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.
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.
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:
The conducts of employees and other working persons that may develop into or cause violence or harassment incidents include without limitation:
The conducts of employees and other working persons that may develop into or cause incidents of sexual harassment include without limitation:
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.
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
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.
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
Alternatively, the complainant may send an e-mail directly to the e-mail address email@example.com
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.
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