Company policy against violence and harassment

Definitions:

Violence and Harassment

The term " Violence and Harassment” refers to various forms of unwanted behavior, acts, or threats that may cause physical, psychological, sexual, or financial harm.

This can happen either once or repeatedly.

Harassment also includes behavior that offends a person's dignity, creating an intimidating or degrading environment, and may include instances of behavior based on gender or other forms of discrimination.

In particular, this can include verbal harassment such as abusive comments, physical harassment such as physically preventing someone from normal work or movement, visual forms of harassment such as posters or drawings with derogatory content, and intimidation or retaliation for reporting or participating in research incident of harassment.

Gender Harassment & Sexual Harassment

“Gender based harassment” refers to behaviors related to one's gender that lead to the violation of one's dignity, creating a hostile or aggressive environment. This includes the “sexual harassment”, meaning unwanted behaviors of a sexual nature, such as unwanted sexual advances, requests for sexual favors, or other unwanted physical or verbal acts of a sexual nature.

These behaviors may include, but are not limited to, offering work privileges in exchange for sexual favors, retaliating after sexual advances are rejected, sexually suggestive visual and verbal behaviors, and unwanted physical contact.

 These references are just some examples.

Discrimination

The term " Discrimination” refers to any kind of discriminatory treatment or prejudice that may be based on factors such as sex, race, skin colour, national or social origin, genetic characteristics, language, religion or personal beliefs, political opinions , disability or health condition, age or sexual orientation.

Retaliation

KOFINAS prohibits its employees or anyone else associated with the company from retaliating against other employees or third parties who resist violence or harassment of any kind. This includes prohibiting retaliation against individuals who report, file, assist, or participate in the investigation of related incidents.

PURPOSE

The company KOFINAS SA follows and implements all the obligations and measures required by Law 4808/2021, regarding the prevention and treatment of all forms of violence and harassment, including those related to gender and sexual harassment.

The main objective of the company's policy is to prevent and combat all forms of discrimination, regardless of a person's personal characteristics or choices. It seeks to create a working environment that respects and promotes human dignity and ensures the right to a world of work free of violence and harassment. The company KOFINAS recognizes and respects the right of every employee to work in an environment free of violence and harassment and does not tolerate any such behavior by any person during or in connection with work.

This policy is based on Articles 9 and 10 of Law 4808/2021 and related legislation, and applies to all persons covered by Article 3 of the same law.

FIELD OF APPLICATION

The company's policy on preventing and dealing with violence and harassment is widely applied and covers a variety of people associated with the company. This includes the company's management, employees with dependent labor contracts, as well as those with contracts such as commission, project, independent services and temporary employment. It also applies to those employed through third-party service providers, apprentices, employees who are no longer with the company, prospective employees, as well as other people who have a professional transaction or collaboration with the company. This approach demonstrates the company's commitment to promoting a discrimination and harassment-free work environment for a wide range of people associated with its activities.

DECLARATION OF ZERO TOLERANCE TO DISCRIMINATION, VIOLENCE AND HARASSMENT – RISK ASSESSMENT

The company is committed to combating and eliminating discrimination, violence and harassment in the workplace, with the aim of creating a working environment based on respect for human dignity, where discrimination is not allowed. It is committed not to tolerate discrimination, violence or harassment during or in connection with work.

In particular, acts such as sexist or racist jokes, innuendo, offensive language, comments about appearance or character, stalking, unwanted attention, sexual messages through various channels, offensive questions about personal matters, sexual gestures, threats, rude gestures, unwanted physical contact, spreading malicious comments or insults, verbal threats, belittling, exclusion from group activities, cyberbullying and other similar behaviors.

The company also promises to provide assistance and cooperate with the relevant authorities in the investigation of incidents of violence and harassment. In addition, it will take appropriate action against those who violate its policy, to prevent and prevent the recurrence of such incidents or conduct.

MEASURES TO CONTROL, PREVENT, LIMIT AND ADDRESS RISKS – AWARENESS & AWARENESS ACTIONS

The company KOFINAS SA implements a policy that requires all employees and anyone else associated with the company to comply with regulations for the prevention of discrimination, violence and harassment. This policy applies to both workplaces and venues associated with corporate meetings, conferences and events, whether in person, online or over the phone.

The company is committed to creating and encouraging the maintenance of a work environment that will be accessible, safe and friendly, promoting mutual respect and cooperation between employees, partners and management.

In addition, the company takes every possible measure to protect and support employees who are victims of domestic violence, as well as to inform and raise awareness among staff about combating violence and harassment. For this purpose, he organizes meetings encouraging the participation of all.

Finally, the company urges employees and anyone associated with the company to report any incidents of discrimination, violence and harassment, thus showing its commitment to ensuring a healthy and safe working environment for all.

THE RIGHTS AND OBLIGATIONS OF THE EMPLOYER AND THE EMPLOYEES IN THE EVENT OF THE OCCURRENCE OR REPORTING OR COMPLAINT OF SUCH INCIDENTS

In the event that an employee or person associated with KOFINAS SA is affected by an incident of violence or harassment, either during access to employment, during work, or even after the termination of the employment relationship, he has the following rights:

1. Right to judicial protection: The aggrieved person can apply to justice for the protection of his rights.
2. Right to appeal to the Labor Inspectorate: Can submit a complaint or request for a labor dispute within the framework of the statutory powers of the Labor Inspectorate.
3. Right to appeal to the Ombudsman: The aggrieved person can appeal to the Ombudsman for consideration of his case.
4. Right to complain within the company: According to company policy, employees can file complaints about incidents of violence or harassment.

The company also ensures that the contact details of the competent authorities are posted in visible places, so that any affected person knows where to turn. These include the SEPE complaint hotline through the citizen service line 1555 and the direct psychological support and counseling service for female victims of gender-based violence, SOS Line 15900.

Regarding the rights and consequences of non-compliance in the context of the employment relationship: articles 12-15 of Law 4808/2021 apply, namely:

Article 12: Rights of victims – Effects on violation of the prohibition of violence and harassment

Any person referred to in article 3 who is affected by an incident of violence and harassment against him in accordance with article 4, even if the relationship, in the context of which the incident or behavior is alleged to have occurred against him, has ended, has the right, in addition to the judicial protection, appeal before the Labor Inspectorate and the Ombudsman as a body promoting and supervising the principle of equal treatment, in accordance with Law 3896/2010 (A' 207) and Law 4443/2016 (A' 232), as well as filing a complaint within the business under the policy of article 10.

When an employee or another person employed in accordance with article 3 violates the prohibition of violence and harassment in article 4, the employer is obliged to take the necessary appropriate and proportionate measures, as the case may be, at the expense of the person complained of, in order to prevent and prevent a similar incident or behavior from happening again . These measures may include recommending compliance, changing the position, time, place or way of providing work or terminating the employment or partnership relationship, subject to the prohibition of the abuse of rights in Article 281 of the Civil Code.

Any person referred to in article 3 who suffers an incident of violence and harassment at his expense, has the right to leave the workplace for a reasonable time, without loss of salary or other adverse consequence, if in his reasonable belief there is an imminent serious danger to life, his health or safety, in particular, when the employer is the perpetrator of such behavior or when he does not take the necessary appropriate measures according to par. 2, in order to restore work peace, or when these measures are not capable of stopping the behavior violence and harassment. In this case, the leaver is obliged to inform the employer beforehand in writing, stating the incident of violence and harassment and the incidents that justify his belief that a serious risk to his life, health or safety is imminent. As long as the risk does not exist or has ceased to exist and the person referred to in paragraph 3 refuses to return to the workplace, the employer can appeal to the Labor Inspectorate with a request to resolve the dispute. In this case, article 18 applies.

When an employer or a person exercising the managerial right or representing the employer violates the prohibition of violence and harassment in article 4 when entering into or refusing to enter into a legal relationship with a person in article 3 or during its development, duration or termination, he violates the labor law and the administrative sanctions of para. a of par. 2 of article 19 are imposed on him.

In any case, the violation of the prohibition according to article 4 gives rise, among other things, to a claim for full compensation of the affected person, which covers his positive and cumulative damage, as well as moral damage.

Article 13: Prohibition of retaliation

 The termination or in any way the termination of the legal relationship on which the employment is based is prohibited and void, as well as any other adverse treatment of a person referred to in article 3, as long as it constitutes retaliatory behavior or countermeasures within the meaning of article 14 of Law 3896/2010 (A` 207) for an incident of violence and harassment of article 4.

Article 14 Appeal by legal persons and associations of persons

 When legal entities and associations of persons, including trade unions, justify a relevant legal interest and have the written consent of the person affected by article 3 from violations herein, paragraph 2 of article 22 of Law 3896/2010 (A' 207) shall apply. The affected party can in any case intervene or even abort the procedure.

Article 15 Burden of proof

When the aggrieved person claims that he is experiencing violence and harassment in accordance with this Part, paragraph 1 of article 24 of Law 3896/2010 (A' 207) shall apply.

The rights regarding the complaint procedure are developed in the Article 10 Policy.

FURTHER INFORMATION – CONTACT PERSONS

Hereby defines the KOFINA SOURCE as a competent person to guide and inform employees about the prevention and treatment of violence and harassment at work, regardless of whether or not employees contact him about an incident or complaint about an incident of violence and harassment. Communication with the above person is possible by (a) visiting the office of the Human Resources Department, (b) sending an e-mail to the e-mail address p.kofina@yahoo.Gr, or (c) by telephone by calling 2299087899 inside 202.

It is the obligation of the aforementioned Reporting Person, as well as any other person involved in this process, to protect Personal Data, which may come to their knowledge during the exercise of their role.