POLICY FOR THE PREVENTION AND COMBATING OF VIOLENCE AND HARASSMENT AT WORK & 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

ΠΑΡΑΚΑΛΟΥΜΕ ΠΑΤΗΣΤΕ ΑΠΟ ΚΑΤΩ ΓΙΑ ΝΑ ΔΙΑΒΑΣΕΤΕ ΤΗΝ:
ΕΛΛΗΝΙΚΗ ΈΚΔΟΣΗ ΤΗΣ ΠΟΛΙΤΙΚΗΣ

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 handling of all forms of violence and harassment, including gender-based violence and harassment and sexual harassment.
2. The purpose of this policy is to create and establish a working environment that respects, promotes, and safeguards human dignity and every person’s right to a world of work free from violence and harassment. Our company declares that it recognizes and respects every employee’s right to a work environment free from violence and harassment and that it tolerates no such behavior, in any form, from any person.
3. This policy is adopted in accordance with Articles 9 and 10 of Law 4808/2021 and the implementing regulatory legislation and applies to the persons referred to in paragraph 1 of Article 3 of Law 4808/2021, specifically:

• Employees and persons working for our company regardless of their contractual status, including those employed under dependent employment contracts, full-time, part-time, or rotational employment, fixed-term or indefinite-term.
• Persons working under project contracts, independent service contracts, or salaried mandates.
• Persons employed through third-party service providers.
• Persons undergoing training, including interns, apprentices, and volunteers.
• Employees whose employment relationship has ended.
• Job applicants.

4. Forms of violent and harassing behavior by the persons referred to above (para. 3) may occur:

• In the workplace, including public and private spaces and places where the employee performs work, receives remuneration, takes breaks especially for rest or meals, in personal hygiene and care facilities, changing rooms, or accommodation provided by the employer.
• During travel to and from work, other work-related travel, training, events, and social activities related to work.
• During work-related communications, including those carried out through information and communication technologies.

5. Through this policy, the company declares that it will implement a zero-tolerance policy against every form of violence, harassment, gender-based harassment, sexual harassment, bullying, threats at work, insults, degradation for any reason or cause, abusive expressions, etc., that may occur during or in connection with work. The company also expresses its commitment to preventing, addressing, and eliminating such behaviors should they arise.
6. It is expressly and unequivocally declared that all forms of violence and harassment manifested during work, related to work, or arising from work are prohibited, including gender-based violence and harassment and sexual harassment.
7. For the purposes of this policy:

a) “Violence and harassment” means forms of behavior, acts, practices, or threats thereof, that aim at, result in, or may result in physical, psychological, sexual, or economic harm, whether occurring individually or repeatedly.

b) “Harassment” means forms of behavior intended to or resulting in the violation of a person’s dignity and the creation of an intimidating, hostile, degrading, humiliating, or offensive environment, regardless of whether they constitute a form of discrimination, and includes gender-based harassment or harassment on other discriminatory grounds.

c) “Gender-based harassment” means forms of behavior linked to a person’s gender that aim at or result in violating that person’s dignity and creating an intimidating, hostile, degrading, humiliating, or offensive environment pursuant to Article 2 of Law 3896/2010 and paragraph 2 of Article 2 of Law 4443/2016. Such behavior also includes sexual harassment under Law 3896/2010, as well as behavior linked to a person’s sexual orientation, expression, gender identity, or gender characteristics.

d) “Sexual harassment” means any form of unwanted verbal, psychological, or physical conduct of a sexual nature resulting in an affront to a person’s dignity, particularly by creating an intimidating, hostile, degrading, humiliating, or offensive environment around them.

Indicative examples of such prohibited conduct include sexual innuendos, mockery, obscene, sexual or racist jokes or comments, use of offensive language, comments on someone’s appearance or character causing shame or embarrassment, stalking, pursuit, sending sexually explicit messages via phone messages, emails, social media, other online applications, fax or letters, offensive and persistent questions regarding age, marital status, personal life, sexual interests or preferences, race, nationality, political identity, or religion, sexual gestures or persistent requests for dates or threats, implications that sexual favors could advance one’s career or refusal of a relationship could negatively affect professional advancement within the company, rude gestures, touching and any unwanted physical contact, spreading malicious comments or insults based on discrimination concerning age, gender, marital status, civil partnerships, pregnancy and maternity, disability, sexual preferences, religion or beliefs, verbal or gestural threats, insults in public or private, degrading or ridiculing a person or their abilities privately or before others, angry outbursts against someone, persistent or uncompromising criticism, cyberbullying, offensive messages, letters and phone calls, display and distribution of offensive or sexually explicit material, retaliatory acts, isolation or refusal to cooperate with a colleague, or spreading malicious or insulting rumors.

To avoid misunderstandings or misinterpretations in the application of this policy that could lead to unnecessary involvement and negatively affect the proper functioning of the company, it is clarified that, in principle, behaviors falling within the employer’s managerial rights and the applicable legal framework, directly or indirectly connected with supervision and control of employees, their productivity and effectiveness, evaluation, and general work performance, shall not be considered acts of violence and harassment.

A. POLICY FOR THE PREVENTION AND COMBATING 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 all phenomena of violence and harassment at work, as well as the effective handling even of suspicions of such incidents. For this reason, the company will include psychosocial risks, including risks associated with violence and harassment, in the Occupational Risk Assessment Study, taking into account, among other things, any inherent risks arising from the nature of the activity, the job position, factors such as gender and age or other characteristics constituting grounds for 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 in Greece through the interactive online OIRA (Online Interactive Risk Assessment) platform of the European Agency for Safety and Health at Work (EU-OSHA) at http://www.oiraproject.eu.

II) Measures for the Prevention, Control, Limitation, and Handling of Such Risks, as well as Monitoring of Such Incidents or Behaviors

The company’s measures and practices for the prevention, control, limitation, handling, and monitoring of such incidents or behaviors include:

A) Encouraging a work climate where respect for human dignity, cooperation, and mutual support are core values.

B) Maintaining open communication between employees, company management, supervisors, and colleagues.

C) Establishing procedures for handling reports/complaints.

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

E) Providing assistance and access to any competent public, administrative, or judicial authority during the investigation of such incidents or behaviors, when requested.

F) Awareness initiatives promoting healthy behavioral standards (e.g., avoidance of addictions) and addressing issues concerning vulnerable groups of employees.

G) Providing employees with information regarding possible risks of violence and harassment in the workplace and the relevant preventive and protective measures, including employees’ and employer’s obligations and rights regarding such incidents.

H) Training employees in violence incident management procedures.

I) Posting information in an accessible location in the workplace regarding the complaint and response procedures for such behaviors.

III) Employee Information and Awareness Actions

Our company shall:

A) Organize targeted staff meetings to discuss relevant issues and promptly address potential risks.

B) Conduct seminars with mental health professionals, counseling service providers, representatives of volunteer organizations, etc.

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

IV) Information Regarding the Rights and Obligations of Employees and Employer

Every employee and generally every person referred to in paragraph 3 of the preamble who is affected by an incident of violence or harassment against them, even if their employment/contractual relationship has ended, has the right to:

A) Judicial protection.

B) File a complaint with the Labor Inspectorate through the citizen service hotline 1555 or via the website https://www.sepe.gov.gr/

C) Appeal to the Greek Ombudsman at:
17 Chalkokondyli Street, 104 32 Athens,
Tel: (+30) 213 1306 600,
Email: press@synigoros.gr

D) Contact the immediate psychological support and counseling service for women victims of gender-based violence through the SOS hotline 15900.

E) Report/file a complaint internally within our company as provided in Section B of this policy.

F) Request the company to take measures against the accused person and/or measures concerning their own protection in accordance with paragraph 2 of Article 12 of Law 4808/2021.

G) Leave the workplace for a reasonable period without loss of salary or other adverse consequences if, according to their reasonable belief, there is an imminent serious danger to their life, health, or safety, especially when necessary protective measures have not been taken or are insufficient to restore workplace peace and stop the violent or harassing behavior.

In such case, the employee must first inform the employer in writing, stating the incident and the reasons justifying the belief that a serious danger exists. If the danger no longer exists and the person refuses to return to work, the employer may refer the matter to the Labor Inspectorate for dispute resolution as provided in Article 18 of Law 4808/2021.

H) Claim full compensation before the courts, covering both actual damages and moral harm.

Every employee and generally every person referred to in paragraph 3 is obliged to:

A) Comply with this policy for their own protection and that of others employed by the company.

B) Immediately report any incident of violence and harassment to the designated liaison/reporting person under this policy.

C) Cooperate during the investigation of internal reports/complaints.

D) Participate in company training actions and programs regarding violence and harassment incidents.

E) Refrain from engaging in prohibited and unwanted behaviors in the course of their duties.

F) Immediately inform the designated liaison/reporting person of any incidents occurring in their work area or area of responsibility.

G) Not obstruct any person from exercising their rights and obligations under this policy and the law.

The company commits to taking all necessary, appropriate, and proportionate measures against the accused person to prevent recurrence of similar incidents or behavior.

V) Reporting Person (“Liaison”)

The reporting person (“liaison”) whom any employee may contact for guidance and information regarding the prevention and handling of violence and harassment at work is:

Georgios Tselios, son of Konstantinos,
General Manager of the company.

Contact details:
Telephone: 22410 96430 – 6947005770
Postal Address: Paralia Ialyssou, 85133, Ialyssos, Rhodes
Email: sbgm@harmonyresorts.gr

The role of the liaison is informative and consists of guiding and informing employees, regardless of whether they contact him regarding an incident or complaint of violence and harassment.

The liaison is obligated to protect Personal Data that may come to their knowledge in the exercise of their role.

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

VI) Protection of Victims of Domestic Violence

Our company protects employment and supports work through all appropriate means or reasonable accommodations for employees covered by 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) Responsible Persons & Communication Channels

The responsible person for receiving and examining reports/complaints and grievances regarding violence and/or harassment behaviors is:

Georgios Tselios, son of Konstantinos
Tel: 2241096430
Mobile: 6947005770

Any employee who believes they have suffered violence and/or harassment, as well as any employee who becomes aware of incidents violating this policy, may submit a written report/complaint through the following channels:

• Sending a letter to: Paralia Ialyssou, 85133, Ialyssos, Rhodes
• Sending an email to: sbgm@harmonyresorts.gr
• Delivering a letter directly to the responsible person: Georgios Tselios

All complaints/reports shall be handled with absolute discretion and confidentiality and stored securely.

The responsible person shall inform the affected individual that at any stage of the internal procedure they may also file a complaint with the competent administrative authorities (Labor Inspectorate and Greek Ombudsman) or judicial authorities.

II) Temporary Measures for the Complainant & Investigation and Examination of Complaints

A) Temporary Measures for the Complainant

Where necessary, and following agreement with the complainant/affected person, the company shall immediately take appropriate measures to protect them until the complaint is fully investigated and resolved. Indicative measures include:

1. Change of working hours and workdays.
2. Transfer of the complainant to another department or branch for an agreed period.
3. Teleworking, where the nature of the work permits.
4. Granting paid leave.

B) Investigation and Examination of Complaints

The company commits that the submission of any complaint under this policy shall not be obstructed and that every such complaint shall be managed and investigated promptly, impartially, respectfully, confidentially, and in compliance with personal data protection rules, while also taking immediate protective measures for the affected person.

All persons involved in the investigation (complainant, accused person, witnesses, etc.) are obliged to maintain confidentiality and comply with personal data protection rules.

Upon receipt of a complaint/report, the investigation process begins immediately by the responsible person.

1) Discussion with the Complainant

Within five (5) working days of receiving the complaint, the responsible person shall invite the complainant for discussion. The complainant is obliged to attend.

The complainant must further explain the alleged facts, while the responsible person may ask clarifying questions. At the end of the discussion, the complainant must submit written clarifications and sign them.

The responsible person may call the complainant again during the investigation. The complainant also has the right to request a hearing.

2) Summoning the Accused Person

After collecting information from the complainant, the responsible person shall invite the accused person within five (5) working days to inform them of the allegations and request a signed written response within five (5) working days.

After submission of the response, the accused person shall be invited for discussion and must answer truthfully. Clarifying questions may be asked. Written clarifications signed by the accused shall be submitted at the end.

The accused person also has the right to request a hearing.

3) Summoning Other Involved Persons

The responsible person may invite any employee involved in the complaint or any employee considered capable of providing useful information.

All involved persons are obliged to attend and provide all relevant information. Written signed clarifications are required after discussions.

4) Collection of Evidence from Company Records

With approval of the Board of Directors, the responsible person may access company records, audiovisual material, and other appropriate means to establish the facts of the complaint.

5) Informing the Company’s Board of Directors

The responsible person must fully inform the company’s legal representatives and Board of Directors regarding every complaint and every new fact or information arising.

The responsible person shall act in accordance with the approval of the company’s legal representatives.

III) Prohibition of Retaliation Against the Affected Person

Dismissal or termination of employment or any other adverse treatment of a person under Article 3 of Law 4808/2021 is prohibited and void where it constitutes retaliatory behavior or a countermeasure within the meaning of Article 14 of Law 3896/2010 regarding incidents of violence and harassment under Article 4 of Law 4808/2021.

However, this prohibition does not protect persons who intentionally submit false or malicious complaints. In such cases, the company may take legal measures or even terminate the employment or cooperation relationship.

IV) Consequences/Sanctions in Case of Violations

If complaints concerning violations of the Violence and Harassment Policy are wholly or partially confirmed, the company shall take all necessary, appropriate, and proportionate measures against the accused person to prevent recurrence.

Such measures may include:

• Written or verbal recommendation for compliance.
• Strict written reprimand.
• Change of position, working hours, place, or method of work.
• Temporary suspension from work for up to 10 days per calendar year.
• Termination of 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 Information to Competent Authorities

Our company and the responsible person handling complaints under this policy commit to cooperating with and providing information to every competent public, administrative, or judicial authority that requests information either ex officio or following a request from an affected person.

For this purpose, all collected information and evidence shall be maintained in a relevant file in accordance with the provisions of Law 4624/2019.