Legal Information

POLICY FOR THE PREVENTION AND COMBAT OF VIOLENCE AND HARASSMENT AT WORK AND POLICY FOR THE MANAGEMENT OF INTERNAL COMPLAINTS REGARDING INCIDENTS OF VIOLENCE AND HARASSMENT AT WORK, PURSUANT TO ARTICLES 9 AND 10 OF LAW 4808/2021

1. Our company complies with all measures and obligations concerning the implementation of the provisions of Part II of Law 4808/2021 for the prevention and management of all forms of violence and harassment, including gender based violence and harassment, as well as sexual harassment.
2. The purpose of this policy is to create and establish a working environment that respects, promotes, and safeguards human dignity and the right of every person to work free from violence and harassment. Our company declares that it recognizes and respects the right of every employee to a working environment free from violence and harassment, and that it does not tolerate any such conduct, in any form, by any person.
3. This policy is adopted in accordance with Articles 9 and 10 of Law 4808/2021 and the regulatory legislation issued pursuant thereto. It applies to the persons referred to in paragraph 1 of Article 3 of Law 4808/2021, namely:

Employees and persons working in our company, regardless of their contractual status, include those employed under a dependent employment contract, whether full-time, part-time, rotational, fixed-term, or indefinite-term.

Persons working under a contract for services, an independent services agreement, or a salaried mandate.

Persons who may be employed through third-party service providers.

Persons undergoing training, including interns, apprentices, and volunteers.

Employees whose employment relationship has ended.

Persons applying for employment.

1. Forms of conduct involving violence and harassment against the persons referred to above, in paragraph 3, may occur:

At the workplace, including public and private spaces and places where the employee provides work, receives remuneration, takes a break, especially for rest or meals, in personal hygiene and care areas, changing rooms, or accommodation provided by the employer.

During commuting to and from work, other travel, business trips, training, events, and social activities related to work.

During work-related communications, including communications carried out through information and communication technologies.

1. Through this policy, the company declares that it applies a zero-tolerance policy towards every form of violence, harassment, gender based harassment, sexual harassment, bullying, threats at work, insults, and degradation for any reason or cause, abusive language, and similar conduct that may occur at work or in connection with work. The company also expresses its commitment to preventing, addressing, and eliminating such conduct, should it occur.
2. It is expressly and categorically stated that every form of violence and harassment is prohibited when it occurs during work, relates to work, or arises from work, including gender based violence and harassment, as well as sexual harassment.
3. For the purposes of this policy:

a) “Violence and harassment” mean forms of conduct, acts, practices or threats thereof, which aim at, lead to, or may lead to physical, psychological, sexual or financial harm, whether occurring as isolated incidents or repeatedly.

b) “Harassment” means forms of conduct which have the purpose or effect of violating the dignity of a person and creating an intimidating, hostile, degrading, humiliating or offensive environment, regardless of whether they constitute a form of discrimination. This includes gender based harassment or harassment on other grounds of discrimination.

c) “Gender based harassment” means forms of conduct related to a person’s gender, which have the purpose or effect of violating that person’s dignity and creating an intimidating, hostile, degrading, humiliating, or offensive environment, in accordance with Article 2 of Law 3896/2010 and paragraph 2 of Article 2 of Law 4443/2016. These forms of conduct also include sexual harassment under Law 3896/2010, as well as forms of conduct connected with a person’s sexual orientation, expression, identity, or gender characteristics.

d) “Sexual harassment” means any form of unwanted verbal, psychological or physical conduct of a sexual nature, which results in an offence against a person’s personality, especially through the creation of an intimidating, hostile, degrading, humiliating or offensive environment around that person.

Indicative examples of such unwanted conduct, which is strictly prohibited, include sexual innuendo, mockery, obscene, sexual or racist jokes or comments, the use of offensive language, comments about a person’s appearance or character that cause shame or embarrassment, monitoring, stalking, sending messages of sexual content by any means, including text messages, emails, social media, other electronic or online applications, fax or letter, offensive and persistent questions about age, marital status, personal life, sexual interests or preferences, race or ethnicity, including political identity and religion, sexual gestures, persistent requests for dates or threats, suggestions that sexual favours may advance a person’s career or that refusal to enter into a relationship may negatively affect professional development within the company, rude gestures, touching and any kind of unwanted physical contact, spreading malicious comments or insulting a person on discriminatory grounds such as age, gender, type of marriage, civil partnership, pregnancy and maternity, any disability, sexual preferences, religion or beliefs, verbal threats or threats through gestures, public or private insults, the degradation or ridicule of a person or their abilities either privately or in front of others, outbursts of anger against someone, persistent or inflexible criticism, cyberbullying, offensive messages by any means, letters and telephone calls, the display and distribution of offensive material or material of a sexual nature, acts of retaliation, isolation or refusal to cooperate with a colleague, or the spreading of malicious or abusive rumors.

For the avoidance of any misunderstanding or misinterpretation during the implementation of this policy, which could cause unnecessary or inappropriate involvement and negatively affect the orderly operation of the company, it is clarified that, in principle, conduct falling within the limits of the employer’s managerial right and the applicable legal framework shall not be considered acts of violence and harassment, provided that such conduct is directly or indirectly connected with the supervision and control of the company’s employees, their productivity and effectiveness, their evaluation and their general work performance.

A. POLICY FOR THE PREVENTION AND COMBAT OF VIOLENCE AND HARASSMENT AT WORK

I. Assessment of risks of violence and harassment at work

The company’s main objective is the prevention and elimination of every phenomenon of violence and harassment at work, as well as the effective management of even suspicions of such phenomena. For this reason, the company shall include psychosocial risks in the Occupational Risk Assessment Study, including risks connected with violence and harassment, taking into account, among other factors, any inherent risk arising from the nature of the activity, the job position, factors such as gender and age or other characteristics constituting grounds of discrimination, as well as risks concerning special categories of employees, such as night workers and newly hired employees.

For this assessment, digital occupational risk assessment tools may be used, such as those available for Greece through the interactive online OIRA platform, Online Interactive Risk Assessment, of the European Agency for Safety and Health at Work, EU OSHA.

II. Measures for the prevention, control, limitation, and management of these risks, as well as for the monitoring of such incidents or forms of conduct

The company’s measures and practices for preventing, controlling, limiting, and managing these risks, as well as for monitoring such incidents or forms of conduct, are the following:

A) Encouraging the maintenance of a working climate where respect for human dignity, cooperation, and mutual support are fundamental values.

B) Maintaining open communication between employees and the company manager, direct supervisors, and colleagues.

C) Establishing a procedure for the management of reports and complaints.

D) Ensuring that employees receive the necessary training and information to perform their duties, especially in positions with a higher risk of incidents of violence and harassment.

E) Providing assistance and access to every competent public, administrative, or judicial authority during the investigation of such an incident or conduct, where requested by such authorities.

F) Actions to raise employee awareness regarding healthy standards of conduct, for example, the avoidance of addictions, as well as issues concerning vulnerable categories of employees.

G) Providing employees with information regarding possible risks of violence and harassment in the workplace and the relevant prevention and protection measures, including the obligations and rights of employees and the employer in relation to such incidents.

H) Training employees in the procedures for managing incidents of violence.

I) Posting information at an accessible point in the workplace regarding the procedure for reporting and addressing such forms of conduct.

III. Actions for informing and raising awareness among staff

Our company shall:

A) Organize targeted staff meetings for the discussion of relevant matters and the timely management of potential risks.

B) Conduct seminars with mental health specialists or counselling service providers, representatives of voluntary organizations, and other relevant parties.

C) Encourage the participation of employee representatives and management executives in training programs and educational seminars concerning the recognition and management of risks of violence and harassment at work.

IV. Information on the rights and obligations of employees and the employer, as well as persons exercising managerial authority or representing the employer, according to their level of responsibility, in the event of the occurrence, report or complaint of such incidents, as well as information on the relevant procedure

Every employee and, in general, every person referred to in paragraph 3 of the preamble, who is affected by an incident of violence and harassment against them, even if their employment relationship or contract has ended, within the context of which the alleged incident or conduct occurred, has the right:

A) To judicial protection.

B) To appeal to the Labor Inspectorate through the citizen service telephone line 1555, or through the website of the Labor Inspectorate.

C) To appeal to the Greek Ombudsman at the following contact details:

17 Chalkokondyli Street, Postal Code 104 32, Athens, telephone: (+30) 213 1306 600, email: press@synigoros.gr,

D) To contact the direct psychological support and counselling service for women victims of gender based violence through the SOS telephone line 15900.

E) To report or complain about the incident or conduct within our company, as provided in Section B of this policy.

F) In accordance with paragraph 2 of Article 12 of Law 4808/2021, to request that our company take measures against the reported person and/or measures concerning their own protection.

G) To leave the workplace for a reasonable period of time, without loss of salary or any other adverse consequence, if they reasonably believe that there is an imminent serious risk to their life, health or safety, especially when the necessary appropriate measures for their protection have not been taken, or when the measures taken are not capable of restoring workplace order and stopping the conduct of violence and harassment.

In this case, the person leaving the workplace is obliged to inform the employer in advance in writing, stating the incident of violence and harassment and the facts justifying their belief that a serious risk to their life, health, or safety is imminent. If 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 may appeal to the Labor Inspectorate requesting resolution of the dispute, as provided in Article 18 of Law 4808/2021.

H) To claim full compensation before the courts, covering actual loss, loss of profit, and moral damage.

Every employee and, in general, every person referred to in paragraph 3 of the preamble, is obliged:

A) To comply with this policy for their own protection and for the protection of the other persons employed by the company.

B) To immediately report any incident of violence and harassment to the reference person or “liaison” of this policy.

C) To cooperate in the event of an investigation into an internal report or complaint within the company.

D) To participate in the company’s training actions and programs concerning incidents of violence and harassment.

E) Not to engage in unwanted and prohibited conduct during the performance of their duties.

F) To immediately inform the liaison, reference person, mentioned in this policy of any incidents of violence and harassment that occurred in their area of work or responsibility.

G) Not to obstruct or prevent another person from exercising their rights and obligations, as provided by this policy and by law.

The company undertakes the necessary, appropriate, and proportionate measures, on a case-by-case basis, against the reported person, to prevent and avoid the recurrence of a similar incident or conduct.

V. Reference person, “liaison.”

The reference person, “liaison”, whom any employee may contact for fuller guidance and information regarding the prevention and management of violence and harassment at work, is TSAMBIKOS GALANOS, son of Dimitrios, Financial Director of the company.

The contact details of the reference person, “liaison”, are:

Telephone: 2241001711,

Postal Address: Ammoudes, Koskinou,

Email: acc@lamarquise.gr

The role of the reference person, “liaison”, is informative and consists of guiding and informing employees, regardless of whether they contact him in relation to an incident or complaint concerning violence and harassment.

The reference person, “liaison”, is obliged to protect Personal Data which may come to his knowledge during the performance of his role.

The reference person may be changed by decision of the company’s Board of Directors.

VI. Protection of victims of domestic violence

Our company protects the employment and supports the work, by every appropriate means or reasonable adjustment, of its employees referred to in this policy who are victims of domestic violence.

B. POLICY FOR THE MANAGEMENT OF INTERNAL COMPLAINTS REGARDING INCIDENTS OF VIOLENCE AND HARASSMENT AT WORK

I. Competent persons and communication channels

The person competent to receive and examine reports, complaints, and grievances regarding conduct involving violence and/or harassment, as defined in this policy, and to inform the reported persons, is TSAMBIKOS GALANOS, son of Dimitrios, telephone 2241001711, mobile 6944379645.

Every employee who considers that they have been subjected to violence and/or harassment, as well as every employee who becomes aware of incidents of violence and/or harassment in breach of this policy, may submit a written complaint or report of the incident through the following communication channels:

Submission of a letter to the address: Ammoudes, Koskinou.

Submission of an email to the email address: acc@lamarquise.gr.

Delivery of a letter to the competent person: TSAMBIKOS GALANOS.

All complaints and reports shall be handled with strict discretion and confidentiality and shall be kept in a secure location.

Upon submission of the complaint, the competent person shall inform the affected person that, at any stage of the internal company procedure, they also have the option to submit a complaint to the competent administrative authorities within the scope of their authority, namely the Labor Inspectorate and the Greek Ombudsman, as well as to the judicial authorities, at their discretion.

II. Temporary measures in favor of the complainant and investigation and examination of complaints

A. Temporary measures in favor of the complainant

Where required on a case-by-case basis and following agreement with the complainant or affected person, the company shall take immediate and appropriate measures to protect them until the complaint has been fully investigated and finally examined. Indicatively and depending on the case, such measures may include:

1. Change of working hours and working days of the personnel.
2. Transfer of the complainant to another department or to another branch of the company, where applicable, for a period to be agreed.
3. Employment of the complainant through remote work, where the nature of the work allows it.
4. Granting paid leave to the complainant.

B. Investigation and examination of complaints

Our company undertakes that the receipt of any complaint concerning this policy shall not be obstructed. At the same time, the company undertakes to handle and investigate every such complaint immediately, impartially, with respect for human dignity, with confidentiality, and in compliance with the rules on the protection of Personal Data of the complainant, the reported person, the persons examined, and any other involved persons. The company should also take immediate measures to protect the affected person.

All persons involved in the investigation of the case, such as the complainant, the reported person, and the persons or employees who may be examined, are obliged to observe confidentiality and discretion and to comply with the rules on the protection of personal data regarding all details and information that come to their knowledge during the examination and investigation of the case.

Upon receipt of the complaint or report, the procedure for its investigation and examination begins immediately by the competent person who received it. The procedure followed is the following:

1. Discussion between the competent person and the complainant.

Upon receipt of the complaint or report, the competent person shall invite the complainant, no later than within five (5) working days, to discuss the case further, and the complainant is obliged to attend this scheduled meeting.

During the discussion, the complainant is obliged to further present and analyze the reported facts to the competent person, while the competent person has the right to ask clarifying questions and receive answers from the complainant to be fully informed of the matters reported. At the end of the discussion, the complainant is obliged to submit in writing all clarifications regarding the matter and to sign them.

Throughout the investigation procedure, the competent person has the right to invite the complainant for discussion, following the above formal process. The complainant also has the corresponding right to be heard by the competent person.

1. Invitation of the reported person for information regarding the allegations, submission of a written explanation and other relevant actions.

Upon completion of the collection of information from the complainant, the competent person shall invite the reported person within five (5) working days to inform them of the allegations and to request that they submit their written and signed explanations within five (5) working days.

After submission of the reported person’s explanation, the competent person shall invite the reported person for discussion regarding the allegations, and the reported person is obliged to answer according to the facts of which they are aware. During the discussion, the competent person has the right to ask clarifying questions and receive answers from the reported person to be fully informed of the allegations. At the end of the discussion, the person is obliged to submit in writing all clarifications regarding the matter and to sign them.

Throughout the investigation procedure, the competent person has the right to invite the reported person for discussion, following the above formal process. The reported person also has the corresponding right to be heard by the competent person.

1. Invitation of other involved persons.

Within the framework of the investigation and examination of complaints, the competent person has the ability and the right to invite for discussion any employee involved in the relevant complaint, or any employee whom the competent person considers able to provide useful information.

All involved persons are obliged to attend the scheduled discussion with the competent person. During the discussion, the people involved must present to the competent person what they know about the reported facts, while the competent person has the right to ask clarifying questions and receive answers from the person involved to be fully informed of the allegations. At the end of the discussion, the person involved is obliged to submit in writing all clarifications regarding the matter and to sign them.

Throughout the investigation procedure, the competent person has the right to invite the involved persons for discussion, following the above formal process. The involved persons also have the corresponding right to be heard by the competent person.

1. Collection of evidence by the competent person through access to company records.

For the collection of evidence and information during the examination of the complaint, the competent person may, following approval by the company’s Board of Directors, have access to company records, audiovisual material, and other appropriate means for establishing the reported facts.

1. Collection and examination of all evidence, information, and reports, and thorough information of the company’s Board of Directors.

The competent person is also obliged to fully inform the legal representative or representatives of the company of every complaint received and of every new item of evidence or information that arises and comes to their knowledge regarding any complaint.

The competent person shall act and follow any procedure under this policy following approval by the legal representative or representatives of the company.

The competent person is also obliged, whenever requested, to fully and analytically inform the legal representative or representatives and the company’s Board of Directors of any complaint.

III. Prohibition of retaliation against the affected person

The termination or any form of dissolution of the legal relationship on which the employment is based, as well as any other adverse treatment of a person referred to in Article 3 of Law 4808/2021, is prohibited and invalid if it constitutes retaliatory conduct or a countermeasure within the meaning of Article 14 of Law 3896/2010 in relation to an incident of violence and harassment under Article 4 of Law 4808/2021.

However, the above prohibition does not aim to protect persons who intentionally submit false or malicious complaints. In such cases, the company may take legal measures against such persons and may even proceed with termination of their employment or cooperation agreement.

IV. Consequences and sanctions in case of established breaches

If the allegations concerning a breach of the policy against Violence and Harassment at Work are confirmed, either wholly or even partially, the company shall take, on a case-by-case basis, the necessary, appropriate, and proportionate measures against the reported person to prevent and avoid the recurrence of a similar incident or conduct.

Such measures include in particular:

Written or verbal recommendation for compliance.

Strict written reprimand.

Change of position, working hours, place or manner of work.

Temporary suspension from work for up to 10 days per calendar year.

Termination of the employment or cooperation relationship, subject to the prohibition of abuse of rights under Article 281 of the Greek Civil Code.

V. Cooperation and provision of all relevant information to the competent Authorities

Our company, as well as the competent person who examines and manages the complaints under this policy, undertakes to cooperate with and provide evidence and information to every competent public, administrative, or judicial authority that, either ex officio or following a request submitted by an affected person, requests the provision of evidence or information within the scope of its authority. For this purpose, any evidence collected in any form shall be kept in a relevant file in accordance with the provisions of Law 4624/2019.