1838

Policy on prevention of Violence and Harassment at Work and for the Management of Internal Complains

1. Introduction

Our company «EVERTECH KATASKEUASTIKI MONOPROSOPI IDIOTIKI KEFALAIOUCHIKI ETAIREIA», which has its registered office in Athens, at 20 Kanari St., with general commercial registry number («Evertech») complies with all measures and obligations concerning the implementation of the provisions of Part II of Law 4808/2021 on the prevention and combating of all forms of violence and harassment, including gender-based violence and harassment as well as sexual harassment.

2. Purpose

The purpose of this policy is to create and establish a working environment which respects, promotes, and safeguards human dignity and every person’s right to a workplace free from violence and harassment. The company states that it acknowledges and respects the right of every employee to a workplace free from violence and harassment and declares that it will not tolerate any such conduct, of any form, by any person.

3. Scope of application

This policy is adopted in accordance with Articles 9 and 10 of Law 4808/2021 and the relevant implementing regulations and it applies to the persons listed in Article 3(1) of Law 4808/2021. In particular, it covers employees and workers, regardless of contractual status, including those engaged under contracts for work, independent services, and mandate, those employed through third-party service providers, trainees and apprentices, former employees, as well as job applicants.

4. Definitions – Prohibited Forms of Conduct

· Violence and Harassment

“Violence and harassment” means behaviours, acts, practices, or threats thereof, that are intended, result in, or are likely to result in physical, psychological, sexual, or economic harm, whether occurring as isolated incidents or repeatedly.

  • Harassment
    “Harassment” means behaviours that aim at or result in the violation of a person’s dignity and the creation of an intimidating, hostile, degrading, humiliating, or offensive environment, regardless of whether they constitute a form of discrimination, and include harassment on the grounds of sex or other discriminatory grounds.
  • Gender-based Harassment
    “Gender-based harassment” means behaviours related to a person’s sex which aim at or result in the violation of that person’s dignity and the creation of an intimidating, hostile, degrading, humiliating, or offensive environment, in accordance with Article 2 of Law 3896/2010 and Article 2(2) of Law 4443/2016. These behaviours also include sexual harassment under Law 3896/2010, as well as behaviours related to sexual orientation, gender expression, gender identity, or sex characteristics.
  • Discrimination
    “Discrimination” means discrimination based on sex, race, colour, ethnic or social origin, genetic characteristics, language, religion or beliefs, political opinions, disability or health status, age, or sexual orientation.
4. Zero tolerance statement

Evertech declares its zero tolerance for any incidents of violence, harassment, or discrimination and undertakes to address and eliminate such incidents in the workplace, ensuring an environment of respect for human dignity. Therefore, it is expressly prohibited for any form of discrimination, violence, or harassment to occur during, in connection with, or as a result of employment.

To this end, Evetech commits to receiving, investigating, and managing every complaint with confidentiality and respect for human dignity.

5. Policy on the prevention and combating of violence and harassment at work
5.1 Work violence and harassment risk assessment

Behaviours associated with violence and harassment at work and strictly prohibited under this policy may include, indicatively:

  • Verbal harassment: e.g. insulting, malicious, or derogatory comments; sexual innuendos or jokes; racist or sexist remarks; persistent or unjustified criticism
  • Physical harassment: e.g. physical interference with movement or work; gestures; any unwanted physical contact; stalking or surveillance and pursuit.
  • Visual/psychological harassment: cyberbullying; sending offensive or sexual content via SMS, email, or social media, etc.
  • Discriminatory insults: based on sex, race, religion, appearance, sexual orientation, disability, age, or other personal characteristics or choices.
  • Comments on appearance or character that cause shame or embarrassment or
  • Retaliation or intimidation in cases of reporting or threatening to report harassment or violence or harassment committed in any way.

Evertech, acknowledges these risks and has consistently worked towards preventing and eliminating any incidents of violence, harassment, or discrimination, making it a primary goal to ensure a workplace that respects human dignity and employee rights.

5.2 Measures to prevent, control, limit, and address these risks and to monitor such incidents or forms of behavior

Evertech undertakes appropriate measures and administrative practices to prevent, control, limit, and address risks of violence and harassment and to monitor such incidents or forms of behaviour. Indicatively, Evertech:

(a) It encourages its employees and executives to maintain a working environment where respect for human dignity, cooperation, and mutual assistance are core values.

(b) Ensures open and unhindered communication between employees and their immediate supervisors and all company executives.

(c) A specific procedure for handling reports and complaints is followed, as described below.

(d) Ensures that employees have the necessary training and information to perform their duties, particularly in jobs that are more prone to incidents of violence and harassment.

(e) Adopts technical measures, such as ensuring the effective operation of lighting in work areas, entrances/exits, etc., monitoring and fencing off entrances/exits and any other isolated areas of the facilities in order to enhance the sense of security.

(f) Takes action to raise employee awareness of healthy behaviour patterns and issues affecting vulnerable groups of employees.

(g) Provides appropriate training to employees on how to deal with and manage incidents of violence and harassment.

(h) Regularly assesses the effectiveness of the preventive and response measures implemented and may review/update the risk assessment and measures.

(i) It oversees the implementation of this policy and trains its managers and executives to recognize discrimination, violence, and harassment in the workplace and to provide the necessary support to staff where needed.

5.3 Actions of informing and awareness-raising of the personnel

Evertech is committed to providing its personnel with information and awareness-raising activities on the risks of violence and harassment, as well as on the prevention and protection measures it takes from time to time. In this context, it takes all necessary measures to inform and raise awareness among staff, using appropriate means (e.g., printed and electronic material, etc.) to combat violence and harassment and ensures that everyone is aware of the company's policy and procedures in such cases. In addition, it ensures that all employees know who they should contact in the event of violence or harassment.

Within the framework of its personnel raising-awareness programme, Evertech may:

- Organize targeted staff meetings to discuss relevant issues and address potential risks in a timely manner.

- Hold seminars with mental health specialists or counseling service providers, representatives of voluntary organizations, etc.

- Encourage employee representatives and management executives to participate in training programs and educational seminars on recognizing and managing risks of violence and harassment at work.

5.4 Information on the rights and obligations of employees and employers
5.4.1 Rights of the affected party

In the event that an employee of the company is affected by an incident of violence and harassment during their employment relationship, or even if the contract or employment relationship in the context of which the incident or behavior allegedly occurred has ended, they have:

(a) the right to judicial protection,

(b) the right to appeal, file a complaint, and request the Labour Inspectorate to conduct a labor dispute investigation, within the scope of its legal powers,

(c) the right to report the incident to the Ombudsman, within the scope of its legal powers, and

(d) the right to file a complaint within the company in accordance with the complaint management policy as set out below.

In any event, when such behaviour is reported or complaint has been filed about it within the company, the affected party reserves all rights to appeal to any competent authority.

5.4.2 Contact details of competent authorities

In particular, the details of the competent administrative authorities to which any affected person has the right to appeal are as follows:

  • Labour Ispectorate (LI)
    Phone line LI: 1555
    Submission of online complaint through the website:
    www.sepe.gov.gr
  • Ombudsman
    Instructions for submitting a report:
    https://www.synigoros.gr/?i=submission-system.el
  • SOS Land Line
    Immediate psychological support and counseling service for women victims of gender-based violence, contact the SOS line: 15900.

5.4.3 Consequences of non-compliance

When an employee or a person occupied under another relationship in the Company violates the policy prohibiting violence and harassment described herein and in the law, the Company commits to take the necessary, suitable and proportionate measures, as the case may be, against the reported person, in order to prevent and not allow a similar incident or behaviour to recur.

These measures may include a recommendation for compliance, change of position, working hours, place or manner of providing work, or termination of the employment or cooperation agreement, subject to the prohibition of abuse of right of Article 281 of the Civil Code.

In addition, any person to whom this applies and who is subjected to violence and harassment has the right to leave the workplace for a reasonable period of time, without loss of pay or other adverse consequences, if they reasonably believe that there is an imminent serious risk to their life, health, or safety, especially when the employer is the perpetrator of such behaviour or when they do not take the necessary appropriate measures as above to restore peace in the workplace, or when these measures are not sufficient to stop the violent and harassing behaviour.

In this event, the person leaving is required to notify the company in writing in advance, stating the incident of violence and harassment and the circumstances that justify their belief that there is a serious risk to their life, health, or safety. If the danger does not exist or has ceased to exist and the person refuses to return to the workplace, the company may appeal to the Labour Inspectorate with a request to resolve the dispute. In this case, Article 18 of Law 4808/2021 applies.

Violation of the prohibition of violence and harassment under this policy and the law gives rise, among other things, to a claim for full compensation for the affected party, covering actual and consequential damages, as well as moral damages. In any event, all consequences and/or penalties provided for in Law 4808/2021 and any other applicable legal provisions shall apply.

5.4.4 Procedure for reporting or filing a complaint about incidents of violence

Evertech implements a specific procedure for reporting or complaining about incidents of violence and harassment, which is described below in Chapter 6.

5.5 Appointment of contact person

Anna Vamialis has been appointed as contact person (liaison) in charge of guiding and informing employees about preventing and dealing with violence and harassment at work. Tel. number: 210-9901501, e-mail address:
anna@evertech.gr.

Her role is informational and lies in guiding and informing employees, regardless of whether they approach her on the occasion of some incident of violence and harassment or a relevant complaint. Access of employees to her is open, easy, immediate and for this reason the following channels/means of communication with her are provided.

5.6 Protection and support for employees who are victims of domestic violence

Evertech declares its unconditional support for its employees facing domestic violence. For this reason, it ensures the protection of employment and support for employees who are victims of domestic violence, as far as possible, by any appropriate means or reasonable accommodation. In particular, the company demonstrates its support for the above category of employees by providing flexible working arrangements at the request of employees who are victims of domestic violence, in order to support them in keeping their job and smoothly reintegrating after such incidents, especially in cases where there are minor children or children with disabilities or serious illnesses.

6. Policy on receiving, examining, and handling complaints

Evertech encourages its employees and anyone connected in any way with the company to immediately report any incidents of discrimination, violence, and harassment in the workplace that they happen to witness and is committed to handling any reports with complete confidentiality and discretion. The company will receive and investigate every report and complaint, showing zero tolerance for discrimination, violence, and harassment, with respect for human dignity.

This policy is put into effect for the greater protection of the employee and in no case does it affect or prejudice his/her lawful rights at civil and criminal level and/or the rights of complaint to any competent authority or court.

However, for the protection of all employees, it is clarified that complaints which are proven to be manifestly malicious will not be allowed, will be considered inadmissible and will be further investigated at the Company’s discretion, both as to the motives and as to the persons involved, to ensure fair treatment of all employees.

6.1 Communication channels – appointed persons

As mentioned above, the person appointed for receiving, examining, handling complaints, and informing complainants is Ms Anna Vamialis

Ms Anna Vamialis is always available and any employee can contact her either in person or by telephone at 210-9901501, or by sending an email to anna@evertech.gr, or by any other appropriate means. She will handle any reports or complaints with absolute confidentiality and discretion and will inform the affected party of their option at any stage of the procedure followed within the company, to also file a complaint with the competent administrative authorities within their jurisdiction, i.e. the Labour Inspectorate and the Ombudsman, as well as with the judicial authorities.

6.2 Investigation and examination of complaints

The company and the competent person are committed to receiving, investigating, and handling any such complaint immediately, investigating and examining the allegations impartially and with respect for human dignity, and to take immediate measures to protect the affected person. In any event, it is a self-evident commitment of our company and the designated responsible person to maintain confidentiality and protect Personal Data (PD) collected in the exercise of the above duties.

An affected person has the right to submit a formal complaint to the company by letter or by email to anna@evertech.gr. As soon as the company receives the complaint, it will assess it and record the nature of the violence or harassment and collect all the necessary information about the incident.

At this stage, the company will make initial contact with the complainant, assuring them of absolute discretion and confidentiality, in order to discuss together the most appropriate and desirable way to handle the incident. Depending on the nature and characteristics of the incident, various ways of managing and resolving it may be chosen, such as:

· mediation between the parties involved,

· imposition of consequences in the event that an incident of violence or harassment as described below is indeed substantiated,

· referral to the company's legal department, etc.

In any case, the method of handling should always be determined based on the specific characteristics and severity of the reported incident.

6.3 Prohibition of retaliation against the affected party

The company is committed to comply with the prohibition of retaliation, in accordance with Article 13 of Law 4808/2021 and the provisions of labour law. In particular, it is prohibited to take retaliatory measures against or victimise the complainant who, as the affected party, asserted their rights and submitted a written complaint regarding an incident of violence or harassment. In this context, it is prohibited and invalid to terminate or in any way dissolve the legal relationship on which the employment is based, as well as any other unfavourable treatment of a person to whom this policy applies, if it constitutes retaliatory behaviour or countermeasures within the meaning of Article 14 of Law 3896/2010 for incidents of violence and harassment under this policy and Article 4 of Law 4808/2021.

6.4 Consequences upon finding a violation

If, following an investigation of the reported incident, it is found that an incident of discrimination, violence, harassment, or retaliation did indeed take place, as mentioned above in Section 5.4.3, the company undertakes to take the necessary appropriate and proportionate measures against the accused, as appropriate, in order to prevent and avoid the recurrence of similar incidents or behaviour.

These measures may include a compliance recommendation, a change of position, working hours, place or type of work, or termination of the employment or contractual relationship, subject to the prohibition of abuse of rights under Article 281 of the Civil Code.

6.5 Co-operation with the competent authorities

In any case, the company, as well as any person within the company responsible for receiving and handling complaints at the company level, shall cooperate with any competent public, administrative or judicial authority which, either on its own initiative or upon request by an affected person, within the scope of its competence, requests the provision of data or information, and undertakes to provide assistance and access to such data. To this end, any data collected, in any form, shall be kept in a relevant file in accordance with the provisions of Law 4624/2019.

7. Employees’ views and communication

The Company ensures that this policy is updated and revised whenever it deems it necessary and is always at the disposal of its employees to listen to their proposals and views regarding this policy and the applicable procedures. To this end, all employees and the persons to whom this applies can at any time communicate with the designated reference person, that is, Ms Anna Vamiali, tel: 210-9901501, email:
anna@evertech.gr, with who they may discussion their opinion in terms of this policy.

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