Policy on Preventing and Fighting Discrimination, Violence and Harassment at Work

The purpose of this Policy is to create and consolidate a work environment that respects, promotes and safeguards human dignity and the right of every person to a world of work free of violence and harassment. Through this Policy, a comprehensive, coherent and up to date framework of rules and internal procedures is set to prevent, deal with and combat forms of violence and harassment at work and the internal management of complaints related to these incidents.

The Company provides a healthy and safe working environment for all its employees, recognizing the importance of a work mentality based on mutual respect and human dignity. To ensure a safe working environment and prevent incidents of violence within, all employees of the Company should be aware of and understand the provisions of this Policy.

The Company declares that it shows zero tolerance for incidents of violence and harassment at work and adopts all necessary measures to prevent and eliminate them, in accordance with the terms hereof. The Company, acknowledging the serious responsibility it has as an employer, strictly prohibits any form of discrimination, violence and harassment that occurs during work, whether connected or resulting from it.

The Company takes into account and recognizes that violence and harassment in the world of work affects the psychological, physical and sexual health and dignity of the individual as well as his family and social environment, creating negative consequences on working relationships, employee motivation and productivity.

This Policy applies to all the Company's personnel (hereinafter the ‘Company’) regardless of their contractual status, including those employed under an employment contract, a project, independent services and temporary employment, salaried mandate and those employed through third party service providers, as well as to persons undergoing training, including trainees and apprentices, volunteers, prospective employees, persons exercising the authority, duties and responsibilities of the employer, employees whose employment relationship has been terminated or ended (hereinafter and for the sake of brevity the ‘Employees’).

The Company, through this Policy, undertakes that it has adopted all the measures and obligations related to the implementation of the provisions of Part II of Law 4808/2021 for the prevention and treatment of all forms of violence and harassment in the workplace, including violence and harassment due to gender, and sexual harassment and to this end it applies this Policy, which was drawn up specifically in accordance with articles 9 and 10 of Law 4808/2021.

The Company, as responsible for receiving and managing complaints in accordance with the terms of this Policy, is committed on one hand to maintaining the confidentiality and security of personal data collected during the exercise of its powers, and on the other to comply with the applicable laws and regulations regarding the processing of personal data of natural persons.

2. Legal Framework

The procedures and requirements described in the following sections are governed by and fully comply with the current relevant legal and regulatory framework, in particular with the following, as applicable from time to time:

Law 4808/2021 (Government Gazette A 101/19.6.2021) "For the Protection of Labor – Establishment of the Independent Authority of ‘Labor Inspection’ – Ratification of Convention 190 of the International Labor Organization for the elimination of violence and harassment in the world of work – Ratification of Convention 187 of the International Labor Organization on the Framework for the Promotion of Safety and Health at Work – Incorporation of Directive (EU) 2019/1158 of the European Parliament and of the Council of 20 June 2019 on work-life balance, other provisions of the Ministry of Labor and Social Affairs and other urgent regulations", in particular articles 9, 10, 11 and 12.
Law 4604/2019 (Government Gazette A' 50/26.03.2019) "Promotion of substantive gender equality, prevention and combating of gender-based violence – Arrangements for the granting of Citizenship – Provisions related to Local Government elections – Other provisions".
Law 3896/2010 (Government Gazette A' 207/08.12.2010) "Implementation of the principle of equal opportunities and equal treatment of men and women in matters of work and employment – Harmonization of existing legislation with Directive 2006/54/EC of the European Parliament and the Council, of 5 July 2006 and other relevant provisions".
Law 4531/2018 (Government Gazette A' 62/05.04.2018) "I) Ratification of the Council of Europe Convention on the Prevention and Combating of Violence against Women and Domestic Violence and adaptation of Greek legislation, II) Incorporation of the framework decision 2005/214/JHA, as amended by the framework decision 2009/299/JHA, regarding the application of the principle of mutual recognition on financial penalties and III) Other provisions of the competence of the Ministry of Justice, Transparency and Human Rights and others provisions."
Law 4601/2019 (Government Gazette A’ 95/11.06.2019) "Ratification of the Criminal Code", in particular art. 308 et seq. ("Crimes against bodily integrity") and 337 ("Insult to sexual dignity").
Law 4443/2016 (Government Gazette A’ 232/9.12.2016) "Incorporation of Directive 2000/43/EC on the implementation of equal treatment principle of persons regardless of their racial or ethnic origin, Directive 2000/78/EC on the formulation of general framework for equal treatment in employment and work and Directive 2014/54/EU on measures that facilitate the exercise of employees' rights in the context of the free movement of employees, II) taking necessary measures to comply with articles 22, 23, 30 , 31 par. 1, 32 and 34 of Regulation 596/2014 on market abuse and the repeal of Directive 2003/6/EC of the European Parliament and of the Council and Commission Directives 2003/124/EC, 2003/125 EC and 2004/72/EC and incorporation of Directive 2014/57/EU on criminal sanctions for market abuse and executive Directive 2015/2392, III) incorporation of Directive 2014/62 on the protection of the Euro and other currencies against counterfeiting through criminal law and for the replacement of the Council's framework decision 2000/383/JHA and IV) Establishment of a National Mechanism for the Investigation of Arbitrariness Incidents in Security Forces and Detention Center Employees, and other decrees”.
Convention 190 of the International Labor Organization "on the Elimination of Violence and Harassment at the Workplace" (ILO).

Furthermore, this Policy is reconciled and supplemented by the Company's regulatory texts, as in force from time to time.

3. Definitions

Based on the current legislation, the following notions are understood as follows:

‘violence and harassment’: forms of conduct, acts, practices or threats thereof, which are intended, lead or are likely to result in physical, psychological, sexual or financial harm, whether they occur individually or repeatedly.
‘harassment’: forms of conduct, with the purpose or effect of violating the dignity of the person and creating an intimidating, hostile, degrading, humiliating or offensive environment, whether they constitute a form of discrimination or not, including harassment based on gender or other grounds of discrimination
‘gender-based violence and harassment’: forms of conduct related to a person's gender with the purpose or result of violating the dignity of that person and creating an intimidating, hostile, degrading, humiliating or offensive environment according to art. 2 of Law 3896/2010 and par. 2 of Art. 2 of Law 4443/2016. These forms of behavior include the sexual harassment of Law 3896/2010, as well as forms of behavior connected to the sexual orientation, expression, identity or gender characteristics of the person.
‘violence and harassment at work’: a series of unacceptable forms of conduct and practices or threats thereof, whether manifested individually or repeatedly, which aim, lead or are likely to lead to physical, psychological, sexual or economic damage and may take place either during or result from work, in particular: (a) in the Company's workplace, including public and private spaces that constitute workplaces and spaces where Employees provide work, receive remuneration, take a break especially for rest or for food, in areas of personal hygiene and care, changing rooms or accommodation provided by the Company, at corporate or group meetings, conferences and work-related events either at the Company's facilities or outside, or in person, or online or by telephone (b) during travel to and from work, other commuting, travel, training, as well as work-related events and social activities and, (c) during work-related communications, including those made through information and communication technologies and (d) in accommodation provided by the employer.

Harassment includes, but is not limited to, the following:

Visual forms of harassment, e.g. posters, cartoons, comics, photographs or drawings that are derogatory.
Retaliation or intimidation for reporting or threatening to report any of the above forms of harassment or for cooperating with an investigation of a harassment incident.
Verbal harassment, including e.g. abusive comments, insult or accusation.
Physical harassment, including e.g. of physical interference with normal work or movement.

Gender-based and sexual harassment

Gender-based harassment is any form of conduct connected to a person's gender with the purpose or effect of violating that person's dignity and creating an intimidating, hostile, degrading, humiliating or offensive environment. These forms of behavior include sexual harassment, as well as forms of behavior linked to sexual orientation. In specific, sexual harassment is defined as unwanted behavior of a sexual nature, which includes unwanted sexual proposals, requests for sexual favors and any other unwanted physical or verbal act of a sexual nature. For illustration and understanding, examples of sexual harassment are the following:

Offering benefits (e.g. career advancement, promotion bonuses) in exchange for sexual favors.
Retaliating or threatening retaliation after rejecting sexual advances.
Forms of visual behavior such as obscene gestures, display of offensive files, photographs, electronic and printed materials (e.g. e-mails, voice files, etc.) cartoons or any material with obscene or sexual insinuations.
Forms of verbal behavior such as derogatory comments, sexual innuendo, use of explicit language or sexual ‘jokes’, verbal sexual harassment or suggestions, sexual or suggestive comments in conversation, letters, invitations, notes or other comments.
Physical contact such as touching, pinching, gestures of a sexual nature, hitting, pushing, etc.
It is noted that the above acts are indicative and do not constitute an exhaustive and exclusive list of prohibited acts.

‘Competent Authority’: a person designated by the Company who has the authority for the purposes of this Policy to guide and inform Employees on the prevention and treatment of violence and harassment at work, as well as to receive any complaints regarding incidents of violence and harassment at work and make the final decisions on how to combat them. The Human Resources Department of the Company is defined as the competent Authority.

‘complainer’: An employee of the Company, who himself suffered, witnessed or became aware of an incident of violence and harassment at work and/or domestic violence. Complainers are obliged under this Policy to report incidents of violence and harassment at work to the competent Authority.

4. Obligations and rights of Employees

4.1 Obligations of Employees

All Employees are ultimately responsible and accountable for their actions and are expected to at least treat each other with respect and refrain from violent and harassing behaviors at work. More specifically, in the context hereof, the Employees are obliged:

To read, understand and comply with the provisions of this Policy.
To refrain from any form of violence and harassment manifested in the course of work whether related to or resulting from it, including violence and gender-based harassment, and sexual harassment.
To immediately report incidents of violence and harassment at work suffered by them or brought to their attention to the competent Authority, for immediate investigation and appropriate measures taking.
To assist the competent Authority in every possible way for the investigation of reported incidents of violence and harassment at work, if requested.
To be informed by the reference person and the occupational doctor about the possible risks of violence and harassment at work and the relevant prevention and protection measures against them; also, about the applied procedures for investigating and dealing with them in accordance with the provisions of articles 7 and seq. hereof.
The employee or third party who engages in any form of prohibited conduct should be aware that he is solely and fully responsible for his actions.

4.2 Employees’ Rights

In the context herein, all Employees who are affected by an incident of violence and harassment during access to employment or during their employment relationship or even if the contract or employment relationship, under which the incident or the offending behavior allegedly occurred, has ended, have the following rights:

Demand a safe and healthy working environment where they are respected, and their dignity is not compromised.
To report to the competent Authority, in accordance with the provisions of articles 8 seq. hereof, demanding the observance of relative confidentiality, incidents of violence and/or harassment at work, which they themselves have suffered or witnessed or have otherwise come to their attention, providing any data and information that may be available to them , for the purpose of checking the merits of the complaint and requiring appropriate measures to be taken, such as recommending compliance to the complainee, changing position, hours, place or manner of providing work, etc.
To report to the body responsible for receiving complaints, requiring the observance of confidentiality, incidents of domestic violence that they themselves have suffered or witnessed or that have otherwise come to their attention, as long as these have an impact on their employment relationship and affect their psychological and physical condition.
Demand information related to potential risks of violence and harassment, including sexual harassment at work and the relevant measures to prevent and combat them, from the competent Authority and/or their administrative superiors and the occupational doctor.
In addition to the right to submit an internal complaint for incidents of violence and harassment at work to the competent Authority, in accordance with the procedure described in article 11 hereof, it is recalled that according to the current legal framework the Employee who is the victim of an incident of violence and harassment at work , even if the relationship under which the incident or behavior allegedly occurred against him has ended, he has the rights of article 12 par. 1 of Law 4808/2021, specifically:
(a) the right to claim judicial protection.

(b) the right to appeal before the Labor Inspectorate and the Ombudsman as bodies promoting and supervising the principle of equal treatment, in accordance with Law 3896/2010 and Law 4443/2016.
If the Employee himself is a victim of an incident of violence and harassment at work, he is entitled to leave the workplace temporarily, for a reasonable time, without loss of salary or other adverse consequence, if in his reasonable belief there is an imminent serious risk to his life, health or safety, especially when the measures already taken are not capable of stopping violent and harassing conduct. In this case, the leaver is obliged to inform beforehand and within a reasonable time before his departure, his administrative supervisor and the Human Resources Department, reporting the incident of violence and harassment and the incidents justifying his belief that a serious risk to his life, health or safety is imminent. If the risk has ceased to exist, the Employee returns to his work, while in case he refuses, the Company has the right to appeal to the Labor Inspectorate with a request to resolve the dispute.

5. Obligations and rights of the Company

5.1. Company Obligations

The Company is obliged to:

To ensure a safe and healthy working environment for Employees, demonstrating zero tolerance for incidents of violence and harassment at work.
To receive through the body designated in accordance with article 3 and 11, to investigate and manage every complaint related to incidents of violence and harassment at work with confidentiality and respect for human dignity, as well as not to obstruct the receipt, investigation and management of these complaints. To have access to audio-visual material collected from its archives and other appropriate means for the collection of information and data, when examining the submitted complaints and for the determination of the complainee.
In the event of a conflict of interest between the affected person and the Competent Authority, the affected person may forward the complaint directly to the Company's Management, which in turn will appoint a competent person to investigate the incident.
To provide assistance and access to any competent public, administrative or judicial Authority, if required, during the investigation of such incident or behavior, if requested by them.
To provide the Employees with information related to the possible risks of violence and harassment at work and with the relevant prevention and protection measures, including the obligations and rights of the Employees and the Company regarding such incidents.
To post within the company and make accessible information on the procedures in place at company level, in accordance with the provisions in articles 8 seq. hereof for reporting and dealing with incidents of violence and harassment at work, including sexual harassment, as well as the contact details for the competent administrative and judicial Authorities in accordance with the applicable provisions.
To take the necessary appropriate and reasonable measures on a case-by-case basis against the complainee / reported person in order to prevent and avoid the recurrence of a similar incident or behavior of violence and harassment at work, in accordance with what is defined in article 12 hereof and based on the applicable legislation.
To train its executives to recognize discrimination, violence and harassment at work and to provide the required support to its staff and partners.
To prohibit retaliation against the affected person and any retaliatory behavior or countermeasure for the reported incident.

5.2. Company Rights

The Company is entitled to take any necessary and appropriate measure on a case-by-case basis against the complainee / reported person, in order to prevent and avoid the recurrence of an incident of violence and harassment at work, in accordance with article 12 hereof and based on the provisions of the applicable legislation and regulations texts of the Company and subject to appeal by the complainer to the competent judicial and administrative authorities.

6. Assessing the risks of violence and harassment at work

Risk assessment is the process of evaluating the risks of the use or threat of violence and harassment against employees, arising from existing risks (sources of risk). It is a systematic examination of all aspects of work, which studies:

What could cause violence and harassment in relation to the object / activity of our Company and the work position of the respective employee,
whether or not the sources of risk could be eliminated,
what preventive or protective measures have been or should be adopted to control these risks.

The identification and assessment of the sources of risks takes place through individualized employee criteria surveys, questionnaires, interviews with employee representatives and statistics, as noted in the reports of the European Organization for Safety and Health at Work (EU – OSHA).

The Company is committed to dealing systematically with the causes that may evoke the risks of violence and harassment at work, identifying weak and strong points, as well as ways to combat the risks identified.

The Company states that it conducts a regular assessment of psychosocial risks in order to immediately respond to combating such incidents and to the need for improvements, when required.

The purpose of the Company through this Policy is to:

Identify the sources of risks that appear in the workplace.
To assess the risks associated with these sources.
To define the measures that must be taken to protect the safety and health of employees in the context of compliance with the legal requirements.

The Company believes that such risks stem mainly from gender, age, differences in nationality, religion, professional training, sexual preferences, external appearance and level of professional experience.

Incidents of violence and harassment at work can take in specific the following forms:

As “harassment”, which is defined, inter alia, as an “unjustified conduct” towards an employee, or a group of employees, that causes risks to the health and safety of the individual. In this very definition, “unjustified conduct” is a behavior that the average sensible employee, considering all working conditions, would consider unfavorable treatment, humiliation, undermining or threat. “Conduct” / “behavior” means the actions of individuals or groups that may involve abuse of authority. “Moral harassment” in the workplace is a risk factor that has serious psychological ramifications. In addition, harassment should be viewed as unethical, oppressive behavior and therefore unacceptable in the work environment.
“Workplace psychological intimidation” (‘mobbing’ or ‘bullying’). The term ‘mobbing’ denotes the pressure exerted by a group of employees on one of its members. The term ‘bullying’ denotes a practice that consists of putting employees under constant pressure. It consists of abusive behaviors (gesture, speech, conduct, attitude, etc.) that, by their repetition or systematization, offend the mental or physical integrity of a person, endangering his work or degrading the working enviroment. It may appear in the context of relationships between colleagues or between superior and inferior in the hierarchy.
The Company declares that the following incidents are strictly prohibited, including but not limited to innuendo, mockery, obscene sexual or racist jokes or comments, the use of offensive language, comments about someone’s appearance or character that cause shame or embarrassment, following, stalking and unwanted verbal or physical assault on a person, sending sexually explicit messages or suggestions via SMS, e-mail, social media, fax or letter, offensive and persistent questions about someone's age, marital status, personal life, sexual interests or preferences, as well as similar questions about race or ethnicity of a person, including cultural identity and religion, its exclusion from social events, meetings workgroups; cyberbullying, offensive e-mails, letters and phone calls, sexual gestures or persistent requests for meetings or threats, rude gestures, touching and any kind of unwanted physical contact, spreading malicious comments or insulting someone mainly because of discrimination for age, gender, type of marriage, pregnancy, maternity, any form of disability, sexual preferences, religion or beliefs; verbal or gestural threats, swearing in public or in private, belittling or mocking a person or his abilities, either in front of him or in front of others, having angry outbursts against someone and making persistent and unwarranted criticism.

The above risks are assessed as serious, concern all the Company's staff and have consequences both on the psychological and physical condition of the Employee, victim of the described behavior.

7. Measures to prevent, control, limit, monitor and deal with the risks of violence and harassment at work

The Company, based on its obligations under the current legislation and in accordance with its regulatory texts, takes all the necessary measures to prevent, control, limit and deal with the risks of violence and harassment at work, indicatively by the following ways:

Providing employees with information related to the potential risks of violence and harassment at work and the measures it takes in the event of such incidents.
Providing through the occupational doctor employed by the enterprise, if requested, advice and relevant information to victims of violence and harassment, including sexual harassment, as well as to victims of domestic violence.
Undertaking actions to inform and raise awareness among staff on issues of employee equality, prevention of violence and harassment at work.
Taking into account the suggestions of the Safety Technician, in the context of the latter's advisory authorities regarding the supervision of working conditions. Among other things, the Security Technician examines the technical/building infrastructure of each facility, especially in areas with a high risk of physical and verbal violence also from third parties (e.g. partner reception areas) and proposes measures to address potential risks by rearranging reception areas, operation of emergency exits, installation of emergency notification, training of security personnel, etc.
Encouraging open communication with the management and direct supervisors to resolve and smooth out conflicts and disagreements, while fostering a working climate where respect for human dignity, cooperation and mutual assistance are core values.
Establishing avoidance of excessive workload that leads to stress and burnout – factors that may favor aggressive behaviors.
By ensuring clear roles and duties, securing that employees have the necessary training and information to perform their duties, especially in jobs that intensely test mental endurance.
Encouraging avoidance of solitary work.
Adjusting shifts, taking special needs of employees under consideration (e.g. new mothers, elderly employees, employees with chronic diseases).
Creating Health Promotion Programs: coordinated actions to raise employees' awareness of healthy behavioral patterns (avoidance of addictions, healthy diet, exercise, etc.), but also on workplace policies concerning elderly and young employees, employees with chronic diseases, education / training, etc.), holding seminars with mental health experts, encouraging employees’ participation in them.
Examining, in the context of its corporate social responsibility, and may be accepting sponsorship proposals and support for actions aimed at combating violence and harassment and strengthening equality without discrimination.
Taking the necessary case-by-case measures against those reported for incidents of violence and harassment at work, in accordance with the provisions herein, changing where necessary , indicatively, the communication between employees, the shifts, the working hours, the work position, the responsibilities, the technical infrastructures.
Protecting employment and supporting Employees who are victims of domestic violence, with every appropriate measure or tenable accommodation.
Adopting this Policy and establishing a procedure for internal management of reporting incidents of violence and harassment at work and designating the head of the Human Resources Department as the reference person (‘link’), within the Company, competent to guide and inform Employees about the prevention and treatment of violence and harassment at work, in accordance with articles 8 seq. hereof.
Encouraging and facilitating the complaints’ process, while taking measures for psychological support of the complainers.
Taking measures to protect victims and witnesses from victimization or retaliation.
Evaluating on a regular basis the effectiveness of applied preventive measures and countermeasures with the participation of employees.
Taking measures to revise / update the risk assessment study, when new risks or insufficient preventive measures are identified.
Carrying out actions to inform and raise the awareness of the staff, placing in a visible place the information of the competent administrative authorities, to which every affected person has the right to appeal (Labor Inspectorate, Ombudsman). In this context, the company makes the staff aware of the Labor Inspectorate (SEPE) complaint hotline 15512 and the citizen service hotline 1555, as well as the immediate psychological support and counseling service for female victims of gender-based violence that corresponds to the SOS Line 15900 of the General Secretariat for Family Policy and Gender Equality (GGDOPIF).

8. Management of internal complaints. Procedure for receiving and examining complaints of incidents of violence and harassment at work

The Company implements a procedure for receiving and examining Employee complaints about incidents of violence and harassment at work in an impartial manner that ensures the confidentiality of the information provided and the personal data of the victims, the complainees and possibly of other persons involved, further ensuring the protection of the victim and respect for human dignity, according to the following.

8.1. Basic principles

(a) The Company is committed to the immediate management of the received complaints, to the investigation and examination of the complained, as well as to taking immediate measures to protect the victims.

(b) The Company ensures, through this Policy, the collection and investigation of all evidence and information related to each submitted Employee complaint, with the aim of providing a reasonably substantiated response and adopting the suitable measures to deal with incidents of violence and harassment at work, if required.

(c) The Company secures an environment of trust and safety for all Employees. For this reason, it encourages them to submit complaints in "good faith" about any incidents of violence and harassment at work and/or even domestic violence, which they suffer themselves or that come to their attention, which at the same time constitute illegal criminal acts based on the current legislation and its regulatory provisions. The Company informs the affected person that he/she may, at any stage of the procedure followed within the company also submit a complaint to the competent administrative authorities within their jurisdiction (Labor Inspection and Ombudsman) and to judicial authorities, of his choice.

(d) The anonymity and personal data of the complainers and complainees are protected, while the Company ensures that the present position of the complainers in the Company or their future development is not jeopardized under any circumstances. due to the submitted complaints.

(e) Secure and easily accessible channels of communication for the reception of complaints shall be created, as well as for the identification of competent persons within the enterprise to receive and examine the complaints and to inform the complainers.

(f) Complaints are made based on compliance and observance of the applicable institutional framework on the one hand and the need to safeguard the interests of the Company and its Employees on the other, without any payment promise or the existence of any compensation to the complainer.

(g) Complaints are treated with respect especially to the principles of high regard for personality, human dignity, protection of personal data, trust, transparency and professional conscientiousness and with impartiality. In this context, the Company: (i) investigates complaints diligently, without prejudice and discrimination, (ii) responds without delay and with attention to each complaint, (iii) makes every effort and exhausts every possibility to settle the complaint immediately, (iv) does not dispute with the complainer nor with the complainee, (v) does not retaliate or treat the affected person adversely.

h) Infringements shall require the cooperation and provision of any relevant information to the competent authorities, upon request.

The Company is obliged to cooperate with any competent authority which, either ex officio or following the request by an affected person, and within the framework of its competence, may request the direct provision of details or information. To this end, any data collected, in any form, is kept in a relevant file for five years, in compliance with the provisions of Law 4624/2019 (Α΄137).

8.2. Object of complaints

8.2.1. The submitted complaints concern incidents of violence and harassment at work and/or incidents of domestic violence, whereas these affect or may affect the Employee's mental and physical condition and consequently have a direct impact on his professional performance and development.

8.2.2. The Company encourages Employees to file complaints provided that they have a sincere and reasonable belief that acts of violence or harassment have been committed, are threatened or are likely to be committed, taking into account the general conduct and character of the complainer. The subject matter of the complaints does not cover mere rumors not connected with any fact, evidence or proof.

8.2.3. In case the reported actions are subject to legal procedure, provided for in the applicable legislation, it will be sent to the competent department of the Company for further investigation and relevant handling, based on the applicable regulations in each case.

9. Complainer Anonymity

9.1. The Company encourages, without excluding in advance, named complaints. Anonymous complaints make the task of detailed investigation extremely difficult or even impossible, due to the difficulty of providing evidence from an anonymous complainer (e.g. conversation, meeting to provide clarification during the investigation), but also due to the difficulty of assessing credibility of complaints. Anonymous complaints are investigated taking into account, inter alia, the seriousness of the matter and the likelihood that the complaint will be verified.

9.2. Submitted anonymous complaints are examined according to their level of substantiation.

9.3. The reference in the complaint to sensitive personal data based on the current legal framework (data concerning racial or ethnic origin, political opinions, religious or philosophical beliefs, membership in a trade union, genetic and biometric data, health, sexual life and sexual orientation) should be avoided, unless directly related to the subject matter of the complaint. Otherwise, the specific information will be deleted.

9.4. The Company undertakes to preserve the anonymity of the complainer and not to carry out actions that may result in the disclosure of his identity. However, disclosure of the identity of the complainer may be required by court or legal process, as part of the investigation of the case.

10. Protection of the complainer and of the complainee

10.1. Complaints must be made in "good faith". The Company undertakes to protect its Employees, who have filed a complaint in good faith, from:

i. any acts of retaliation regarding their current position and future career development. It is noted that the Company does not tolerate and prohibits any kind of retaliation and further victimization of the affected Employee and will take all appropriate measures for his protection,

ii. any other kind of discrimination or any kind of unfavorable treatment,

iii. targeting actions or behaviors on the part of the competent body for receiving and examining their complaint. Similarly, if the examination of the complaint does not result in proof of the alleged conduct, it is prescribed that there will be no consequences for the person who made the report/complaint in good faith.

10.2. If the complainer participated in the event or act complained of, he is not relieved of his responsibilities, however, his contribution to the detection and investigation of irregularities, omissions or criminal acts will be much appreciated.

10.3. The persons included in the complaints (complainees) have the right to be informed about the complained act and about the persons who have access to the data included in the complaint, in the context of its examination. However, if there is a serious risk that the above notification could hinder the investigation of the case and the collection of the necessary evidence, the notification of the persons concerned by the report/complaint may be postponed until this risk ceases to exist.

11. Competent Authority for Filing Complaints – Procedure for Filing Complaints

The Company appoints the relevant Head of the Human Resources Department as the competent Authority, responsible for the receipt, management and examination of complaints. This body/person must cooperate and provide all relevant information to the competent administrative or judicial authorities, upon request.

The Head of the Human Resources Department declares and guarantees, on the one hand the observance of the confidentiality and security of personal data, which may come to his knowledge during the exercise of his above authority, and on the other hand his compliance with the applicable laws and regulations on the processing of personal data.

11.1. Complaints may:

i. be submitted directly in paper form to the Head of the Human Resources Department.

ii. be sent to the e-mail address policy@uni-pharma.gr

iii. be submitted through the anonymous complaints’ platform, which can be accessed via e-mail.

iv. be sent by post to the Company's headquarters, to the attention of the Head of the Human Resources Department, marked ‘Confidential’.

12. Management, evaluation of complaints

12.1. The Head of the Human Resources Department keeps a file, which contains the following information for each complaint: (i) number, subject, category and origin, (ii) information about the investigation of the complaint, and (iii) final result of the investigation and of actions.

12.2. After receiving the complaint, the Complaints / Reports Evaluation Committee is responsible for examining the complaints, which is formed by the company's Management, especially in view of the specific case (ad hoc) and consists of three (3) employees of the company, who they are neither complainers nor complainees. The Reports Evaluation Committee:

i. Immediately informs the complainer that his complaint has been received by providing him with a relevant acknowledgment of receipt (paper or electronic); also, about the findings of the relevant audit after its completion, if possible, but also during the investigation, if requested by the complainer.

ii. First assesses the seriousness and credibility of the complaint. If the complaint is judged by the Competent Authority to be indeed serious, it informs the Administration within five (5) days. If a complaint is deemed malicious or in bad faith or unsubstantiated, then it is archived, and no further investigation follows, after informing the complainer. The Company may, however, at its discretion, further investigate evidently malicious complaints, both in terms of motives and those involved, so as to restore order by any legal manner and means.

iii. Investigates, if the complaint is considered well-founded, within a reasonable period of time that cannot exceed thirty (30) days and formulates proposals to resolve the issue. Any delay should be adequately justified.

iv. Keeps minutes regarding the results of the investigations conducted on submitted complaints and informs the Company's Board of Directors through reports it submits annually or whenever it deems necessary, regarding all the complaints it has received and managed during the year.

v. To maintain workplace safety and the effectiveness of investigations, the Company may, inter alia, move employees or modify their work hours, while pending the outcome of the investigation. During this period, partial or total access to buildings and/or facilities may not be permitted.

12.3. If the complaint is verified and a violation is determined, the consequences of article 13 hereof will apply. Otherwise, the complaint is archived, and the complainer is informed accordingly.

12.4. If the complaint is related to a person involved in its investigation process or one of these persons has a conflict of interest, then this person will refrain from investigating the complaint and will be replaced after the Company's Management approval.

12.5. The Head of the Human Resources Department (the reference person or "link") informs the Employees regarding this Policy and the related procedures.

13. Consequences upon detection of violations

The finding of any culpable violation of the articles herein and the provisions of the current legislation that prohibit any form of violence and harassment at work, results in characterizing the complainee’s act as a disciplinary offense within the meaning of articles 23, 24 and 25 of the Company's Labor Regulation. This bears the further consequence of initiating the disciplinary procedure provided for in the relevant provisions against the offender and imposing the disciplinary penalties provided for in the Regulation (remark, recommendation, reprimand, fine, even abstention from work). In addition to disciplinary sanctions, there may be a change in the position and working hours, the place or way of providing work, and even termination of the employment contract. Disciplinary proceedings are independent of any criminal proceedings that may be initiated.

In any case, the offender may be subject to criminal or civil liability, in accordance with what is defined in the current legislation.

This policy is applied in parallel with the existing general legislation for the protection of the personality of the employee and does not affect his/her legal rights at the level of civil and criminal legislation, as well as the rights to submit a complaint before the competent authorities.

14. Record keeping

The Company keeps, in the Human Resources Department of the Company, in electronic or paper form, a file with the necessary security specifications, which includes all complaints received, as well as the documents related to each of them, from the time of their submission and for a minimum period of five (5) years from the date each evidence came into its possession, subject to the provisions of Law 4624/2019. This period is necessary for the effective management of complaints and the rational handling of issues raised, including the procedures for assessing and analyzing incidents, with a view to addressing malfunctions and preventing related incidents in the future, especially those regularly repeated. The period of five (5) years is considered absolutely proportionate in regard to the above purposes and coincides with the statutory limitation period for tort claims.

15. Personal Data

15.1. Any processing of personal data under this Policy is carried out in accordance with the relevant national and European legislation on personal data. The data of all parties involved is protected and subject to processing only for the purpose of verifying the validity or not of the specific report/complaint and investigating the specific incident.

15.2. If those included in the complaint are not immediately informed of its content, so as to prevent them from actions that would obstruct the investigation, the reasons for the relative delay should be recorded in writing and the document entered in the case file.

15.3. Only those involved in the management and investigation of the incident may have access to the data included in the complaints for the purposes of investigating or managing the complaints. Also, data contained in complaints may be accessed by individuals included in the complaint, witnesses and anyone else with a legitimate interest. When access is granted, the complainer’s and witnesses’ details are withheld, unless they have given explicit consent, and the report / complaint has been proven malicious.

15.4. The Company takes all necessary technical and organizational measures to protect personal data.

16. Final Provisions

16.1. This Policy is reviewed on an annual basis and revised whenever necessary. The Human Resources Department is responsible for its preparation, supervision, proper implementation and suggestions for its revisions. All questions related to the execution or interpretation of this policy, the advisory guidance on issues related to the prevention and response to workplace violence and harassment should be submitted to the Company's Human Resources Department.

Athens, June 11, 2024

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