Policy against Violence and Harassment at Work

This policy seeks to prevent and address workplace violence and harassment, to provide a zero tolerance statement for incidents and conduct that constitute violence or harassment, and to establish the rights and responsibilities of employees and the Company in receiving and investigating complaints to prevent and address such incidents or conduct.
1. Introduction
The Company is firmly focused on creating and maintaining a work environment in which all employees and partners are treated with dignity, decency and respect. The Company's work environment is characterized by mutual trust and the absence of intimidation, oppression and exploitation. The Company does not tolerate unlawful discrimination or harassment of any kind against employees, customers or partners and, by this policy, declares its firm and non-negotiable commitment to a prompt and effective response to any incident of workplace violence and/or harassment.
2. Scope
This policy is binding on the members of the Board of Directors, the directors and the staff of the Company, regardless of the type of employment contract that binds them to the Company. 
This policy also applies to the Company's contractors under project contracts, independent service contracts, independent contractors, employees of third-party service providers, and individuals participating in training, including interns and trainees, employees whose employment has terminated, and individuals applying for employment, in accordance with applicable law. 
3. Purpose of the Policy
The purpose of this policy is to establish a consistent and up-to-date framework for preventing, addressing, and combating forms of violence and harassing behavior, thereby contributing to the creation of a work environment that respects, promotes, and protects the right of every person to work free from violence and harassment. In addition, this policy regulates the procedure for handling (receiving and reviewing) internal complaints about incidents of violence and harassment in the workplace.
4. Terms and Conditions
Therefore, for the purposes of this policy, the following definitions apply: 
"Violence and Harassment in the Workplace" means conduct, actions, practices, or threats thereof, whether occurring on a one-time basis or repeatedly, that are intended to cause, result in, or are likely to result in physical, psychological, sexual, or economic harm, 
"Harassment" means conduct that has the purpose or effect of violating the dignity of a person and of creating an intimidating, hostile, degrading, humiliating, or offensive environment, whether or not such conduct is a form of discrimination, and includes harassment based on sex or other grounds of discrimination,
"Gender-based violence and harassment" means all forms of violence and harassment that are directed against persons on the basis of their gender or that disproportionately affect persons of a particular gender, and includes sexual harassment. 
"Gender-based harassment" means conduct related to a person's gender that has the purpose or effect of violating that person's dignity and creating an environment of intimidation, hostility, humiliation, degradation, or insult. These behaviours include sexual harassment and behaviour related to a person's sexual orientation, expression, identity, or gender characteristics. 
Violence and harassment in the work environment occur in the course of, are related to, or result from the work: 
i. in the workplace, including public and private places that are workplaces,  
ii. places where the employee is paid, takes a rest or meal break, or uses restrooms or other public places,  
iii. during travel, journeys, training, events or social activities related to work,  
iv. through work-related communications, including those conducted using information and communication technologies, 
v. in accommodation provided by the employer,
vi. while the employee is travelling to and from work, 
vii. in any manner and by any means outside the place and/or time of work, if it takes place between persons who have come into contact with the company as a result of their living together under the same employer or working together.
5. Zero Tolerance Statement
The Company is committed to providing all employees, regardless of the form of employment contract, with a safe environment free from any form of harassment or violence in the workplace, including sexual harassment. The Company has a zero-tolerance policy toward all incidents of workplace violence and harassment, handles all incidents responsibly, and promptly investigates all allegations of violence and harassment. If an employee is found guilty of violence or harassment of an employee, potential employee, contractor or partner of the Company, such conduct will not be tolerated and will result in appropriate consequences as described below. All complaints about incidents of violence and harassment will be taken seriously and treated with respect and fairness. 
Anyone who complains to the Company about incidents of violence or harassment will not be discriminated against in any way on this basis.
All employees, regardless of the type of employment contract under which they are employed by the Company, are expected to take reasonable precautions to ensure that they do not engage in any form of prohibited conduct. 
The Company will ensure that all appropriate action is taken against anyone who violates this policy. Depending on the seriousness of the misconduct, the Company will take all necessary measures or, if deemed necessary, even proceed to termination in cases of prohibited conduct. Company officers who knowingly permit or tolerate discrimination, harassment or retaliation, including failure to report such incidents directly to management, are in violation of this policy and subject to Company scrutiny.
6. Commitments to Prevent and Respond to Violence and Harassment 
All parties bound by this policy are responsible for its implementation, specifically: 
- maintaining a work environment free from violence and harassment,
- reporting all incidents of violence or harassment of which they become, 
- aware and cooperating fully at all times in the investigation of complaints of violence or harassment.
Company leaders are responsible for:
- promptly and impartially responding to all allegations of violence or harassment,  
- promptly addressing conduct that could lead to an incident of violence or harassment.
The Company is responsible for: 
- taking all reasonable steps to ensure that no employee is subjected to violence or harassment in the workplace,
- implementing measures to prevent violence and harassment, training 
- company personnel to recognise and respond to incidents of violence and harassment, 
- establishing the procedure for reporting and investigating incidents of violence and harassment, 
- identifying the source of the harassment and ensuring that it is stopped, 
- taking repressive and/or deterrent measures against anyone who commits violence or harassment,  
- taking all necessary and appropriate measures to eliminate the consequences of violence or harassment and prevent future occurrences, 
- continuously informing and raising awareness among staff. 
7. Indicative cases of violence and harassment 
For illustrative purposes and by no means as a limitation, some common cases of violence and harassment are mentioned: 
- Dissemination or mere display of offensive or obscene material.
- Insinuations, ridicule, mockery, vulgar language, jokes or comments based on or motivated by race and/or sexual orientation.
- Use of offensive language or tone or mockery of people with disabilities.
- Comments about appearance, manner of speaking, or other characteristics that are embarrassing or cause shame.
- Unwanted attention, such as unwanted off-duty calls or messages or letters or social media reports or stalking or stalking.
- Arbitrary and persistent questions about a person's age, marital status, personal life, sexual interests or preferences, and similar questions about a person's race or ethnicity, including cultural identity and religion. 
- Rude gestures or unwanted physical contact or persistent 'suggestions' of dates or threats if not accepted.
- Dissemination of malicious comments and/or insults (especially for discrimination based on age, race, sex, type of marriage, civil partnership, pregnancy and maternity, gender, any disability, sexual preference, political, religious or political beliefs).
- Physical violence, including sexual assault.
- Verbal and/or gestural threats, such as yelling at or insulting - in public or in private - co-workers or colleagues, accompanied by derogatory or stereotypical language and/or comments.
- Personal insults.
- Belittling or ridiculing a person and/or their abilities either personally or in front of others.
- Angry outbursts against someone and/or a group.
- Unjustified criticism.
- Expressing unreasonable demands.
- Unjustified exclusion of anyone from company events, work group meetings, discussions, and joint decisions or planning.
- Threats or inappropriate comments about an employee's ability to advance.
They are not a nuisance:
- Justified actions taken by Company employees and agents within the scope of their duties to transfer, demote, exercise disciplinary authority, give advice, direction or instruction, or discharge an employee of the Company without violating the rules of decency.
- Decisions by the Company or its officers, based on reasonable and supportable reasons, not to promote, transfer or grant an employee a benefit related to his or her work. 
- Any justified and reasonable action taken by the Company and its managers that does not violate the rules of decency, as regards the place, time, manner of work or employment of employees, and that is related to the work of the employee, within the exercise of the right of direction.
8. Effects of violence and harassment in the workplace (risk assessment) 
i) For employees - victims of violence and harassment 
- Anxiety, sleep disorders, post-traumatic stress syndrome 
- Inability to work, loss of self-esteem and self-confidence.
- Feeling of social isolation at work.
- Physical stress symptoms such as headaches, back pain, stomach cramps.
- Panic attacks, severe fatigue. 
- Deterioration of personal relationships.
- Depression.
ii) For the Company
- Increased staff turnover, cost of training new employees.
- Disruption of work climate and relationships between colleagues.
- Unsafe and hostile work environment. 
- Bad publicity, poor public image, loss of public trust. 
9. Measures to prevent and respond to violence and harassment 
The Company will, under this policy and in accordance with the procedure set forth in this policy: 
(a) receive, investigate and respond to complaints by demonstrating zero tolerance for violence and harassment, in a confidential manner and in a manner that respects human dignity, 
(b) assist and provide access to any appropriate agency, administration, or court in the investigation of such incident or conduct when requested, 
(c) inform employees of the potential risks of violence and harassment in the workplace and of the appropriate prevention and protection measures, including the obligations and rights of employees and the employer in the event of such incidents, 
(d) distribute a physical copy of this policy and the procedure for reporting and dealing with such conduct, as well as the contact information for the relevant administrative and judicial authorities, in accordance with applicable regulations.
The competent judicial and administrative authorities in this respect are the locally competent courts (https://www.ministryofjustice.gr/?page_id=895, the locally competent services of the Labour Inspectorate ((https://www.sepenet.gr/liferayportal/documents/20181/0/SEPE+email+phones+catalog+23072019.pdf/ad017663-9ec4-4307-a52b-fad4064b23e3) and the Ombudsman (https://www.synigoros-solidarity.gr/sxetika-epikoinonia).
10. Ensure that there are no adverse consequences for individuals who report conduct that constitutes violence or harassment
The Company expressly and unequivocally assures that individuals who intend to file a complaint in connection with this policy will not suffer any adverse consequences. No action will be taken against an individual who files a complaint in good faith, even if the allegations are not substantiated as a result of a full investigation. Victimization, harassment, intimidation or any other adverse treatment in retaliation against an individual who has filed a complaint under this policy will not be tolerated by the Company under any circumstances. 
Unacceptable retaliation includes, but is not limited to, the following: 
- Termination of an employment contract. 
- Non-renewal of a fixed-term employment contract. 
- Arbitrary transfer of the complainant to another job as a means of addressing the incident complained of or unjustified denial of a transfer requested by the complainant. 
- Unreasonable restriction or expansion of the complainant's duties or an unfavorable change in the complainant's scope of work.
- Denial of opportunities and training. 
- Arbitrary exclusion from company benefits. 
- Verbal or written harassment or intimidation. 
If the complainant believes that he or she is being subjected to retaliation for filing a complaint under this policy, he or she should immediately notify the Complaint Officer (see paragraph 12), who should then initiate the process described in this policy to investigate the complaint. The Company will take all necessary steps to restore the work environment of an employee, partner or contractor who is found to have been subjected to retaliation of any kind.
This also applies to employees who testify as witnesses in the appropriate complaint review proceedings and to investigators in those proceedings.
11. Ensure Confidentiality
All complaints and investigations will be kept confidential to the extent possible, and information will be shared strictly and only on a need-to-know basis. It should be noted that disclosure of the identity of the complainant may be requested by a court or other authority as part of the investigation of the case. The identity of the complainant will normally be disclosed to the parties involved during the investigation, and the Complaint Manager (see paragraph 12) will take appropriate steps to ensure that the complainant is protected from retaliation during and after the investigation. All information relating to a complaint or investigation under this policy will be kept in secure files in the Company's Human Resources Department. The storage and processing of personal data will be carried out in accordance with the applicable legislation on the protection of personal data. 
12. Procedure for reporting violence or harassment
A person subjected to violence or harassment should, if possible, inform the alleged harasser in writing or verbally that the behavior is unwelcome and unacceptable. 
The Company recognizes that violence and harassment may occur in unequal relationships (e.g., between a supervisor and his or her subordinate) and that it may not be possible for the harasser to inform the alleged harasser. If the harassed person cannot reach the alleged harasser directly, he or she may contact the Complaint Manager to file a complaint. 
Complaints will be forwarded to the Complaint Manager, whose duties are assigned to Human Resources Manager.
Upon receipt of the complaint, the complaint manager:
- Immediately records the dates, times, and details of the incident.
- Inquires as to the views of the harasser as to the result sought.
- Ensures that the harasser understands the company's procedures for handling the complaint.
- Discuss and agree on next steps: Inform the harasser that the decision to settle the matter informally does not prevent them from filing a formal complaint if they are not satisfied with the outcome.
- Keeps a confidential record of all conversations
- Respects the choices of the person being harassed.
- Ensures that the harassed person knows that he or she can take his or her complaint outside the company to the appropriate administrative or judicial authorities.
12.1 Informal complaint procedure 
If the person being harassed wishes to resolve the matter informally, the grievance manager may:
- Give the alleged harasser an opportunity to respond to the complaint.
- Make sure the alleged harasser understands the reporting mechanism.
- Facilitate communication between the two parties to find an informal solution acceptable to the complainant or refer the matter to a mediator within the company (Food Quality and Safety  Manager). 
- Ensure that confidential and secret records are kept.
- Monitor the outcome of the process to ensure that the unacceptable behaviour has been stopped. 
- Ensure that all of the above steps are completed within 10 business days of filing the complaint.
12.2 Formal complaint procedure
Once a formal complaint has been filed, the following investigation procedure will be followed: 
The Grievance Manager 
- shall acknowledge receipt of the grievance to the grievant on the same or next business day after receipt. 
He shall inform the Complaint Review Committee, composed of himself, Production Manager and Imports/Exports Administrator, of the content of the complaint.
The Complaint Review Committee shall first consider whether the complaint falls within the scope of this policy and whether the complaint is admissible or clearly unfounded. 
If the grievance is denied, the grievant will be notified in writing of the reasons within ten (10) working days of the filing of the grievance; this applies to cases where: 
- The acts alleged do not fall within the definition of infringement.
- The complaint does not contain sufficient information to substantiate the allegation.
After this initial review, the Complaint Review Committee shall investigate the complaint. If the complaint is against a member of the Complaint Review Committee or if a member of the Committee has a conflict of interest, that member shall not participate in the investigation of the complaint in question and shall be replaced on an ad hoc basis by a person appointed by management. 
The Complaint Review Committee shall decide on the merits or otherwise of the complaint under investigation and recommend appropriate remedial action to the Chairman of the Company's Board of Directors to enable him to make the necessary decisions. Decisions of the Appeals Board shall be reasoned and shall be made by majority vote.  
The appellant:
- may be invited to attend a committee meeting in the context of the particular investigation. 
- will be informed in an appropriate manner of the progress and outcome of the investigation no later than 15 days after receipt of his/her complaint, taking into account, in particular, any legal obligations of confidentiality. 
12.3 Mitigation measures
If violence or harassment as defined in this policy is confirmed, the following actions will be taken as appropriate: 
- verbal or written recommendation or reprimand, change of position, work  
- schedule, work location or work method, termination of employment or   
- cooperation,
The choice of appropriate response will depend on the severity and extent of the harassment. Appropriate and proportionate repressive and/or deterrent measures will be taken to ensure that incidents of violence or harassment are treated as extremely serious. In certain serious cases, including physical violence, employment or cooperation with the harasser will be terminated immediately.
Details of any repressive or deterrent action taken by the Company against the alleged harasser may be provided to the complainant if deemed appropriate by the Complaint Review Committee. 
12.4 Dissatisfaction with the result of the investigation of the complaint.
If the complainant is not satisfied with the outcome of the investigation, he or she may appeal to the Chief Executive Officer of the Company, stating the reasons for his or her dissatisfaction. The Chief Executive Officer, or a person authorised by the Chief Executive Officer, shall respond in writing informing him/her of the acceptance or rejection of a request for further investigation of the complaint. 
13. Exercise of other rights 
Nothing herein is intended or shall be construed to prevent or preclude any complainant from exercising hisor her rights in accordance with applicable law and seeking judicial or non-judicial redress from the competent administrative or judicial authorities. 
The competent judicial and administrative authorities are the courts with local jurisdiction (see exact address and telephone numbers: https://www.ministryofjustice.gr/?page_id=895), the locally competent departments of the Labour Inspectorate (see detailed addresses and telephone numbers : https://www.sepenet.gr/liferayportal/documents/20181/0/SEPE+email+phones+catalog+23072019.pdf/ad017663-9ec4-4307-a52b-fad4064b23e3) and the services of the Ombudsman (https://www.synigoros-solidarity.gr/sxetika-epikoinonia).
14. Staff awareness and sensitization. 
Company employees will receive appropriate information and training to ensure that they are fully aware of the unintended consequences of violence or harassment, their rights and responsibilities under this policy, and the Company's procedures for reporting such incidents.
The Company will ensure that this policy and its amendments are communicated to all persons to whom it applies and that its contents are included in the Work Rules when they are updated. 
15. Effects of a breach of the policy  
The Company reserves the right to take appropriate action against its employees or affiliates if it appears or is determined that an individual who has filed a complaint under this policy has been subjected to any form of discriminatory treatment. The same procedure may also be followed if an employee or associate of the Company intentionally misleads the Company regarding a matter under investigation under this Policy or makes false allegations against another employee, contractor or associate of the Company. 
16. Policy monitoring and evaluation 
The Company recognizes the importance of monitoring the results of this policy and will ensure that anonymized statistics and data are collected on its implementation and effectiveness. The Company's department heads will work with the Human Resources Department to prepare an annual report on compliance with this policy, which will include the number and type of incidents, how they were handled, and the actions taken. Based on this report, the Company will evaluate the effectiveness of this policy and make adjustments as necessary. The annual report will be communicated to all personnel.
17. Roles and responsibilities
Α. Board of Directors 
Approves policies and their amendments.
Β. Complaint Management Officer 
Is responsible for carrying out all the steps provided for in the Complaint Management Procedure.
C. Complaint Review Committee 
- Investigates whether the complaint falls within the scope of this policy.
- Investigates the complaint.
- Decides on the merits of the complaint under investigation and recommends appropriate remedial action to the Chief Executive Officer of the Company for appropriate action to be taken. 
D. Complainant 
- He/she shall report incidents of violence or harassment, provide all information available to him/her, and cooperate with the Grievance Manager and the Grievance Evaluation Committee in the investigation of his/her complaint.
- He/she shall report to the CEO if he/she is not satisfied with the outcome of the investigation of his/her complaint.
- Decides on the appropriate response actions. 
- Responds in writing and informs the complainant of the acceptance or rejection of his/her request to further investigate the complaint in the event that the complainant is not satisfied with the outcome of the investigation and addresses it to him/her.
F.  Executive Directors 
Company leaders are responsible for:
- promptly and impartially responding to all allegations of violence or harassment, 
- promptly addressing conduct that could lead to an incident of violence or harassment.
- Providing all information required during the investigation of a complaint to both the complaint manager and the complaint evaluation committee and/or CEO.