Protection Policy Prevention of All Forms of Violence

Protection Policy for the Prevention and Handling of All Forms of Violence and Harassment at Work and Internal Complaints Management Policy


The company shall comply with all measures and obligations relating to the application of the provisions of Part of Law no. 4808/2021 on the prevention and treatment of all forms of violence and harassment, including gender-based violence and harassment and sexual harassment.


The company prohibits any form of violence and harassment that occurs during the course of employment, whether related to or arising from work, including gender-based violence and harassment and sexual harassment. a)Violence and harassment means any form of conduct, acts, practices or threats thereof, which are intended to, lead to or may lead to physical, psychological, sexual or economic harm, whether manifested in isolation or repeatedly; b) Harassment means conduct, harassment shall mean any conduct which has the purpose and effect of violating the dignity of a person and of creating an intimidating, hostile, degrading, humiliating, humiliating or offensive environment, whether or not it constitutes a form of discrimination, and shall include harassment based on sex or other grounds of discrimination. Gender-based harassment shall mean forms of conduct related to the gender of a person which have the purpose or effect of violating the dignity of that person and of creating an intimidating, hostile, degrading, humiliating, humiliating or aggressive environment within the meaning of Article 2 of Act No. 3896/2010 (A΄107) and par. 2 of Article 2 of Law No. 4443/2016 (Α΄232). These forms of conduct include sexual harassment under Law 3896/2010, as well as forms of conduct related to a person’s sexual orientation, expression, identity or gender characteristics.


The purpose of this policy is to create and consolidate a working environment that respects, promotes and safeguards 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 of violence and harassment and that it will not tolerate any such conduct, in any form, by any person.


This policy is adopted in accordance with Articles 9 and 10 of Law No. 4808/2021 and the regulatory legislation pursuant thereto and covers the persons referred to in par. 1 of Article 3 of Law No. 4808/2021 and shall apply to all forms of violence and harassment behaviour against the aforementioned persons that may take place: (a) in the workplace, including public and private places and places where the employee provides work, receives remuneration, takes a break, in particular for rest and eating, in personal hygiene and care areas, changing rooms or accommodation provided by the employer; (b) in travel to and from work, other travel, travel, education, as well as events and social activities related to work; and (c) during work-related communications, including those carried out by means of information and communication technologies.


Α. Preventing and combating violence and harassment at work.

The company shall take all appropriate and necessary measures to prevent and manage such incidents and forms of behaviour. a) assessing the risks of violence and harassment at work: The company shall take and implement all necessary measures to identify the risks associated with violence and harassment, taking into account, inter alia, any inherent risk arising from the nature of the activity, the workplace, factors such as gender and age or other characteristics that are grounds for discrimination, as well as risks relating to specific groups of employees.

To assess these risks, the company uses all legal and prescribed occupational risk assessment tools, such as those available for our country. b) Measures for the prevention, control, mitigation and response to such risks, as well as for the monitoring of such incidents or forms of behaviour, which the company implements are: 1) Encouraging the maintenance of a working climate where respect for human dignity, cooperation and mutual assistance are core values, 2) Ensuring open communication, 3) Ensuring that all employees are aware of the risks and that they are able to communicate openly with each other, and 4) Ensuring that the company’s employees are aware of the risks. 5) Implementing measures of a technical nature, such as improving lighting, etc, 6) Taking actions to inform and sensitize employees to healthy behaviour patterns (e.g. (e.g. avoidance of substance abuse, addiction), but also on issues concerning vulnerable categories of employees; 7) Guidance and support for victims of violence and harassment or victims of domestic violence for reintegration into the workplace; 8) Training of employees in procedures for managing incidents of violence; 9) Evaluation, through transparent and merit-based procedures, on a regular basis of the effectiveness of the preventive and countermeasures implemented and review/update the assessment of risks and (c) information and awareness-raising activities for staff: The company shall ensure the provision of continuous and uninterrupted information and provision of information through accessible formats, as appropriate, on the risks of violence and harassment, as well as on the related prevention and protection measures, on the procedures in place at the company level and on the possibilities provided by law in the event of such incidents.

The company in the context of staff awareness: organises targeted staff meetings to discuss relevant issues and address potential risks in a timely manner; organises and conducts seminars with mental health specialists or counselling service providers, representatives of voluntary organisations; encourages the participation of employee representatives and management in training programmes and seminars on the identification and management of risks of violence and harassment at work, d) information on the rights and obligations of employees and of the company, as well as of persons exercising managerial authority or representing the employer, to the extent and to the extent of their responsibility, in the event of the occurrence, reporting or reporting of such incidents, and on the procedure to be followed.

In particular, the company shall continuously inform staff and it is accepted that in the event that a person is affected by incidents of violence and harassment in access to employment, during the employment relationship or even if the contract or employment relationship under which the incident or conduct allegedly occurred has ended, the person has: a) the right to judicial protection, (b) an appeal, a complaint and an application for an industrial dispute to the Labour Inspectorate, within the scope of its statutory powers, (c) a petition to the Ombudsman, within the scope of his powers; and (d) lodging a complaint within the company in accordance with the complaint handling policy; (e) designating a reference person (“liaison”) to guide and inform employees regarding the prevention and response to violence and harassment at work.

Their role is to guide and inform employees, whether or not they are approached in response to an incident or complaint of violence and harassment. Staff can contact the reference person via the following e-mail address:

(f) Protecting employment and supporting workers who are victims of domestic violence, to the extent possible, by any appropriate means or reasonable accommodation. The company is against all incidents and phenomena of domestic violence and to this end shall take measures and implement policies to protect its personnel who have been subjected to such behaviour, namely: employment protection, special leave or flexible working arrangements at the request of the employee victim of domestic violence, with a view to supporting the employee in maintaining employment and smooth reintegration after such incidents, particularly in cases where there are minor children or children with disabilities or disabled children


Β. Procedure for receiving and examining complaints.

Any employee who has been subjected to any incident of violence or harassment may submit a written complaint to the competent person designated by the company. The complaint may be submitted in person or by e-mail, in particular to the following e-mail address: It is not possible to submit a complaint orally or by telephone.

a) channels of communication – responsible persons: our company has designated a responsible person who will receive, examine and manage complaints or grievances of the affected persons about behaviour of violence or harassment. This competent person will inform the person concerned of the possibility, at any stage of the procedure within the company, of also lodging a complaint with the competent administrative authorities within their competence (Labour Inspectorate and Ombudsman) and with the judicial authorities, at his/her choice.

b) Investigation and examination of complaints with impartiality and protection of the confidentiality and personal data of victims and complainants: the company, through the person in charge, undertakes to receive and not to prevent the receipt of complaints, to investigate and examine complaints with impartiality and respect for human dignity, as well as to take immediate measures to protect the affected person. The Competent Person shall thoroughly investigate each complaint and collect any information necessary in relation to it, always subject to the confidentiality and protection of Personal Data collected in the exercise of the above mentioned duties.

c) the prohibition of retaliation against the aggrieved person and the prohibition of victimisation of the complainant: The company undertakes to comply with the obligation of prohibition of retaliation in accordance with Article 13 of Law no. 4808/2021 and with the provisions of labour legislation. Retaliation and victimisation of the complainant constitute a serious breach of this policy and will result in consequences for the person acting in this way.

d) the description of the consequences of any violations. In accordance with Article 12.2 of the Act No. 4808/2021, when an employee or a person employed in another relationship violates the prohibition of violence and harassment in Article 4 of the same Act, the company undertakes to take immediately the necessary and appropriate measures, where appropriate, against the complainant, in order to prevent and avoid a similar incident or behaviour from recurring. These measures are: a) a recommendation to comply; b) a change of position or working hours or place or manner of providing work; and c) termination of the employment or cooperation relationship, without prejudice to the prohibition of abuse of right in Article 281 CC.

e) cooperating and providing any relevant information to the competent authorities, upon request: The company and the aforementioned competent person dealing with the reception and management of such complaints at company level shall cooperate with any competent public, administrative or judicial authority which, either on its own initiative or upon request by an aggrieved person, within the scope of its competence, requests the provision of data or information and undertake to provide assistance and access to the data ( par. 1 of article 5 of Law 4808/2021). To this end, any information they collect, in any form, shall be kept in a relevant file in compliance with the provisions of Law no. 4624/2019 (Α΄137).