1. Purpose

The Company is committed to ensuring a working environment free from all forms of violence and harassment, in accordance with Law 4808/2021. Respect for human dignity, mutual respect, and equal treatment constitute fundamental principles of our operations.

2. Scope of Application

This Policy applies to all employees, regardless of the nature of their employment relationship, as well as to external collaborators, interns, trainees, job applicants, and any third party associated with the workplace.

3. Definitions

Violence and harassment refer to any unwelcome behavior, act, or practice that has the purpose or effect of violating a person’s dignity and creating an intimidating, hostile, degrading, or offensive environment. The absence of an explicit refusal does not constitute consent.

4. Examples of Conduct

• Persistent and unwelcome personal messages
• Pressure to engage in personal meetings outside the workplace
• Sexual innuendos or inappropriate comments
• Verbal or psychological intimidation
• Threats or any form of coercive or intimidating conduct
  
  

5. Employer Obligations

The Company is required to take preventive measures, promptly investigate any complaint, ensure confidentiality, and protect individuals from retaliation.

6. Employee Obligations

Employees are expected to respect professional boundaries, refrain from conduct that may be perceived as harassing, and cooperate fully in any investigation process.

7. Complaint Submission Procedure

A complaint may be submitted either verbally or in writing to the Human Resources Department. The Company is committed to conducting a prompt, objective, and confidential investigation.

8. Disciplinary Measures

In the event that, a violation of this Policy is confirmed, disciplinary measures may be imposed, including a written recommendation, formal reprimand, or termination of the employment relationship.

9. Protection Against Retaliation

Any form of retaliation against a person who submits a complaint or participates in an investigation is strictly prohibited.

10. Communication and Training

This Policy shall be communicated to all employees and posted in a visible location or on the Company’s internal network. The Company shall ensure regular training and awareness initiatives.

11. Person of Contact

HR Director: Stella Koukoumpani