Policies:
(a) for the fight against violence and harassment at work (b) for the management of internal complaints

1. PREAMBLE

A1. INGROUP advocates strongly against any form of violence or harassment at work including violence and harassment due to gender and shows zero tolerance to any kind of behaviour likely to be considered as such.

A2. INGROUP has already adopted and is applying the ethical practices ‘Respect, Dignity and Fair Treatment’ which impose respect to human rights and, among others, prohibit any kind of violence and harassment manifested during work, whether it is related thereto or is a result thereof.

A3. The purpose of the policies being adopted and reflected in this document is the creation and consolidation of a work environment that respects, promotes and safeguards human dignity and the right of each individual to be in a workplace without facing any form of violence and harassment.

 A4. The policies in question are adopted in accordance with the provisions of Articles 9 and 10 of Law no. 4808/2021 which specify the rights and obligations of the employees and the employer, to wit the affiliated companies of the Group, with regard to any form of violent conduct or harassment at work, as well as the measures applied in order to prevent and address the relevant risks.

1. DEFINITIONS – SCOPE OF APPLICATION

As “violence and harassment” are understood the forms of conduct, acts, practices or threat thereof aiming at, leading to or likely to lead to corporal, psychological, sexual or financial harm and occurring either once or repeatedly.

As “harassment” are understood the forms of behaviour aiming at or resulting in the offence of the person’s dignity and the creation of an intimidating, hostile, degrading, humiliating or aggressive environment, irrespective of whether such forms of conduct constitute a form of discrimination and comprise also harassment due to gender or other reasons of discrimination.

As “harassment due to gender” are understood the forms of behaviour relating to a person’s gender and aiming at or resulting in the offence of the person’s dignity and the creation of an intimidating, hostile, degrading, humiliating or aggressive environment. Such forms of conduct also comprise sexual harassment as well as forms of behaviour relating to sexual orientation, or a person’s sexual expression, identity or features.

The term “employees” means the employees of INGROUP in Greece, irrespective of the contractual status of their employment, under either permanent or fixed term agreements entered into either directly or through third-party providers (employees that are borrowed genuinely and by profession).

The term “other working persons” means all the employees, except those engaged under an employment agreement, including those employed under a contract for independent services or a work contract and all interns and apprentices, any employee the employment of whom has been terminated as well as people seeking employment and people employed in the informal economy.

1. PREVENTION OF AND FIGHT AGAINST VIOLENCE AND HARASSMENT AT WORK

Harassment and violence risks at work. Prevention and response measures

INGROUP has zero tolerance towards any conduct amounting harassment at work against its employees and other working persons. Nevertheless, such fact does not exclude completely the risk of any employee manifesting a hostile or intimidating behaviour or any other form of violent conduct that may affect the colleagues’ dignity and embarrass the same by offending them.

Such risks may occur especially: (a) at the workplace including the offices, common areas of the company and other private or public areas where the employees’ and other working persons’ work is provided or/ and where the same receive their fees or/ and do their break for rest, entertainment or another reason, as well as personal hygiene and care facilities, changing rooms and accommodation that the employer may provide, (b) in transport from and to work, in traveling, in training as well as in events and social activities connected to employment, and (c) in the communications relating to work including those made using information and communication technology.

More specifically, special reference and insight are highlighted and increased care must be taken in workplaces where only two employees are working, in workplaces where only one male employee is working or only one female employee is working together with other employees of the other sex, respectively, in personal hygiene and care facilities, in the context and during communications made through information technologies with the use of image or/ and sound as well as in any other case defined by the professional risk report.

The management of each company, the relevant employees and the other working persons shall ensure the identification and comprehension of new and particular risks in the work context in order to address them and prevent the adverse consequences thereof.

Prevention Measures/ Action for the Staff’s Information and Awareness

INGROUP undertakes the following specific action in order to prevent, monitor and address such risks, as well as for the tracking of such incidents or forms of conduct and in order to draw the attention of all employees and other working pesons and to raise their awareness in matters in the context of their work:

• Ensures that all the employees are trained in matters of respect of their colleagues’ dignity, mutual assistance, cooperation and equal treatment and that all of them commit themselves to comply with the policies and practices of INGROUP’s Business Principles including also the practices for Respect, Dignity and Fair Treatment aiming at establishing and preserving a working environment based on such principles;
• Ensures that all the employees are informed on a regular basis, whenever required, by the HR Manager both as regards the methods of prevention and the methods of combatting violence and harassment incidents;
• Invites the employees and the other working persons to be on their guard and ready, if they identify conducts of such kind occurring either against them or against their colleagues, to report the same immediately pursuant to the complaint policy and to take the prescribed action;
• Draws the attention of the heads of departments to be extra responsible, to supervise and to identify any misconduct in the groups they supervise (at the directorate, department or other work subgroups) and take them into account in assessing the performance of their subordinates as well as in organising work. At the same time, the superiors must endeavour to prevent – of course after they become aware of a risk of manifestation of any form of violence and harassment – situations that under certain circumstances may lead to such violence or/ and harassment incidents. The wariness regarding the conduct of the colleagues should be a continuous effort of the superiors, the security offices and the employees. In parallel INGROUP draws the superiors’ attention to refrain in performing their duties from any acts and more generally to avoid showing a conduct towards their subordinates which constitutes or could develop in and viewed as violence and harassment at work.

The conducts of employees and other working persons that may develop into or cause violence or harassment incidents include without limitation:

• Implied or open threats;
• A conduct being intimidating, physically violent or threatening
• A conduct aiming at slandering, mocking or humiliating a person especially before colleagues
• The lack of self-control (sudden movements/ behaviours)
• Frequent and unjustified complaint for unfair treatment
• Accusations against other colleagues
• Refusal of acceptance of criticism in the context and in the performance of work
• Inadequate personal care including without limitation the inadequate observation of hygiene
• Deterioration of the employment conditions including without limitation the extended absence and the systematic inadequate performance of work.

The conducts of employees and other working persons that may develop into or cause incidents of sexual harassment include without limitation:

• Requests for sexual favours,
• Offensive or degrading comments, jokes and insinuations,
• Sexual proposals or flirtation or date proposals,
• Projection, dispatch through e-mail or receipt of offensive material,
• Questions, comments or insinuations regarding a person’s sexual activities or private life,
• Physical contact (for example, kissing or body touching the body of another person by passing close to it),
• Threat, benefit or promise either openly expressed or implied,
• Behaviour causing a hostile work environment,
• Offensive gestures,
• Inappropriate looks,
• Any conduct that would also be an offense based on penal law/

In a multicultural work environment, it is possible that some conducts be offensive for certain people, while others, such as comments about the appearance or the attire or jokes, may not be. In any case, the company shall always examine the conduct’s impact on the victim and not the offender’s intention.

• The Human Resources Department and the occupational physician shall monitor and immediately inform the relevant superior but also the person responsible for compliance with the business principles, practices and policies (‘Business Integrity Officer’) of the Company or another person responsible for these matters, in case they notice behaviours that could deteriorate or incidents likely to cause unrest, so that the appropriate measures be taken in the workplace prior to the manifestation of violence or/ and harassment conducts.
• Ensures that are minimized to the extent possible the cases of isolation of the employees and other working persons in the areas where work is provided and at the same time encourages and enhances the opportunity thereof to communicate with their superiors and other colleagues in the case of incidents that could develop into manifestations of violence or/ and harassment behaviour;
• Encourages and ensures the organisation of targeted meetings with the staff in order to discuss and to address such matters, the organisation of seminars with mental health experts or counselling services providers and volunteer organisation representatives and the participation of the employees’ representatives and the management officials in training programmes and educational seminars.

Combat Measures

In the event of manifestation of violent conduct or harassment at the workplace, then must be notified immediately and as soon as possible the immediate superior and the remaining officials/ employees the competences and duties whereof relate to the resolution of such matters and more specifically the Head of the Human Resources Directorate or, if there is no such post, the Head of the Department of Personnel, the Head of the Department of Health and Work, the occupational physician and the the person responsible for compliance with the business principles, practices and policies (‘Business Integrity Officer’).

At a first level, the purpose of the notification concerns the de-escalation of tension, the avoidance of further risks, the removal of the persons involved and the securing of the avoidance of any further contact and communication between the abuser and the abused likely to flare the tempers. In order to achieve such purpose, the officials responsible shall use a calm way of communication, with politeness and civility and without any violence, avoiding any offences, verbal exaggerations and unneeded actions that are of no use, while as a last resort the relevant police authorities must be called if felonies or other unlawful acts are perpetrated and this is deemed necessary due to the severity and criticality of the situation. In any case, the action of the competent officials at that stage must focus on the avoiding of further escalation of the incident and the elimination of any chance of deterioration of the extreme, aggressive and illegal behaviours.

At a second level, immediately after the violence/ harassment incident it must be ensured that all the persons involved are safe, that they be provided with first aid and the requisite medical care, if required, that the victim and the other employees and other working persons that may have been involved in the incident be provided with psychological or other support, that be secured the safeguard of all exhibits/ means of evidence, that be questioned all the persons involved as soon as their condition permits, as well as the other employees and other working persons who were present during the facts constituting the illegal behaviour and the conditions in which and how such facts have taken place, and that be recorded and registered the relevant information in order to be verified, that the incident be investigated and that the disciplinary and other internal processes enshrined by the company be followed, in any case with respect to human dignity and in accordance with the law.

Rights of Employees and other working persons

Each employee who experiences a violence and harassment incident against him/ her is entitled to complaint and report it to his/ her employer but also to leave his workplace for a reasonable period of time to be determined by the Business Integrity Officer or the Business Integrity Committee, without any salary cut or other adverse consequence, if such employee is convinced and it does appear that there is an imminent serious risk for his/ her life, health or security, especially when, in spite of the measures that have been adopted, he/ she continues to be harassed.

In this case, the victim of violence or harassment should have previously informed in writing his/ her immediate superior or/ and the head of the directorate/ department of Human Resources, reporting the violence and harassment incident and the facts confirming and proving such conviction of his/ hers, to wit that there is a serious risk for his/ her life, health or security. In any case, if the risk ceases, the employee incurring the risk must return to his/ her workplace immediately and in all cases as soon as he/ she is informed accordingly by his/ her employer.

The other working persons have the same rights respectively.

Notwithstanding and in parallel with the above-mentioned rights, INGROUP has enshrined in order to address violence or/ and harassment incidents a specific policy/ process for the management of internal complaints which applies to any kind of fault and is set out below.

Information, Rights and Obligations of Employees Exercising Managerial Right or/ and Representing the Employer

The officials exercising the managerial right and/ or representing the employer must demonstrate a particular diligence in matters of violence and harassment, be informed and trained continuously for the prevention and addressing of matters of such nature, follow the relevant procedures, instructions and recommendations laid down by INGROUP and assist their subordinates in any manner whatsoever in case of occurrence of a violence or harassment incident, with discretion, respect and objective judgment.

In case of direct and imminent danger, the officials exercising the managerial right and/ or representing the employer have the right and the obligation to apply what is prescribed by the applicable laws and the relevant procedures, instructions and recommendations laid down by INGROUP, aiming at preventing and addressing incidents of violence and harassment at work, even without the employer’s prior special approval.

The officials exercising the managerial right and/ or representing the employer must keep secrecy and confidentiality as regards questions of violence and harassment and show the requisite diligence, objectivity, professionalism and discernment in dealing with such incidents. At the same time, they must comply with INGROUP’s procedures and protocols in order to avoid unjustified exposure and shaming of the persons alleged as abusers or abused.

Appointment of Person Responsible (“Liaison”)

The employer has appointed the company’s Business Integrity Officer as responsible to instruct and inform the employees and other working persons in respect of prevention and addressing violence and harassment at work. The role of such person is strictly informative and consists in instructing and informing the employees and other working persons irrespective of whether the latter are reporting an incident or file a complaint or not. Communication therewith may be carried out through e-mail or telephone or through a meeting. Protection of personal data is an obligation of the person named above in the performance of his/ her duties.

Domestic Violence Victims

INGROUP gives particular consideration in the protection of employment and in the support of domestic violence victims. Employees who have demonstrably been victims of domestic violence shall enjoy increased protection of their job, they shall be given their regular leave by priority as well as any other leaves that the employer may have enshrined, they shall be entitled by priority to work in flexible work forms  depending also of course on the employer’s business needs and more generally in consultation with their employer they shall rejoin smoothly their job after such incidents, and especially in cases there are minor or disabled children or children suffering from serious diseases.

Persons Employed by Third Parties

• The people employed under employment contracts or employment relationships with Temporary Employment Businesses (TEB) fall within the protection that the indirect employer must provide to its employees but also within the obligations of the indirect employer for the adoption of measures in the event of infringement of the relevant provisions of Article 4 of Law no. 4808/2021 (violence and harassment policies and complaints policies) by a person temporarily employed in its business, given that the managerial right is exercised by the indirect employer.

However, in case of infringement of the prohibition of any form of violence and harassment under Article 4 by a person temporarily employed by the business of an indirect employer, the latter shall transmit the relevant file also to the direct employer (TEB), as the exercise of the disciplinary power remains vested in the direct employer, is governed by the atter’s context and is not transferred under the concession agreement to the indirect employer.

1. INTERNAL COMPLAINTS/ REPORTS POLICY

Complaint Process/ Report

It is a right but also an obligation of any employee or other working person who becomes aware of any harassment behaviour or violence manifestation at wok, to report such behaviour and follow the prescribed procedure.

INGROUP has implemented a practice/ procedure for the report of possible infringements. All the employees are encouraged to unleash and to notify their thoughts and their concerns if they feel that any principle of the business is being breached, especially, inter alia, where the conducts concern violence and harassment at work and lack of respect and dignity towards colleagues.

The procedure in such a case is the following:

The complainant immediately notifies the case

1. Either to his/ her superior;
2. Or/ and to the Head of the Directorate/ Department of Human Resources;
3. Or/ and to the person responsible for compliance with the company’s principles, practices and policies (Business Integrity Officer).

Alternatively, the complainant may send an e-mail directly to the e-mail address bio@ingroup.gr

In all the above-mentioned cases, the INGROUP’s responsible for compliance with the company’s principles, practices and policies (Business Integrity Officer) is mandatorily notified.

In all the above-mentioned cases, the complainant’s anonymity may be preserved (if the complainant so wishes), whether the complainant is an employee or another person reporting such a matter, at any stage or level of the procedure the anonymity may be requested, while the complainant’s personal data are kept strictly confidential and protected.

Access to the complainant’s personal data, where the same have been declared at the time of the complaint shall be allowed to the person against whom the complaint has been filed, the occupational physician and INGROUP’s responsible for compliance with the company’s principles, practices and policies (Business Integrity Officer), to whom the complaint will be transmitted for investigation. The Business Integrity Officer may delegate the complaint’s investigation to a special investigation team that is formed especially to that effect within INGROUP and will assist such Officer in his/ her task. The investigation team shall be notified such personal data of the complainant as are required for the performance of its duties, unless the complainant has objected thereto. The results of the complaint’s investigation shall be notified by the Business Integrity Officer to INGROUP’s Committee responsible for compliance with the company’s principles, practices and policies (Business Integrity Committee) provided for and formed by the Company in order to apply the disciplinary law and to report to the Company’s management, so that the latter adopts all necessary decisions. In case a Committee has not been constituted or operating within the employer’s business – Business Integrity Committee, the duties and powers thereof are exercised by the Business Integrity Officer, while after the Committee’s constitution and operation, the latter may assign part of its duties and powers to the Business Integrity Officer, especially if the incidents do not constitute a confirmed manifestation of physical and psychological violence, if they do not concern more than one employee and do not constitute a repeated behaviour of an employee or against any employee, if they concern anonymous complaints and in the case of any such other incident as the Committee may deem, provided however that the Committee shall be informed of the development and the results of the investigation procedure, while the same may be seized of the case at all times, if it is considered that a certain case is of major importance.

The Committee responsible for compliance with the company’s principles, practices and policies (Business Integrity Committee) is composed of at least three members and comprises (a) the Managing Director, (b) the Head of Human Resources, and (c) the Company’s legal counsel.

In the case the complaint is turned against the Business Integrity Officer, the duties and powers thereof shall be exercised by the Officer’s deputy and by the Business Integrity Committee. In the event that such persons do not exist, the complaint is filed with/ transmitted directly to the Company’s Managing Director. In case the complaint is turned against an employee of the Company who is a member of the Committee, then such employee is informed and does not participate in the Committee or is substituted by another high-ranked and experienced official, if this is resolved unanimously by the remaining members, in which case the Company’s management is informed forthwith. The Company’s management may change the composition of the Committee per year and at all times on serious grounds, and such decision of the same must be reasoned in writing and may not be connected to the ruling on the merits, the recommendation or the adoption of measures in a specific case, provide that such acts are lawful and in line with INGROUP’s policies and the business’s Staff Rules.

No adverse measures may be taken against the members of the Committee or the person responsible for compliance with the company’s principles, practices and policies (Business Integrity Officer) by reason of the exercise of their duties and powers and in accordance with the law, INGROUP’s policies and the company’s Staff Rules.

A person not having an employment relationship with INGROUP may also be appointed as responsible for compliance with the company’s principles, practices and policies (Business Integrity Officer).

It is important to specify that, if the complainant wishes to remain anonymous, then the complaint may not be investigated in depth so that the complainant’s identity is not disclosed to any third parties through the investigation, depending of course on the circumstances of each case.

The complainant is protected from any retaliation due to his/ her complaint, while INGROUP commit themselves to protect the complainant and take any measure against his/ her further “victimisation”. Nevertheless, if the complaint is proven false, the complainant shall be liable towards INGROUP and the person against whom the complaint had been filed to compensate any damage suffered by the came.

The person so denounced may be informed and be provided with a copy of the complaint, if he/ she has so requested and to the satisfaction of the employer and the relevant organs all the requisite measures have been adopted and there is no risk for the victim and the securing of the exhibits aiming at having the case investigated. In any case, the person denounced shall be informed of the content of the complaint against him/ her when he/ she will be invited by the relevant organs in order to be examined and provide explanations in respect of the incident constituting the content of the complaint or when the denounced person’s identity has been notified to a third party, the testimony of whom has been requested for the case and this is requested by the denounced person.

The Company’s management, the Business Integrity Officer, the head of the Directorate/ Department of Human Resources and the occupational physician shall cooperate in any relevant matter relating to the evolution and improvement of the relevant procedures and ensure that the company’s policies and other procedures are understood by the employees and other working persons and also that they do serve the purpose for which they have been laid down.

Complaint Management Procedure 

1. For each complaint for violent behaviour or harassment that may be filed in any of the above-mentioned manners, an investigation shall be conducted by the Business Integrity Officer or care of the latter by the investigation team appointed by such Officer. The investigation team must be formed by officials, employees or other working people of INGROUP or/ and third parties, provided that in this last case they do have specialised experience and knowledge as well as warranties for the observance of secrecy and confidentiality. The composition thereof must be promptly notified to the management, while, if an additional cost is involved, the assignment of the inquiry to an investigation team shall be conditional upon the expenditure’s approval by the management.
2. The investigation of each case must be carried out immediately and it is recommended that it be completed within 90 days. For each case summary report with the elements that have been taken into account and the results of the investigation shall be drawn up. The care of drawing up such report is the duty of the Business Integrity Officer or of the Business Integrity Committee and the report shall be taken into account by the company’s management and disciplinary organs in the adoption of their decisions.
3. The persons who compose the investigation team as well as the Business Integrity Committee may exercise their duties exclusively or in parallel with other duties, even when they are part of the company’s staff.
4. The receipt, investigation and examination of the complaints shall be made impartially, with respect to the secrecy and protection of the information’s confidentiality, but also by protecting the personal data of the subjects involved (the abuser, the abused and the witnesses). The employer encourages and does not hinder in any manner whatsoever the receipt and investigation of the complaints and ensures that investigation be conducted with respect to human dignity, to the authorities, to the Company’s policies and to the applicable laws.
5. The Business Integrity Officer and the people composing the Business Integrity Committee may have access to the company’s files, to audiovisual material and to the content of the employment file of the persons involved, if and to the extent these are necessary in order to investigate the complaint. Under the same restrictions such data may be notified care of the Business Integrity Officer also to the persons composing the complaints’ Investigation Team. The head of the directorate/ department of Human Resources and the other officials of the employer must cooperate with the persons and organs that are responsible for the investigation of the complaints and assist them in collecting information under the above-mentioned conditions. In case of refusal or disagreement between the persons named above with regard to the expediency and necessity of collection of the requisite material, the opposite views shall be quoted in writing and the company’s General Manager or the legal representative thereof shall decide in consultation with the legal department, where there are (also) legal questions.
6. The collection, processing and retention of the data and information of each complaint must be carried out in a manner ensuring the secrecy and confidentiality thereof. To that effect the employer shall take the necessary technical, organisational and other measures that are proportionate to the size and capacities of the business thereof and always pursuant to the applicable laws. The witnesses’ testimonies are mandatorily taken into account provided that they are given with named names and in writing, whereas, if the witnesses ask from the Business Integrity Officer to not disclose their identity, then the testimony thereof does not suffice by itself for the complaint’s establishment and the imposition of sanctions to the abuser unless the content thereof coincides with and is confirmed by other means of evidence.
7. The accused abuser must have the possibility on the one hand to be informed of the entirety of the case’s means of evidence that the Business Integrity Officer and the persons composing the Business Integrity Committee have collected and taken into account as the same are stated in their report (but not of the report’s content which remains secret) and on the other hand and at the same time the possibility to file his/ her views on the case and the means of evidence documenting such views, promptly and in any case at a time prior to the imposition of any disciplinary sanction or other unfavourable measure against him/ her.
8. In the event the subject-matter of the complaint is strongly considered as very probable or/ and a direct and imminent danger is noticed due to or on the occasion of the complaint and/ or the conditions under which the same has been filed, the Business Integrity Officer and the persons composing the Business Integrity Committee take all the necessary measures aiming at ensuring the integrity of the persons involved pursuant to the applicable laws and to immediately inform the employer. The employer may either ex officio or following the suggestion of the Business Integrity Officer and the persons composing the Business Integrity Committee take additional measures if it deems necessary. It is specified that the procedure of the complaint’s investigation does not affect the employer’s right to terminate the employment agreement of the persons involved or of any of them, irrespective of the merits and the verification of the complaint and even before completion or the opening of the relevant procedure, provided that the complaint has been filed lawfully and not vengefully.
9. In case of confirmation of the complaint’s subject-matter, the employer shall take all the measures required for the protection of the victim’s protection (either it is the complainant him/ herself or not) in the context of the employment relationship, including without limitation the moving away of the person denounced and of any other person responsible from the victim, while depending on the seriousness of the complaint, the employer shall moreover take all expedient and necessary measures as the case may be and at its discretion, in order to prevent that such an incident or behaviour is repeated. Such measures may include a compliance recommendation a change of the workplace, a change of the place, the time schedule and/ or the manner work is to be provided, position, of time and/ or way of the provision of work, as well as the termination of employment or cooperation. Accordingly, the abuser/ responsible should be protected against retaliation and unjustified conducts of other colleagues, if he/ she continues to be employed in the employer’s business.
10. The victim of violence or harassment incidents shall be informed by the Business Integrity Officer of the possibility to apply at the same time to the competent administrative authorities (Labour Inspection and Ombudsman) as well as to the judicial authorities, at the victim’s discretion. The employer and the competent organs of the business thereof shall cooperate with any relevant governmental, administrative or judicial authority, which either ex officio or upon the request of the abused requests the provision of data and information in the context of its powers and as prescribed by law.
11. After the completion of the investigation procedure, the complaints and the evidence collected in the context thereof shall be filed electronically or/ and in hard copies and be kept secret and confidential for a period of ten (10) years, after the expiry of which the material shall be destroyed care of the Business Integrity Officer or of the Business Integrity Committee, if there is any, following a relevant written notice given to the employer. The material obtained following unfounded complaints or complaints based on insufficient evidence may be destroyed immediately following completion of the investigation procedure unless the Business Integrity Officer or the Business Integrity Committee makes a reasoned request that the material be kept for a certain period of time. Access to the content of the complaint and to the material collected following completion of the investigation procedure and of the possible imposition of disciplinary sanctions shall be reserved solely and exclusively to the Business Integrity Officer and the persons composing the Business Integrity Committee, as well as to the employer in order to exercise its rights and only to the extent required following the information of such Officer and Committee. The Business Integrity Officer and the persons composing the Business Integrity Committee are entitled to refuse the employer’s access to the above-mentioned data, while in case of disagreement the dispute shall be resolved in the context of a conciliation procedure by the relevant organs (the Organisation of Mediation and Arbitration or the Labour Inspection or another organ in their stead). Nevertheless, it is specified that (a) the entire material of the complaints and the content thereof shall be kept by the company and constitute the assets thereof (and not of the Business Integrity Officer or the Business Integrity Committee), while the preservation thereof and the access thereto by the employer’s competent organs must be secured also after termination in any manner whatsoever of such persons with the Company; (b) the above-mentioned restrictions do not impair, hinder or affect the right of the employer, the head of the Directorate of Human Resources, the occupational physician and the remaining officials of the employer in the context of the powers and duties thereof, respectively, to preserve files and to have access to information and data, in accordance with the applicable law, the company’s Rules and Policies, as well as the employees’ employment agreement; and (c) the subjects of the personal data preserve the rights contemplated by the laws and the company’s relevant policies, and may receive further clarifications upon their request.
12. The policies and procedures contemplated by this document are supplemented by the provisions of the law and are construed pursuant to the purpose thereof. The policies and procedures hereof do not affect or alter the rights and the obligations of the employer and the employees but also of the other persons working for INGROUP, as the same appear from the laws, the employment agreement, the Collective Labour Agreements, the Work Regulation and the other regulatory law sources, while in case of conflict between provisions the rules of the labour laws shall prevail.
13. The employer reserves the right to amend the existing policies and procedures or even to enshrine new policies and procedures in substitution thereof, in any case pursuant to the applicable laws, if it considers that its purpose is better served that way.