1. Purpose

GEA GRAMMO ERATO APOLLON hereafter referred to as the “Organization” supports the idea that all employees have the right to work in an environment that respects the dignity, worth and human rights of every individual. To this purpose, the Organization is committed to ensuring a workplace free of violence, harassment and bullying, with zero tolerance towards any form of violence or harassment.

The purpose of this policy is to provide a comprehensive and modern framework for the purpose of informing, preventing, addressing, and combating violence and harassment in the workplace, contributing to the creation of a working environment that respects, promotes and safeguards the right of every individual to a workplace free of violence and harassment.

The Organization is committed to providing the necessary information as well as the safe and easily accessible communication channels for receiving complaints, to appointing the persons responsible to handle the relative complaints, to the impartial and confidential investigation of such incidents, prohibiting retaliation and further victimization, as well as to cooperating with and providing any relevant information to the competent authorities if requested.

2. Legal Framework

Through this policy, the Organization recognizes, adopts, and implements without hesitation, preconditions or limitations, the provisions as defined by the relative articles of the following effective legislation:

• Charter of Fundamental Rights of the European Union (2016/C 202/02).
• ILO Convention 190 for the Elimination of Violence and Harassment in the Workplace.
• Law No. 4808/2021 of the Hellenic Republic ratifying ILO Convention 190 (Government Gazette Issue A’/No. 101, June 19, 2021).

3. Definitions

For this policy and according to the terminology imposed by the legislation in effect, the following definitions apply:

• Employee

Any person employed under a full-time, part-time, permanent or temporary employment or occupation, performing any work on behalf of the Organization.

• Violence and Harassment

A range of unacceptable behaviors and practices or threats thereof, occurring as single incidents or repeatedly, aimed at, resulting in, or are likely to result in physical, psychological, sexual, or economic harm of the individual, including gender-based violence and harassment.

• Gender-Based Violence and Harassment

Violence and harassment directed at individuals because of their gender or disproportionately affecting individuals of a particular gender, including sexual harassment.

• Harassment

Several forms of behaviors, aimed at or resulting in the violation of the person’s dignity and the creation of an intimidating, hostile, humiliating, degrading, or offensive environment, regardless of whether they constitute a form of discrimination, including gender-based harassment or harassment for other reasons of discrimination.

• Gender-Based Harassment

The forms of behavior associated with a person’s gender, and which have the purpose or effect of violating that person’s dignity and creating an intimidating, hostile, degrading, humiliating or aggressive environment. These forms of conduct include sexual harassment, as well as forms of conduct related to the person’s sexual orientation, expression, identity or gender characteristics.

• Sexual Harassment

Any form of unenviable verbal, psychological, or physical conduct of sexual nature, that results to the insult of the individual’s personality and dignity, particularly by creating an intimidating, hostile, humiliating, degrading, or offensive environment around them.

According to the above, each concept is a subset of the previous one: sexual harassment is a subset of gender harassment, which belongs to the broader concept of harassment and, in its turn, gender-based violence and harassment, the latter pertains to the general category of violence and harassment.

• For the scope of implementing this Policy, the various forms of violence and harassment may take place in particular:
  • At the workplace, including public and private places where the employee performs her/his duties, receives wage, takes a break particularly for rest or lunch, in personal hygiene and care areas, in dressing rooms or accommodations provided by the employer.
  • During commute to and from work and any other journeys and travels, during training, as well as during work-related events and social activities related to the labor and
  • During work-related communications, including those carried out using technologies of informatics and communication.
• A behavior generally characterized as violence and harassment can occur in various forms, such as physical, verbal, non-verbal, direct, indirect, overt or implied and can be expressed either in person or online, regardless of whether corporate or personal equipment and accounts are used. Indicative examples of violent and harassing behavior include:
• Physical

Physical violence, unwanted touching, unwanted physical contacting, unwanted hugging, unwanted kissing and/or any other similar conducts.

• Oral / Verbal

Offensive and harassing questions about the individual’s personal life, comments about appearance, age, gender, privacy, sexually awkward and/or offensive comments/jokes, inappropriate, unwanted and/or repeated requests for dates, use of threats, blackmail or inappropriate rewards and/or similar.

• Non-verbal

Showing of inappropriate visual material of sexual content or nature, inappropriate, of persistent and intrusive gaze with sexually suggestive intent, lewd gestures and/or any other similar.

• Cyber

Offensive and inappropriate suggestions on websites and social networking applications, sending emails or other computerized/electronic messages with offensive, sexual content.

Sexual harassment can include one or more incidents and actions that constitute harassment and can be physical, verbal and non-verbal.

4. Declaration of Policy

The Organization is committed to providing a safe environment for all its employees, free from illegal discrimination of any kind and free from illegal violence or harassment in the workplace, including sexual harassment. The Organization covenants to a zero-tolerance policy against any form of workplace violence or harassment. The Organization handles all incidents seriously and investigates immediately and promptly all allegations with respect and confidentiality. Any person found to have been engaged in violent or harassing behaviors will face disciplinary actions as specified below.

The Organization is committed to completely preventing or confronting any cases of violence and harassment through:

• Risk assessment for violence and harassment in the workplace according to Law No. 3850/2010 of the Hellenic Republic, along with implementing protective and preventive measures and activities concerning the Organization in general and any specific employment positions and duties.
• Providing information concerning the rights and obligations of the employees, the employer and the individuals exercising managerial authority through this policy.
• Designating an individual as the reference person of the Internal Complaints and Accusations Committee, which will be responsible for handling these complaints and for guiding and informing the employees in matters of prevention and management of violence and harassment.
• Ensuring that this reference person responsible for complaint management understands how to respond to harassment incidents, including the correct manners to collect information, to safeguard confidentiality, to react, to handle restricted information, to substantiate and to keep documented records.
• Providing a procedure for complaints (as described below) that is fair, timely, effective as well as a safe and easily accessible communication channel for receiving complaints and further confidential and impartial investigation of such.
• Prohibiting retaliation and further victimization of the affected person and describing the consequences upon confirmation of offences.
• Promoting appropriate behavior standards.
• Cooperating with and providing any necessary information to the competent authorities if required or requested.

 

The Organization is committed to taking all reasonable measures to eliminate bullying and harassment in the workplace, in accordance with Law No. 4808/2021 and encourages any of its employees who witness or are victims of harassment or bullying to disclose the information as soon as possible, in accordance with the following complaint procedure.

This Policy is not intended to create new or abnormal patterns of behavior but rather to reduce and eliminate offending behavior that falls within the definitions of violence and harassment.

Every employee of the Organization should be aware that the Organization respects the rights of every person affected by an incident of violence and harassment as defined by Article 12 of Law No. 4808/2021 of the Hellenic Republic, which generally refers to the following:

• Any employee who is affected by an incident of violence and harassment, even if the employment has been terminated, in the context of which it is alleged that the incident or the conduct against him/her occurred, has the right to file a complaint with the Labor Inspectorate (telephone number 1555) and the Ombudsman (telephone number +30 213 1306 600) as a body for promoting and supervising the principle of equal treatment, in addition to judicial protection, in application of the Greek Law No. 3896 / 2010 (Government Gazette A’ 207) and Law No. 4443 / 2016 (Government Gazette A’ 232), as well as to file a complaint within the organization according to the procedure described in the relevant article of this Policy. This Policy does not substitute the legal procedures established by law and does not deprive the employee of his/her legal rights.
• When an employee of the Organization violates the prohibition of violence and harassment, the Organization will take the necessary and appropriate measures in each case against the person being reported in order to prevent and avoid a similar incident or behavior from recurring. These measures may include a recommendation to comply, a change of position, time, place or manner of work or termination of the employment or partnership relationship, without prejudice to the prohibition of abuse of rights as provided for in Article 281 of the Civil Code (abuse of rights). The relevant sanctions and disciplinary measures are described in the relevant article of this Policy.
• Any Employee who suffers an incident of violence and harassment against him/her shall have the right to choose to leave the place of work for a reasonable period of time, without loss of pay or other adverse consequences, if in the reasonable belief there is a serious risk to his/her life, health or safety in order to restore industrial peace or when the measures referred to in the above paragraph are not sufficient to stop the behavior of violence and harassment. In this case, the worker must inform the Organization in writing in advance, stating the incident of violence and harassment and the circumstances which justify his/her belief that there is a serious risk to his/her life, health or safety. If the risk does not exist or has ceased to exist and the reported person refuses to return to the workplace, the Organization may appeal to the labor Inspectorate with a request to resolve the dispute based on the relevant Article 18 Law No. 4808/2021 of the Hellenic Republic.
• When an employee exercising administrative responsibility or representing the Organization violates the prohibition of violence and harassment, that employee is in violation of labor legislation and may be subject to the most severe administrative consequences provided for in the legislation.
• An employee affected by an incident of violence and harassment who makes a complaint within the Organization in accordance with the procedure described in the relevant article of this Policy will be protected by the Organization against any action that may constitute retaliation, including any change in daily duties and employment status.
• When an employee who is affected by an incident of violence and harassment and makes a complaint within the Organization, in accordance with the procedure described in the relevant article of this Policy and invokes, before the Internal Complaints and Allegations Committee of the Organization, as defined below, facts or evidence from which an incident of violence and harassment occurred, the person being reported shall bear the burden of proof (the same applies in the case of a court or other competent authority, in accordance with the relevant legislation). This provision does not apply to criminal proceedings.

As part of staff awareness, the Organization encourages:

• The organization of dedicated meetings with employees to discuss relevant issues and address potential risks in a timely manner.
• Holding seminars with mental health specialists or counselling service providers.
• Participation of the Organization’s managers in training programs and seminars on the identification and management of risks of violence and harassment at work.

The Organization expressly prohibits the possession and use of any form of weapon in the presence of an employee in the workplace (as defined at length above), even if kept in the employee’s vehicle. Any employee found to be in possession of a weapon while in the workplace will be subject to immediate dismissal. Employees who fail to submit to or fully cooperate with possible searches for possession of weapons will be subject to disciplinary action, including dismissal.

The Organization’s managers and/or directors must carefully monitor the behavior of employees to ensure that incidents of workplace violence and harassment do not take place. Supervisors and Directors who witness any such behavior or suspect that such behavior is taking place should report it immediately to Operations Manager / PA to GM and in her absence or incapacity to Financial Director. Supervisors and Directors who tolerate incidents related to workplace violence and harassment or who fail to promptly report such conduct as provided in this Policy will also be subject to appropriate disciplinary action, including dismissal.

Employees are encouraged to report unwanted behavior of violence and harassment by others in the workplace. While the Organization cannot control the behavior of non-employees, the Organization is committed to directing the complaint to the appropriate representatives of the third-party employer.

The Organization declares its zero tolerance for incidents of retaliation, retaliatory behavior and toxic working environment related to incidents of violence and harassment.

In the event of a disagreement or conflict between this Policy and the applicable legislation, the articles of the applicable legislation will prevail over this Policy.

5. Clarifications

Violence and harassment in the workplace ranges from threats and verbal abuse to physical assaults and even homicide. It can affect and involve employees, co-workers, customers and visitors.

Indicative examples of NON-ACCEPTABLE behaviors are the following.

• aggressive or threatening behavior,
• spreading malicious rumors about a person or group, socially excluding or isolating someone,
• using offensive humor, including racist, religious, sexist or ethnic jokes,
• derogatory comments concerning another person’s gender, race, ethnicity, national origin, age, disability, religion, sexual orientation, gender identity or expression, or any other legally protected characteristic of another person,
• public humiliation of another person,
• downloading, posting, uploading, displaying, publishing, photographing, printing, distributing pornographic, obscene, offensive or inappropriate material or material of an ethnic, religious or racist nature,
• constant and suffocating monitoring and supervision,
• destruction, concealment or theft of personal effects or entertainment equipment,
• exclusion of applications for leave, training or promotion in an arbitrary manner,
• physical abuse,
• any act or omission which excludes or places persons at a distinct or disadvantage because of their sex, age, origin, sexual orientation, gender identity or religious beliefs,
• any instruction, incitement or systematic encouragement of persons to engage in discriminatory or unequal treatment of others on grounds of sex, age, origin, sexual orientation, gender identity, religious beliefs (direct discrimination),
• obstructing the advancement of a person because of age, gender, origin, religion, political beliefs,
• denying a person access to privileges and facilities to all staff based on gender, age, sexual orientation, gender identity, religious beliefs.

6. Scop

This Policy applies to:

• All employees of the Organization (as defined in Section 3.1 above)
• All partners and employees of companies cooperating with the Organization
• All contractors or subcontractors and their employees associated with the Organization

and covers incidents of violence and harassment that occur in the locations defined in Section 3.7 above.

7. Complaint Procedure

Anyone subjected to an incident of violence or harassment is encouraged to submit their complaint or report to the Organization.

For this purpose, the reference person of the Internal Complaints Committee is Operations Manager/PA to GM, and in her absence, Financial Director as the person responsible for receiving and following up on complaints and allegations.

The members of the Internal Complaints and Allegations Committee are:

1. Legal Advisor
2. Lawyer
3. Lawyer

If the person being reported is a member of the Internal Complaints and Allegations Committee and is involved in any way in the complaint of violence or harassment, that person will not be involved in any of the procedures and the complaint will be handled by the other members of the committee or their substitutes.

The submission of any incidents may be carried out through the electronic platform, which meets all specifications relating to the security of:

• Information systems
• Personal data
• Confidentiality or anonymity of the reporting person, if they choose so

It also provides the ability to monitor the status of the report from the initial submission to its completion. Access to the electronic platform is available on the Company’s website, and we encourage reporting people to use it, as it is the most comprehensive and secure means of handling reports.

In addition, written complaints may be submitted by hand to the reference person of the Internal Complaints and Allegations Committee, namely Operations Manager.

The organization encourages signed complaints. Anonymous complaints make the work of thorough investigation extremely difficult or even impossible, due to the difficulty of obtaining information from an anonymous complainant (e.g., conversation, meeting to provide clarifications during the investigation), as well as assessing the reliability of the complaint. However, even anonymous complaints will be taken seriously and investigated. Specifically, anonymous complaints submitted will be examined depending on the degree of documentation and the possibility of identifying the conduct incompatible with this Policy that they describe.

All complaints or allegations should be submitted within 3 months from the date of the incident/last incident. The reference person may extend the timeframe for reasons that are recorded in writing and if it is satisfied that these reasons prevented the complaint from being made. Complaints should be accompanied by supporting evidence in all forms (documents, videos, emails, text or voice messages, witnesses, etc.). Complainants should be aware that delay in filing a complaint will make it more difficult to fairly and fully investigate the complaint.

After receiving a complaint and/or allegation, the following procedure is followed:

• The reference person within ten (10) working days from the receipt of the complaint and/or the allegation, proceeds to make the relevant report that will include the description of the incident of violence and harassment accompanied by the necessary data (place, time, persons involved, supporting evidence, testimonies, names of witnesses, etc.) as well as a report of the view of the complainant and all parties involved regarding the result they are seeking. If necessary for the proper completion of the above report, the reference person will conduct an interview with the complainant as well as with all parties involved. This record will be shared with the complainant to obtain his/her agreement as to the accuracy of the information recorded.
• The reference person within five (5) days of the completion of the above step will proceed to share the recording of the complaint or allegation to the person being reported. The above will happen through an interview in which the incident will be presented to him/her, and he/she will be asked for his/her written response which should be submitted to the reference person within ten (10) days of the notification of the report.
• Upon receipt of the person’s response being reported, the reference person will undertake further examination of the complaint and/or allegation. In this process, the reference person may additionally interview the complainant and the person being reported, as well as all parties involved and possibly other relevant third parties separately and impartially. Thereafter, the reference person will prepare an investigation report of the complaint or allegation to the Complaints and Allegations Committee, which will include the findings and possible proposed sanctions or disciplinary action as provided below. The Complaints Committee may conduct a further round of interviews with the complainant, the person being reported and any third party involved. The final text of the investigation report shall be validated by the Complaints and Allegations Committee and communicated to the complainant and the person being reported. This procedure shall not extend the overall procedure beyond sixty (60) days from the date of the complaint or allegation.

The reference person will keep a record of all actions taken and will ensure that a) the situation has been resolved and b) all records relating to the matter are kept confidential.

If at any stage of the above procedure the reference person concludes that the procedure is not worthy of continuation (and does not need to proceed to the next steps), he/she will inform the complainant and the person being reported in writing of the reason why the procedure was not continued.

8. Penalties and Disciplinary Measures

The organization takes sanctions and disciplinary action, using the Progressive Discipline method, up to and including the implementation of termination of cooperation for the offender(s), following the following progressive steps:

Step 1: Verbal warning.

Step 2: Written warning.

Step 3: Suspension.

Step 4: Termination.

Depending on the seriousness of the event, any step can be taken, with the relevant actions that can be taken including: written apology, mandatory training or counselling session, recommendation of compliance, change of employment relations, mandatory teleworking, change of departments or positions, suspension or dismissal of the person being reported (without prejudice to the prohibition of abuse of rights in article 281 of the Civil Code).

The nature of the penalties will depend on the severity and extent of the incident of violence and harassment. Some serious cases, including physical violence or sexual harassment, may result in the immediate dismissal of the person being reported. The final determination of the appropriate course of action is the decision of the Internal Complaints and Allegations Committee and will be included in the incident investigation report.

Where the Internal Complaints and Allegations Committee concludes in the incident investigation report that the allegation against the person being reported is malicious, or the complainant or any other person making the complaint has made the complaint knowing it to be false, then the reference person may recommend to the Executive Management Team that action be taken against the complainant or the person making the complaint, corresponding to those listed above as sanctions and disciplinary measures.

Simply stating that a complaint is not substantiated does not imply malicious intent. Malicious intent must be clearly proven through a separate investigation and is based solely on deliberate, false accusations by the complainant.

The Criminal Code of Greece defines as illegal specific issues such as violent acts, sexual harassment, threats and behavior such as violence at work. In case of any of the above, the Organization may contact the police.

In any case, it is the inalienable right of the Company and its Partners to take any disciplinary measure – sanction by assessing the facts independently of the Internal Complaints and Allegations Committee.

9. Protection against retaliation

The Organization will not accept retaliation of any kind against any employee who, acting in good faith, reports act of violence or harassment. Any employee who engages in such acts, directly or indirectly, or encourages others to do so, will be subject to appropriate disciplinary action and the law.

Retaliation will be treated as serious misconduct. Anyone who suspects or experiences retaliation should report it to the reference person. Retaliation will be treated by the Organization as seriously as incidents of violence and harassment, even if the original complaint of violence and harassment is not substantiated.

10. Confidentiality

The identity of the complainant, the person being reported, witnesses, statements and any other evidence collected during the investigation process, the recommendations of the committees and the actions of the Organization are considered confidential material and will not be published or disclosed to the public or the media or to other employees or other persons associated with the Organization that are not necessary for the resolution of the complaint.

11. Personal Data

Any processing of personal data under this policy is carried out in accordance with the national and European legislation applicable to personal data and the relevant GDPR policy of the Organization. The data of all parties involved is protected and processed, exclusively and only in relation to the complaint in question, to verify the validity of the complaint, to investigate the specific incident and to take the necessary measures. Sensitive personal data and other data not directly related to the complaint at the discretion of the Internal Complaints and Allegations Committee will not be considered and will not be recorded or deleted. Access to the data contained in complaints will only be available to those involved and the members of the Internal Complaints and Allegations Committee, excluding the company’s legal advisor in his capacity as an external partner. Personal data related to the complaint will be deleted within a reasonable period after the completion of the investigation initiated based on the complaint and, in any case, after five years from the date of collection for specific reason.

12. Cooperation with the Competent Authorities

The Organization undertakes to cooperate and to provide any relevant information and data to any competent authority which, either on its own initiative or following a request from the complainant, requests data or information within its competence.

13. Validity Date

This Policy will be effective as of 01 May 2025 onwards.

SUBMISSION OF REPORT