential,”

(e) submitted verbally or in writing to the members of the Three-Member Committee or directly to the Committee as a body.

5.2. If the complaint is submitted by email, it is received and reviewed directly by the reference person.

5.3. If the complaint is submitted in writing to the complainant’s direct supervisor, the supervisor must immediately forward it electronically to the designated contact person.

5.4. In the case of a verbal complaint, the reference person informs the alleged victim of all their rights, as described in this policy, and assists them in drafting a written complaint to the company, if the alleged victim so wishes.
5.5. Complaint Content Requirements

The complaint must clearly and in as much detail as possible describe:

• the date and time of the incident,

• the person who exhibited the behavior falling within the scope of this policy,

• the actual events that occurred,

• any individuals who may have been present during the incident,

• the reasons why the alleged victim believes the incident took place,

• any witnesses whom the alleged victim wishes to be examined,

and, in general, any other information deemed necessary for the investigation of the incident.

6. Complaint Management

6.1. Complaint Record-Keeping

The Committee shall maintain a file that, for each complaint, includes the following details:

(i) the number, subject, category, and origin of the complaint,

(ii) information regarding the investigation of each complaint, and

(iii) the final outcome of the investigation and the actions taken.

6.2. Responsibilities of the Committee in Handling Complaints

The Committee is responsible for managing complaints submitted through the aforementioned channels. Its duties include:

(a) Reviewing the admissibility of the complaints received through all established reporting channels.

(b) Evaluating and prioritizing the complaints.

(c) Contacting the complainant, where required.

(d) Taking all appropriate measures to protect the personal data of individuals involved and ensuring their deletion according to applicable retention periods.

6.3. Committee Procedures

(a) The Committee must promptly inform the complainant of the receipt of their complaint by providing written or electronic confirmation and, if possible, inform them of the outcome of the investigation after its conclusion, or during the process if requested by the complainant.

(b) Within two days of receiving the complaint, the Three-Member Committee must initiate an investigation of the claims made therein. The execution of the investigation is assigned to one of the Committee members, who will act as the Investigation Officer.

(c) The type of investigation carried out by the Committee is determined based on the nature and specifics of the complaint. In general, the investigation will include interviews with the complainant and the alleged perpetrator, collection of evidence from the parties involved, interviews with witnesses proposed by either party or deemed necessary by the Committee, review of any relevant documents, emails, etc., and a comprehensive assessment of all materials available.
6.3 (d)-(h). Investigation Timeline and Outcome Procedures

(d) The investigation must be completed within one week from the date it begins, unless, due to the nature of the case, its complexity, or other relevant factors, more time is required. In such cases, the Three-Member Committee shall submit a written notification to the company’s legal representative, explaining the reasons for the delay and indicating the estimated date of completion.

(e) Upon conclusion of the investigation, the Three-Member Committee drafts a report and shares it with the company’s legal representative.

(f) Based on the findings of the report, the company’s legal representative takes the necessary measures, as defined in Article 7 of this policy.

(g) The measures decided upon are communicated in writing on the day following the decision to both the complainant and the respondent.

(h) The same procedure shall also be followed if a third party submits a complaint through the aforementioned channels concerning a relevant incident they have become aware of.

7. Measures to Be Taken

The actions taken by the company’s management may vary depending on the nature of the contractual relationship of the respondent with the company, the seriousness, type, and nature of the incident, and whether similar behavior has occurred in the past. Such measures may include:

a) Activation of the disciplinary procedure as defined in the company’s regulations

b) Issuance of a formal compliance warning

c) Mandatory attendance of training or educational seminars

d) Change of position, working hours, location, or method of work

e) Assignment to remote work or teleworking

f) Termination of the employment or other contractual relationship
8. Confidentiality, Privacy, Personal Data Protection, Impartiality, and Objectivity

The above procedure must be conducted with strict confidentiality and discretion. All applicable legal provisions regarding the processing of personal data must be observed, and impartiality and objectivity must be demonstrated throughout the process.

9. Prohibition of Retaliation

9.1 Any form of retaliation against the complainant, the alleged perpetrator, or witnesses involved in the investigation is strictly prohibited, as is any further victimization of the affected individual. It is also prohibited to obstruct the receipt, investigation, or management of complaints or reports in any manner.

9.2 Under this framework, every affected individual is encouraged to speak openly and provide honest and complete information without fear of any form of retaliation.

10. Cooperation with Competent Authorities

The company is obligated to cooperate with all relevant authorities in matters concerning violence and harassment and to provide all available information in its possession, provided that the provisions for the protection of personal data are respected, as per Article 5(1) of Law 4808/2021.

11. State Institutions and Other Bodies for Filing a Complaint

Complaints concerning violence and harassment may also be submitted to the following authorities, independent bodies, and judicial authorities:

a) Independent Authority – Greek Ombudsman

Address: 17 Chalkokondyli Street, Athens, 104 32

Website: https://www.synigoros.gr
11. (continued) State Institutions and Other Bodies for Filing a Complaint

b) Independent Labour Inspection Authority:

Central Service

Address: 10 Aghisilaou St., Athens, Postal Code 10437

Complaint Hotline: 15512

Website: www.sepenet.gr

Autonomous Department for Monitoring Violence and Harassment in the Workplace

Address: 18 Dragatsaniou St., Athens, Postal Code 10559

Email: sepeviapar@ypakp.gr

Phone: +30 213 1516869

Regional Offices and Labour Relations Inspection Departments of the Independent Labour Inspection Authority.

Citizen Service Telephone Line: 1555

Immediate psychological support and counseling service for women victims of gender-based violence: SOS Line 15900

The full telephone directory and contact information are available on the website www.sepenet.gr under the link:

https://www.sepenet.gr/liferayportal/documents/20181/55607/SEPE+email+phones+catalog+072021.pdf

c) Local Prosecutorial Authorities and Police Departments

d) Trade Union Organizations

12. Personal Data

All company personnel and departments mentioned above are committed to maintaining confidentiality and protecting Personal Data (PD) collected during the performance of their duties.

Any processing of personal data under this policy is carried out in accordance with the applicable national and European legislation on data protection. The personal data of all parties involved are protected and are processed solely in relation to the specific complaint and exclusively for the purpose of assessing the validity of the complaint and investigating the reported incident.

The company takes all necessary technical and organizational measures to safeguard personal data.

Sensitive personal data or any other data not directly related to the complaint will not be taken into account and will be deleted.
Access and Retention of Data

Access to the data contained in the reports is strictly limited to individuals involved in the handling and investigation of the incident.

Personal data is deleted within a reasonable timeframe after the conclusion of the investigation initiated by the complaint.

The company retains any collected information in a file, in compliance with the provisions of Law 4624/2019.

D. FINAL PROVISIONS

1. Fraudulent or Malicious Complaints

This Policy must under no circumstances be used to submit false or malicious complaints against other individuals. It is important to understand that unfounded or frivolous allegations may cause significant harm to both the accused and the company. If the company determines that a person has knowingly made false statements in relation to a claim, immediate disciplinary measures will be taken.

2. Posting of This Policy

This policy shall be delivered to all individuals subject to its scope and posted in a visible location within the workplace, alongside the contact details for the competent administrative and judicial authorities.