Policy for combating violence and harassment in the workplace

Α. Introduction

With Law 4808/2021, the International Labour Organization’s Convention 190 for the elimination of violence and harassment in the world of work, which was adopted by the International Labour Organization Conference on 21-6-2019, was ratified and gained legal force. This convention is the first international contractual document establishing global standards for addressing violence and harassment in the workplace. The second chapter of Law 4808/2021 includes the adoption of measures and regulations concerning harassment and violence at work.

Β. Objective

i. The company complies with all the measures and obligations regarding the implementation of the provisions of Part II of Law 4808/2021 (and Section II of Presidential Decree 80/2022, which codified the provisions of Law 4808/2021) for the prevention and management of all forms of violence and harassment, including gender-based violence and harassment as well as sexual harassment.

ii. All forms of harassment and violence violate an individual’s dignity. They lead to a decrease in self-esteem, intense feelings of fear, anger, and victimization, which can further affect the physical and mental health of the employee. In some cases, they may disrupt the interpersonal relationships of the victim and reduce their professional performance.

iii. Interpersonal violence, such as sexual harassment, is one of the most traumatic events an individual can experience. The company is committed to responding to the immediate needs of the victim by managing the issue seriously to help limit the further harmful effects of the violation. Equally important is that the company continues to support the victim until they recover from the incident.

iv. In view of the above legal obligation, the purpose of this procedure is to identify prohibited behaviors and actions, the scope of protected persons, and to define the investigation, management, and ultimately the penalty process for prohibited behavior, as well as to prevent the recurrence of such actions in the company’s workplace.

v. Specifically, 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 individual to a world of work free from violence and harassment. In this context, the company declares that it recognizes and respects the right of every employee to a work environment free from violence and harassment and ultimately declares zero tolerance for any form of violence and harassment in the workplace.

vi. Furthermore, employees and persons equated with them are informed of their rights and the company's obligations in the event of a prohibited incident, the procedure to be followed, the impartial investigation and examination of complaints, while strictly adhering to the provisions of the General Data Protection Regulation of the persons being reported.

vii. Employees are also informed about the relevant Authorities to which they can refer beyond filing a complaint within the company.

viii. The purpose of this policy is:
-To appropriately inform the employees of the company about the concepts of harassment and violence and the individual's rights in case they face incidents of harassment and/or violence at work.
– To create an environment within the company that will prevent deviant behavior in situations of violence and harassment.
– To maintain conditions in the workplace where all staff are treated with respect, dignity, and courtesy.
– To promote appropriate behavior standards based on the company's principles and values as well as corporate culture.
– To implement procedures so that all employees are aware of their rights and responsibilities.
– To encourage reporting of undesirable behaviors.
-To define the process for reporting and investigating complaints/reports of incidents of violence and harassment.
– To assist in timely handling of all reports with seriousness, sensitivity, fairness, and confidentiality.
– To ensure the confidentiality of information and disclose the issues arising from exposing individuals and personal data.
– To protect employment and support employees who are victims of domestic violence as much as possible with every suitable means or reasonable adjustment.

ix. Scope of Application:

This policy is adopted in accordance with Articles 9 and 10 of Law 4808/2021 and the applicable regulatory legislation and applies to the persons in paragraph 1 of Article 3 of Law 4808/2021, that is, it covers the employees and workers in the company, regardless of their contractual status, including those employed under a work contract, independent services contract, or salaried mandate contract, those employed through third-party service providers, as well as persons attending training, including interns and apprentices, volunteers, employees whose employment relationship has ended, persons applying for work, and employees in the informal economy.

C. General Principles

i. As a general rule, all forms of violence and harassment are prohibited, which may manifest during work or due to work, including harassment based on gender and sexual harassment.

ii. Specifically, “violence and harassment” are defined as behaviors, actions, practices, or threats aimed at or resulting in physical, psychological, sexual, or economic harm, whether occurring as isolated incidents or repeatedly.

iii. “Harassment” refers to behaviors intended to or resulting in an affront to an individual’s dignity and the creation of an intimidating, hostile, degrading, humiliating, or offensive environment, regardless of whether these behaviors constitute discrimination. This also includes harassment based on gender or other discriminatory reasons.

iv. “Gender-based harassment” refers to behaviors related to an individual’s gender, intended to or resulting in an affront to an individual’s dignity, creating an intimidating, hostile, degrading, humiliating, or offensive environment. Such behavior includes sexual harassment and behaviors related to sexual orientation, gender expression, identity, or characteristics of the person.

v. This behavior can be isolated or repeated. It does not matter how the perpetrator perceives their behavior toward the harassed individual, nor is it necessary for the harassed person to inform the perpetrator that their behavior is undesirable.

vi. The perpetrator's intent is irrelevant. What matters is that the harassed individual reasonably perceived the behavior as unpleasant, offensive, intimidating, humiliating, or aggressive.

vii. Sexual harassment, in particular, is not always easily distinguishable. Such behavior may be considered a simple joke or teasing without the intent to harass. However, if the other person feels disturbed by this behavior and perceives it as suggestive, offensive, or threatening, then an issue arises, and intervention is required.

D. Forms of Harassment / Violence

i. Prohibited behavior may manifest in the following ways:
Verbally: Demeaning or disrespectful comments, derogatory insinuations about performance, professional competence, or efficiency, unjustified excessive assignment of duties resulting in stress, anxiety, and psychological pressure, sexual comments and insinuations, jokes, gestures, indecent and offensive comments about gender or sexual orientation, discussions on sexual topics, intrusive questions about personal or sexual life, abusive language, suggestions for private meetings or sexual relations.
Non-verbal behavior: Unjustified significant and substantial downgrading of working conditions, unwanted touching, caresses, kisses, unnecessary proximity, obscene gestures, suggestive insinuations, monitoring of personal life (e.g., via social media), attempts to share sexual material such as images, magazines, or videos.
Other forms of remote behavior, in writing or via the internet or other digital means or technologies: Texts with clearly offensive or sexual content, similar telephone communications, messages, displaying photos, posting sexual images or films, spreading sexist claims.
ii. Prohibited behaviors may come from colleagues, but also third parties such as clients or suppliers, as long as they occur within the context of work. Special care should be given to vulnerable categories of employees, such as those working shifts, night workers, new hires, people with disabilities, and migrant workers.

iii. Prohibited behaviors may manifest in the following places:

(a) in the workplace, including public and private spaces that constitute workspaces,

(b) in places where the employee is remunerated, takes breaks for rest or food, or uses bathrooms, sinks, and changing rooms,

(c) during travel, trips, training, events, or social activities related to work,

(d) through work-related communications, including those carried out via information and communication technologies,

(e) in accommodations provided by the company as the employer, and

(f) during the transportation of employees to and from work.

E. Prevention and Combating Violence and Harassment in the Workplace

i. Assessment of the Risks of Violence and Harassment at Work

The risks of violence and harassment in the workplace are defined by the International Labour Organization (ILO) as the interaction between organizational factors (work content, work organization, environmental and organizational conditions) and the abilities and needs of the employee. The factors related to the design, organization, and management of work, as well as its social and environmental contexts, which can potentially cause psychological or physical harm to the individual, are work-related and recognized as one of the most significant modern challenges to occupational health and safety. These factors are linked to issues such as workplace stress, violence, and harassment.

Based on international literature and research, twelve factors have been identified that belong to the category of Psychosocial Risks:

  • Psychological Support
  • Organizational Culture
  • Clear Guidance and Supervision
  • Workplace Atmosphere
  • Person-Job Fit (Psychologically and Knowledge-Based)
  • Development and Advancement
  • Recognition and Reward
  • Engagement and Influence
  • Workload Management
  • Professional Commitment
  • Work-Life Balance
  • Psychological Characteristics

The effects on the employee may relate to their physical health: mild problems like headaches, back pain, or more severe issues such as cardiovascular diseases, diabetes, and chronic health problems. Psychological issues include: workplace stress, anxiety, depression, substance abuse or addiction, emotional exhaustion, psychosomatic symptoms, burnout, decreased concentration and memory, etc.

The impacts on the business include: absenteeism, reduced productivity/performance, decreased work quality, work errors, increased legal claims, and insurance costs, among others.

ii. Measures for the Prevention, Control, Limitation, and Management of these Risks, as well as the Monitoring of Such Incidents or Behaviors

The company explicitly and unequivocally states that it strictly adheres to the legislation for addressing workplace harassment and violence. The company commits to taking any appropriate measure or reasonable adjustment, considering the duties and position of the employee, to support employees who are victims of domestic violence. Specifically, the company:

a) Encourages maintaining a work environment where respect for human dignity, collaboration, and mutual assistance are core values.

b) Ensures open communication with the employer, immediate supervisors, and colleagues.

c) Has established a process for managing reports/complaints. Any complaint regarding any form of violence or harassment in the workplace will be handled with absolute confidentiality, discretion, and respect for the dignity and personal data of the complainant.

d) Ensures that employees receive the necessary training and information to perform their duties, particularly in positions with higher risk for incidents of violence and harassment (e.g., group work, night shifts, holidays, and isolated locations).

e) Adopts actions to raise awareness among employees about healthy behavioral models, such as avoiding dependencies, and addresses issues concerning vulnerable categories of employees.

f) Guides and supports victims of violence and harassment, as well as victims of domestic violence, for their reintegration into the workplace.

g) Trains employees on procedures for managing incidents of violence.

h) Regularly evaluates the effectiveness of preventive and response measures and revises/updates risk assessments and measures.

i) Informs every new employee from the outset about the company's policies through corporate documents and maintains additional tools for managing inappropriate behaviors (appraisals, written reprimands, etc.).

iii. Actions for Informing and Raising Staff Awareness a) The company declares zero tolerance for violence and harassment. Specifically, the categories of actions for raising staff awareness on these issues are defined as follows:

Avoid discussions, comments, innuendos, gestures, and expressions among colleagues that target an individual for professional performance, achievement of results, immediacy and readiness in task execution, or that refer to gender, sexual orientation, or gender identity.

  • Correct your behavior when you realize it bothers or offends colleagues and do not hesitate to apologize.
  • Set personal boundaries in your relationships with colleagues.
  • Collaborate with your department supervisors to eliminate the phenomenon.
  • Do not ignore or downplay unpleasant feelings caused by unwanted behavior from a colleague.
  • Do not hesitate to express your opinion about the behavior of the person harassing you.
  • Do not feel uncomfortable, ashamed, or blame yourself for the perpetrator’s behavior.
  • Do not choose isolation from colleagues.
  • Do not justify the perpetrator’s behavior.

b) The company is committed to providing staff with information and resources in accessible forms, depending on the case, regarding the risks of violence and harassment, as well as related preventive and protective measures, the procedures that exist at the company level, and the legal options available in case of such incidents.

c) As part of raising staff awareness, the company may:

  • Organize targeted staff meetings to discuss related issues and address potential risks promptly.
  • Conduct seminars with mental health professionals or counseling service providers, representatives of volunteer organizations, etc.
  • Encourage the participation of employee representatives and management personnel in training and educational seminars on recognizing and managing risks of violence and harassment in the workplace.

iv. Information on the Rights and Obligations of Employees and Employers, as well as those Exercising Managerial Authority or Representing the Employer, to the Extent and Degree of Their Responsibility in Case of an Incident, Report, or Complaint of Such Incidents, and the Relevant Procedure.

a) 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 under which the incident or behavior allegedly occurred has ended, they have the following rights:

  • Judicial protection
  • The right to file a complaint and request a labor dispute resolution with the Labor Inspectorate
  • Reporting to the Ombudsman
  • Filing a complaint within the company in accordance with the complaint management policy

b) Contact Information for Relevant Authorities:

  • Labor Inspectorate complaint line, tel. 1555
  • Ombudsman, tel. 2131306600, email [email protected]
  • Immediate psychological support and counseling service for women victims of gender-based violence, SOS Line 15900

v. Designation of a “Liaison” Point of Contact

The company’s HR manager is the designated "liaison" within the company. They are responsible for issuing updates and instructions to employees on the prevention and management of violence and harassment in the workplace. The liaison is committed to protecting any personal data that may come to their knowledge in the course of performing their role.

• Contact: tel. 6947901947

• Email: [email protected]

vi. Employment Protection and Support for Employees Who Are Victims of Domestic Violence

The company, demonstrating its social responsibility, actively supports employees in dealing with the consequences of domestic violence by taking measures that contribute to the smooth continuation of the employment relationship of the victim. In any case of domestic violence, the victim should contact the liaison mentioned in section v of this document. After assessing the severity of the incident, the victim is supported in every appropriate way to maintain their job and smoothly reintegrate after the incident, with particular emphasis on cases involving minors or children with disabilities or serious illnesses. Indicative measures include psychological support from a suitable person, granting special leave, or flexible working hours upon the employee's request.

F. Complaint Management Policy and Procedure of Article 10 of Law 4808/2021

This policy aims to promptly address any incidents of harassment or violence within the company, collect evidence for investigation, and take measures to resolve the issue. All employees, as well as anyone providing services to the company in any capacity, must show absolute respect to their colleagues, be polite, cooperative, tolerant, collegial, patient, and demonstrate solidarity, teamwork, and understanding. These behaviors are thoroughly and systematically monitored by the heads of each department. Department heads will closely monitor the work behavior of their subordinates and evaluate them not only on job performance but also on behaviors that may offend a colleague’s dignity or create feelings of aggression, fear, humiliation, or anxiety.

The policy applies when:

  • An employee claims to have been a victim of violence or harassment, is aware of the incident management process, and wishes to follow it.
  • The complainant and the accused are in continuous or frequent contact, and the complainant wishes the issue to be resolved to restore a harmonious relationship and cooperation.
  • The incidents of harassment or violence are of a less serious nature, and the complainant hopes the problem can be resolved internally within the company without needing to approach authorities such as the Labor Inspectorate or the Ombudsman.

To this end, this policy is:

  • Clear, well-known, defined, and understandable.
  • Objective and respects the personal data and dignity of the involved parties.
  • Has clearly defined stages throughout.
  • Does not victimize the complainant or potential witnesses.
  • Has a set timeframe within which it must be completed.

i. Communication Channels – Responsible Persons

  • The complainant must address their complaint to the business supervisor of the department to which they belong. If the supervisor is involved in the complaint, it is submitted to the next responsible person according to the organizational chart.
  • Any complaint regarding behaviors or acts of violence or harassment must be written, named, and specific, and may also be submitted electronically. Throughout the handling of the complaint, confidentiality is strictly maintained.
  • Upon submitting the complaint, the complainant is informed by their supervisor of their right at any stage of the internal process to file a complaint with the competent authorities (Labor Inspectorate and Ombudsman) or judicial authorities as they see fit.

ii. Investigation and Examination of Complaints with Impartiality and Protection of Confidentiality and Personal Data

The employer and any responsible person in the company are committed to receiving and not obstructing the receipt, investigating, and immediately managing any such complaint, investigating and examining the allegations impartially and with respect for human dignity, and taking immediate measures to protect the affected party. In any case, these individuals are obligated to maintain confidentiality and protect personal data collected in the course of performing their duties. As part of the investigation:

  • The complainant is asked to name any witnesses.
  • Witnesses are asked for a written report of the alleged incident or behavior.
  • Within seven (7) days of the complaint's submission, the accused is informed of the complaint and is asked to submit their views in writing, even electronically, to the three-member committee within seven (7) days of being notified. Legal representation is not allowed. In the process, it is the accused who must prove they did not commit the alleged acts.
  • The accused has the right to propose witnesses who may provide written or oral testimony about the incident.
  • If the accused accepts the complaint, the method of acceptance will be evaluated to resolve the issue.
  • Consequences will be proportionate to the seriousness of the proven offenses.
  • Anyone making false accusations will face appropriate consequences.
  • The complaint is examined promptly by a three-member committee consisting of the complainant’s business supervisor, the company’s personnel officer, and the legal representative.

iii. Prohibition of Retaliation Against the Affected Person

Regardless of the outcome of the complaint, all forms of retaliation or further victimization of the complainant by any employee or anyone collaborating with the company are strictly prohibited. The company adheres to the prohibition of retaliation according to Article 13 of Law 4808/2021 and the provisions of labor law. Specifically, it is prohibited and invalid to terminate or in any way dissolve the legal relationship upon which employment is based, as well as any other adverse treatment of the complainant, as long as it constitutes retaliatory behavior or a countermeasure: a) due to gender or family status; b) when it constitutes retaliatory behavior by the employer due to the employee’s refusal to submit to sexual or other harassment; c) when it is in reaction to the employer to a complaint, testimony, or any other action by the affected person.

iv. Description of Consequences for Proven Violations

a) The three-member committee mentioned in Chapter F.ii, after considering the views of both sides, will determine the validity of the complaint. If the complaint is found to be valid, even in part, the company will take appropriate and proportionate measures against the accused to prevent a repeat of similar incidents or behaviors. b) Considering the severity and seriousness of the incident, the following measures will be imposed on the accused, according to Chapter IV of the Regulation:

  • For minor offenses: a written warning for compliance.
  • For medium-severity offenses: temporary or permanent changes to the accused’s position, hours, location, or work tasks, as well as disciplinary fines.
  • For serious offenses, especially in case of repeat offenses, the company may impose the disciplinary penalty of suspension from work and, depending on the severity, may terminate the employment contract of the accused, subject to the provisions on abuse of rights under Article 281 of the Civil Code. c) If there is an imminent danger to the life, health, or safety of the complainant due to an incident of violence or harassment, after prior notice to the accused for immediate explanation, the investigation committee under Chapter F.ii may take one or more of the following temporary measures until the danger ceases:
  • Removal of the complainant from the workplace with payment of wages;
  • Change of shifts for the involved parties;
  • Transfer of the accused to another department;
  • Assignment of the accused to telework or remote work depending on the nature of their duties.

v. Cooperation and Provision of Relevant Information to Authorities Upon Request

The company and any person responsible for receiving and managing complaints about violence and harassment cooperate with any competent public, administrative, or judicial authority, which, either on its own initiative or upon request by an affected party, requests information and assistance within its jurisdiction. They are committed to providing assistance and access to relevant information. Any collected information is stored in a relevant file, following the provisions of Law 4624/2019 on the operation of the Data Protection Authority and the implementation measures of Regulation (EU) 2016/679. vi. Application a) Any deviation from the aforementioned procedure requires prior notification/approval by the company's management. b) The strict application of this policy and the related provisions of the law on preventing violence and harassment in the workplace deserves special attention because it protects the personality and individual rights of the staff and any collaborators, ensures a climate of workplace peace, harmonious cooperation, and good practices, and safeguards the company’s credibility, reputation, principles, and values, ensuring compliance with the law and protecting the company from administrative and financial penalties. Last Updated: 01/11/2023