The company “GEORGIOS EVRIPIDIS KALANTZIS SINGLE-MEMBER P.C.”, demonstrating zero tolerance for incidents of violence and harassment in the workplace, adopts this policy in compliance with Articles 9 and 10 of Law 4808/2021, which ratified the International Labor Convention 190/21.06.2021 of the International Labor Organization (ILO) regarding the elimination of violence and harassment in the world of work, the text of which was annexed in its entirety to the law.

Purpose

The purpose of this policy is to create and establish a work environment that respects, promotes, and ensures human dignity and every individual’s right to a workplace free of discrimination, violence, and harassment. The company declares that it recognizes, respects, and protects the right of every employee to a work environment free from violence and harassment and does not tolerate any such behavior, regardless of its form or the person responsible.

Scope – Covered Individuals

This policy applies to the persons referred to in paragraph 1 of Article 3 of Law 4808/2021. It covers all types of employees and workers of “GEORGIOS EVRIPIDIS KALANTZIS SINGLE-MEMBER P.C.”, regardless of their contractual status, as well as job applicants and other individuals who interact or collaborate with the company.

Prohibited Forms of Behavior – Definitions

Violence and harassment: Includes behaviors, acts, practices, or threats thereof that aim at, result in, or may result in physical, psychological, sexual, or economic harm, whether occurring as isolated incidents or repeatedly.

Harassment

Refers to behaviors intended to or resulting in the violation of an individual’s dignity and the creation of an intimidating, hostile, degrading, humiliating, or offensive environment, regardless of whether they constitute a form of discrimination. It includes gender-based harassment or harassment due to other discrimination factors.

Gender-based harassment

Refers to behaviors related to a person’s gender that aim at or result in the violation of their dignity and the creation of an intimidating, hostile, degrading, humiliating, or offensive environment. This includes sexual harassment and behaviors associated with sexual orientation, gender identity, expression, or characteristics.

Discrimination

Defined as the differential treatment of individuals due to prejudices or interests, unjustified distinctions based on group affiliation, class, or other categories. Examples include discrimination based on gender, age, language, nationality, race or ethnicity, disability, religious beliefs, or sexual orientation.

Incidents

The forms of behavior prohibited by this policy include, but are not limited to: discrimination-based insults related to gender, race, religion, appearance, sexual orientation, disability, age, or other personal characteristics and choices; threats, whether verbal or through gestures; insults, whether in public or private; the belittling or mocking of an individual or their abilities, either privately or in the presence of others; threatened or actual physical violence; and persistent or unjustified criticism.

Additionally, the following are prohibited:

abusive, malicious, derogatory, obscene, or mocking comments and their dissemination; innuendos; sexist or racist “jokes” and remarks; the use of offensive language; verbal sexual harassment or propositions; insinuations that sexual favors can advance one’s career or that refusal to engage in a sexual relationship could negatively impact professional progress within “GEORGIOS EVRIPIDIS KALANTZIS SINGLE-MEMBER P.C.”; offering benefits (e.g., promotion or salary increase) in exchange for sexual favors; or creating an environment that promotes “sexual relations” as a means of career advancement in the workplace.

Furthermore, retaliation or threats of retaliation following the rejection of sexual advances, cyberbullying, sending harassing and offensive messages via SMS, email, social media, fax, or letters, and persistent or offensive questioning about an individual’s age, marital status, personal life, sexual orientation, race, ethnicity, cultural identity, or religion without a legitimate reason are prohibited.

Visual forms of harassment, such as posters, cartoons, caricatures, photographs, or drawings that are derogatory based on legally protected characteristics, are also included. Additionally, unwanted physical contact such as touching, pinching, sexual gestures, hitting, grabbing, pushing, and any form of physical violence is prohibited. Violations of privacy, intentional partial or complete destruction of personal belongings, vehicles, or property, interference with or obstruction of normal work, movement, and physical integrity, physical confinement or restriction, sexual gestures, physical stalking, and pursuit are also considered violations.

The aforementioned acts are indicative and do not constitute an exhaustive list of prohibited behaviors.

Acceptable Behaviors

The following behaviors do not constitute incidents of violence or harassment:

• The direct supervision of employees, including setting performance expectations.
• Taking measures to correct performance, such as placing an employee on a performance improvement plan.
• Assigning tasks and providing guidance on how and when they should be completed.
• Requesting updates or progress reports on work.
• Approving or justifiably denying leave.
• Requesting documentation for absences due to health reasons in accordance with applicable legal provisions.
• Ethical or financial rewards for excellent employee performance.
• Providing constructive feedback on work performance.
  

Scope – Determination of the Workplace

a. The workplace is understood as a broader spatial framework in which incidents of violence and harassment can occur. The aforementioned forms of behavior may take place in the offices of the company “GEORGIOS EVRIPIDIS KALANTZIS MONOPROSOPOI I.K.E.”, where employees provide their services, as well as in the areas where employees take breaks for rest or meals, or in individual hygiene and care facilities. Furthermore, this policy also covers any kind of travel to and from work, other work-related trips, training seminars, educational activities, as well as social events and activities related to work or connected with the company’s actions. Finally, it applies to all forms of communication related to the company, including those conducted through information and communication technologies (e.g., emails, Zoom or Teams meetings, social media, etc.). 

b. Domestic Violence- All acts of physical, sexual, psychological, or economic violence that take place within the family or home, regardless of biological or legal family ties, or between former or current spouses or partners, and regardless of whether the perpetrator shares or has previously shared the same residence with the victim. Domestic violence that occurs in the workplace, such as physical violence, sexual harassment, and stalking by current or former partners, constitutes a serious form of violence in the workplace.

Acts of domestic violence, including stalking/surveillance, can also be perpetrated by individuals within the same work environment, with whom the victim has (or had in the past) close relationships. Domestic violence, in any of the aforementioned forms, that is exercised against an employee during remote working.

Assessment of Violence and Harassment Risks in the Workplace

a. Evaluation of Risk Factors and Improvement

The company “GEORGIOS EVRIPIDIS KALANTZIS MONOPROSOPOI I.K.E.” collaborates with all its departments to study the potential risk factors depending on the nature and scope of the work provided, the psychosocial risks, including risks of violence and harassment in the workplace, with the aim of evaluating the existing working conditions and adjusting them in a way that minimizes the likelihood of incidents of violence and harassment occurring in the workplace.

Examples of risk situations include: high stress in the workplace, isolated or closed workspaces, distribution of workstations, facility safety and their control, lack of proper training, individuals with a history of violent behavior, delivery of goods or services, individual or isolated work, working late at night or in the early morning hours, personal or domestic issues spilling over into the workplace.

b. Organization of Seminars, Issuance of Informational Materials, and Regular Staff Training on Violence and Harassment Issues

All employees must understand which behaviors constitute violence and harassment, and recognize them as unacceptable and reprehensible. The designated contact person for issues of violence and harassment will ensure that the staff receives the appropriate awareness training on violence and harassment and will make this policy known both within and outside the company.

Preventive Measures for Incidents of Violence and Harassment 

a. Information on the Rights of Affected Individuals

The company “GEORGIOS EVRIPIDIS KALANTZIS MONOPROSOPOI I.K.E.” states that if an individual is affected by an incident of violence or harassment during access to employment, during the course of their employment relationship, or even after the termination of the contract or employment relationship in which the incident or behavior allegedly occurred, they have the following rights:

1. a) The right to judicial protection,
   b) The right to file a complaint, report, and request a labor dispute investigation with the Labor Inspectorate, within its legal authority,
   c) The right to report to the Ombudsman, within its legal authority, and
   d) The right to report within the company according to the complaint management policy.

The specific procedures for submitting, managing, and internally investigating reports include the detailed steps to be taken by any complainant, as well as the responsibilities of the personnel of “GEORGIOS EVRIPIDIS KALANTZIS MONOPROSOPOI I.K.E.” and the actions they must take to ensure the effective management of related incidents. In every case, when a report or complaint of such behavior arises within the company, the affected individual retains the right to appeal to any competent authority. Any employee who experiences domestic violence that extends into the workplace may report this incident verbally or in writing to Mr. Georgios Kalantzis in order for the company to be informed and take the appropriate and necessary measures.

b. Actions for Information, Awareness, and Support of Staff

The company “GEORGIOS EVRIPIDIS KALANTZIS MONOPROSOPOI I.K.E.” hereby informs its staff and displays in a visible location the contact details of the competent administrative authorities to which any aggrieved party has the right to appeal (Labor Inspectorate, Ombudsman), specifically informing them about the SEPE complaint hotline (15512) as well as the citizens’ service line 1555 and the website https://1555.gov.gr/. Additionally, the company informs about the immediate psychological support and counseling service for women victims of gender-based violence, with the SOS Line 15900 (General Secretariat for Demographic and Family Policy and Gender Equality [G.G.I.F.]).

The company “GEORGIOS EVRIPIDIS KALANTZIS MONOPROSOPOI I.K.E.” takes all appropriate measures within its capabilities and makes every reasonable adjustment to the working conditions for the protection of employment and the support of employees who are victims of domestic violence. The company also takes all necessary measures to inform and raise awareness among its staff, using the aforementioned appropriate means to combat violence and harassment, ensuring that everyone is aware of the company’s policies and procedures regarding incidents of violence and harassment, knows where to turn in case of violence or harassment, and understands the possibilities provided by the law.

The company trains its staff in any suitable way and with available means to recognize discrimination, violence, and harassment in the workplace and to provide the required support to its employees and partners. Furthermore, it encourages the participation of employees and management in training programs and seminars related to the identification and management of potential risks of violence and harassment. The company may also conduct seminars with mental health experts or counseling service providers.

Procedure for Submitting and Managing Internal Complaints – Point of Contact

Any employee who has been subject to any incident of violence or harassment may submit an oral or written complaint to Mr. Georgios Kalantzis, who is designated as the “point of contact” for this policy. The complaint can be submitted in person or via email to the address info@ieengineering.gr. The complaint cannot be anonymous.
The complaint must include the details of the person being reported, i.e., the individual who engaged in a form of prohibited behavior, as well as specific incident(s) that substantiate the claim.
The point of contact thoroughly investigates each complaint and gathers any necessary information related to it. Complaints and investigations remain strictly confidential to the maximum extent possible, considering the sensitivity of the matter and the privacy of all parties involved.
In particular, the point of contact may speak with the complainant and the accused, examine witnesses, request the submission of any relevant documents, and communicate with department supervisors in case the complainant approached them.
Once the point of contact completes their investigation, they submit a written report to the company’s Management, which includes the findings of the investigation. The results of the investigation are also communicated to both the complainant and the accused to ensure they are aware of the outcome. The completion of the investigation and the submission and communication of the findings must occur as soon as possible and, in any case, no later than three weeks from the date the complaint was submitted by the complainant.

If it is determined that an incident of discriminatory treatment, violence, harassment, or retaliation has occurred, the company’s Management will take all necessary, appropriate, and proportionate measures against the accused.
These measures may include, but are not limited to:
a) issuing a compliance warning,
b) changing the job position, working hours, location, or method of work,
c) terminating the employment or cooperation contract with the company, subject to the prohibition of abuse of rights under Article 281 of the Civil Code.

Complaints that are found to be clearly malicious will be considered inadmissible and will be further investigated at the company’s discretion, both in terms of motives and involvement of the parties, in order to restore order through all lawful means and action.

Rights of Victims

According to the current legislation, any person who is subjected to an incident of violence or harassment has the right to leave the workplace for a reasonable period of time, without salary deduction or other adverse consequences, if they reasonably believe that there is an imminent serious threat to their life, health, or safety, especially when the employer is the perpetrator of such behavior or when the employer does not take the necessary appropriate measures to restore workplace peace, or when these measures are insufficient to stop the violence and harassment behavior.

In this case, the person leaving the workplace is required to inform the designated reference person in writing, stating the incident of violence and harassment, and the circumstances that justify their belief that there is an imminent serious threat to their life, health, or safety.

Employees who face incidents of violence and harassment in the workplace have the right to appeal to the competent authorities, as prescribed by law (a. the right to judicial protection, b. the right to appeal and file a complaint and request for the investigation of an employment dispute with the Labor Inspectorate, within its legal competencies, c. a report to the Ombudsman, within its legal competencies).

Obligation of Impartiality and Confidentiality

The person in charge is required to act in an objective and impartial manner during the investigation of complaints. Furthermore, they must behave respectfully towards all involved parties and in a confidential and discreet manner. It is strictly prohibited to disclose or make known to non-involved parties any details related to the complaint under investigation. These obligations also apply to the management of the company during the final stage of taking measures and decisions.

Prohibition of Retaliation – Victimization of the Whistleblower

Retaliation and victimization of the whistleblower, who, as the affected party, has asserted their rights and submitted a written complaint regarding an incident of violence or harassment, is prohibited. Retaliation and victimization of the whistleblower constitute a serious violation of this policy and will result in consequences for the person engaging in such behavior. If any employee or third party associated in any way with the company believes they have been subjected to retaliatory behavior due to filing a complaint or providing assistance in the investigation of incidents of discrimination, violence, or/and harassment, they are required to follow the aforementioned procedure to report such retaliatory incidents.

Collaboration with Administrative and Judicial Authorities

The company “GEORGIOS EVRIPIDIS KALANTZIS MONOPROSOPI I.K.E.” and any responsible person or service for the reception and management of such complaints cooperate with any competent public, administrative, or judicial authority that, either ex officio or upon request from an affected individual, within its competence, requests the provision of data or information, and is committed to offering assistance and access to the data. For this purpose, any data they collect, in any form, is kept in a relevant file, in accordance with the provisions of Law 4624/2019 (A’ 137) “Personal Data Protection Authority, measures for the application of Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, regarding the protection of natural persons against the processing of personal data.”

For more information regarding this policy, any interested individual may contact Mr. Georgios Kalantzis.
This policy is posted on the official website of the company at the following link: www.ieengineering.gr.