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Policy against violence and harassment at work & internal complaint management.

1.INTRODUCTION

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 recognizes and respects the right of every employee to a work environment free of violence and harassment and hereby declares its zero tolerance for workplace violence and harassment behavior in any form and by any person.

This policy is adopted in accordance with Articles 9 and 10 of Law No. 4808/2021 and the regulatory legislation implementing them.

2.FIELD OF APPLICATION

The content of this policy applies to and covers members of management, all employees regardless of their contractual status, including those employed under a contract of employment, independent services, paid assignments, those employed through third party service providers, as well as persons attending training, including trainees and apprentices, any volunteers, employees whose employment relationship has ended and persons applying for employment.

Violence and harassment behaviour is considered to take place at work when it occurs:

  1. in the workplace, including public and private places and areas where the worker provides work, receives pay, takes a rest or meal break and in personal hygiene and care areas.
  2. travel to and from work, other travel, travel, education, and work-related events and social activities; and
  3. in work-related communications, including those carried out by means of information and communication technologies.

3.TERMS

For the purposes of this policy, the following definitions apply:

  1. 'violence and harassment' means any form of conduct, acts, practices or threats thereof, intended to cause, resulting in or likely to result in physical, psychological, sexual or economic harm, whether occurring in isolation or repeatedly
  2. 'harassment' means conduct that has the purpose or effect of violating the dignity of a person and of creating an intimidating, hostile, degrading, humiliating, dehumanising or offensive environment, whether or not it constitutes a form of discrimination, and includes harassment based on sex or other grounds of discrimination
  3. 'gender-based harassment' means forms of conduct related to the sex of a person which have the purpose or effect of violating the dignity of that person and of creating an intimidating, hostile, degrading, humiliating, degrading or offensive environment. These forms of conduct include sexual harassment (as defined below), as well as forms of conduct related to a person's sexual orientation, expression, identity or gender characteristics.
  4. 'sexual harassment' means any form of unwanted verbal, psychological or physical conduct of a sexual nature intended to or having the effect of violating the personality of a person, in particular by creating an intimidating, hostile, degrading, humiliating, humiliating or offensive environment around that person.

4.PROHIBITION OF VIOLENCE AND HARASSMENT AT WORK

All forms of violence and harassment occurring in the course of work, whether related to or arising from work, including violence and harassment based on gender, religion, race, sexual orientation and sexual harassment, are prohibited.

Indicative examples of violence and harassment behaviour:

Violent and harassing conduct may occur either in person or in cyberspace, whether or not using corporate or non-corporate equipment and accounts, and may be physical, verbal or non-verbal, direct or indirect, veiled or implied. It includes forms of conduct which are intended to violate the dignity of the individual and to create an intimidating, hostile, degrading, humiliating, humiliating or offensive environment

Indicatively, behaviours strictly prohibited in the workplace include: unwanted touching, unwanted physical contact, unwanted kissing and embracing, offensive and intrusive questions about personal life, sexually awkward and offensive comments and/or jokes, inappropriate dating proposals, obscene gestures, inappropriate, persistent and indiscriminate looking with a sexually suggestive tone, offensive and inappropriate suggestions on websites and social networking applications, sending emails with offensive sexual content.

(SEV Guide for businesses - Harassment and Violence at Work - Measures and regulations of Law 4808/2021).

5.PREVENTING AND COMBATING VIOLENCE AND HARASSMENT AT WORK

5.1. Assessing the risks of violence and harassment at work

The company, in cooperation with the persons appointed for this purpose, studies and assesses the possible risk factors of violence and harassment incidents in order to minimize the chances of violence and harassment incidents in the workplace.

Any inherent risks arising from the nature of the activity of the work provided, the workplace, the gender, the age of the worker, psychosocial risks, as well as risks relating to specific groups of workers, shall be taken into account and taken into account.

Indicative examples of risk situations for violence and harassment behaviour are: lack of training of employees regarding the understanding of violence and harassment behaviour, provision of work in isolated closed spaces, without the presence of more people, working hours (very early morning hours), individual history of employee-employee behaviour, way of job allocation.

5.2. Measures to prevent, control, mitigate and address such risks and to monitor such incidents or patterns of behaviour

The Company takes measures and implements management practices to prevent, control, mitigate and address the risks of violence and harassment at work and to monitor such incidents or forms of behaviour.

Indicative Prevention Measures:

  1. Encourage the maintenance of a working climate where respect for human dignity, cooperation and mutual assistance are core values. Encouraging and facilitating open communication between employees and between employees and those directly supervisors and their colleagues on issues of violence and harassment in the workplace.
  2. Informing and training employees on the applicable legislation, their rights and obligations in case of reporting or reporting incidents of violence and harassment and informing them of the procedures for handling incidents of violence.
  3. Taking actions to raise awareness of healthy behavioural patterns among employees
  4. Technical measures, such as the availability of appropriate lighting, etc.
  5. Evaluating on a regular basis the effectiveness of the preventive and countermeasures in place and reviewing/updating the assessment of risks and measures.
  6. Report/Complaint Management Procedure - Adoption of a Policy for the Management of Internal Complaints on Incidents of Violence and Harassment.

5.3. Staff information and awareness-raising activities

1. The company shall post this notice in a prominent place in the company's premises, so that all employees may be aware of it.
The company may:

  • Organise targeted staff meetings to discuss relevant issues and address potential risks of violence and harassment behaviour in a timely manner.
  • Organise seminars with mental health experts or counselling service providers or representatives of voluntary organisations on risk prevention and dealing with violence and harassment in the workplace.
  • Encourage the participation of employee representatives and management in training programmes and seminars on the recognition and management of risks of violence and harassment at work.

2. Information on the rights and obligations of employees and the employer, as well as of persons exercising managerial authority or representing the employer, to the extent and to the extent of their own responsibility, in the event of the occurrence, reporting or denunciation of such incidents, and on the relevant procedure.

In the event that an employee and any person covered by this policy is affected by an incident of violence and harassment during the course of his/her employment relationship, or even if the contract or employment relationship under which the incident or conduct allegedly occurred has ended, he/she has the right to:

  • Judicial protection and compensation claims
  • File a complaint, a grievance and an application for an industrial dispute with the Labour Inspectorate, within the scope of its legal powers,
  • Reporting to the Ombudsman, within the framework of his legal powers, and
  • Complaints within the company, in accordance with the complaint handling policy.
  • The affected person is also entitled, within the framework of the applicable legislation, to leave the workplace for a reasonable period of time without loss of pay or other adverse consequences, if, in his or her opinion, there is a serious risk to life, health or safety, and in particular if the employer is the perpetrator of the violent or harassing conduct, or if he has not taken appropriate measures or if the measures he has taken are not sufficient to stop the violent or harassing conduct against him. Before leaving, the person concerned must have informed the employer in writing of the incident.

The company maintains in a prominent place and hereby informs its staff of the details of the competent administrative authorities, to which every affected person has the right to appeal (labour inspectorate, Citizen's Advocate), and in particular informs about the telephone line for complaints 15512 of the SEPE, the telephone line for citizens' service 1555, the online service for citizens-submission of complaints 1555.gov.gr, as well as the service for immediate psychological support and the service for the submission of counselling for women victims of gender-based violence, who can contact the SOS 15900 line.

3.Designate a contact person ("liaison") to guide and inform employees on how to prevent and deal with violence and harassment at work. His/her role is informative and consists of guiding and informing workers, whether or not they contact him/her in response to an incident or complaint of violence and harassment. Contact with the above reference person (contact person) will be made either in person or by sending an e-mail to the e-mail address: The company as well as the reference person is obliged to protect the Personal Data that comes or may come to his/her knowledge in the performance of his/her role. The reference person is Charis Fytrakis.
4.Protecting employment and supporting workers who are victims of domestic violence:
The company may provide special leave or flexible working arrangements at the request of an employee who is a victim of domestic violence in order to support him/her in maintaining employment and his/her smooth reintegration, especially in cases where there are minor children or children with disabilities or serious illnesses.

6.PROCEDURE FOR RECEIVING AND EXAMINING COMPLAINTS

The employee or any person protected by this policy, who considers that he/she has been harmed due to the occurrence of violence or harassment against him/her, is entitled to submit a written complaint or grievance to the reference person designated by the company Charis Fytrakis, either in person, with proof of receipt, or by sending an e-mail to the e-mail address support@horizon365.com. The complaint must be anonymous and must describe the specific incidents that the complainant considers to constitute violence or harassment. The main concern and purpose of the company is the safe submission of the complaint, as well as protection from malicious complaints.

Upon receipt of the complaint, the reporting person shall inform the aggrieved person of the possibility, at any stage of the procedure to be followed within the undertaking to investigate the complaint, to submit a complaint to the competent administrative authorities within their competence (the Labour Inspectorate and the Ombudsman) and to the judicial authorities, at the same time, at his/her choice.

The company commits that the reporting person will receive the complaint without hindrance, investigate and handle it promptly, with impartiality, objectivity

and respect for human dignity, and the appropriate measures will be taken, at the discretion of the Board of Directors of the company, for the immediate protection of the affected person. The company also undertakes that the investigation of the complaint by all persons involved will be carried out with absolute discretion and confidentiality and that all necessary measures will be taken to protect the personal data collected throughout the process of investigation and evaluation of the complaint.

The reporting person will investigate and evaluate the complaint in cooperation with the heads of the departments to which the complainant and the respondent belong and with the company's Board of Directors, which will ultimately decide on the complaint. The Board may also request legal assistance in the investigation of the complaint.

The reporting person in the investigation of the complaint will communicate in complete confidentiality with both the complainant and the respondent of the complaint. The reporting person, as well as any other person involved in the handling of the complaint, may have access to electronic or non-electronic records of the company, to audiovisual material that may be collected by the company, and to any appropriate means of collecting information and data to establish the merits or otherwise of the complaint. The Board of Directors of the company will always be informed in writing prior to accessing the aforementioned records and media.

The investigation of the complaint is completed as soon as possible and at the latest within one month from the day of the submission of the complaint and the company's management issues its decision on the substantiation or not of conduct that violates the prohibition of violence or harassment, according to article 4 of Law 4808/2021, which it communicates by e-mail or by any other appropriate means to both the complainant and the respondent of the complaint.

In the event that a complaint is substantiated that an employee or other employee of the company violates the prohibition of violent or harassing behaviour, the company will take the necessary and appropriate measures against the complainant in order to prevent similar behaviour from recurring in the future. Indicatively, the company may take the following measures:

-Compliance status,

-Change of job,

-Change of working hours

-Change the way or place of work, if the type of work allows it

-Cancellation of the employment or cooperation relationship, without prejudice to the prohibition of abuse of rights under Article 281 CC.

- Guidance and support for victims of violence and harassment to reintegrate them into the workplace

The company hereby undertakes to comply with the obligation of non-retaliation against persons who have reported behaviours and incidents of violence and harassment against them, in accordance with the provisions of article 13 of Law 4808/2021. Any vindictive behaviour, unfavourable treatment and generally retaliation against the above-mentioned affected persons, as well as victimisation of them, is prohibited, is reprehensible and must be reported to the above-mentioned reporting person, who must immediately investigate the relevant complaint in cooperation with the company's management.

The company, the reporting person and any competent person designated to receive and manage complaints shall cooperate with any competent public, administrative or judicial authority which, either on its own initiative or following a request from an aggrieved person, requests, within its competence, the provision of data or information and undertakes to provide assistance and access to the data. To this end, any data collected and in any form, are kept by the company in a relevant file, (paper and / or electronic file) for the period required by the applicable legislation, subject to the provisions of Law 4624/2019 and Regulation 2016/679 for the protection of natural persons with regard to the processing of their personal data.

7.FINAL PROVISIONS

This policy, as well as any amendment to it or the details of the reference person Charis Fytrakis is posted in a prominent place in the workplace and on the company's website, www.horizon365.com, and is also communicated to employees in paper or electronically. This policy is updated at the discretion of the company, in accordance with the legislation in force at the time.


Last Revision: July 2024