POLICY TO COMBAT VIOLENCE AND HARASSMENT AT WORK
POLICY FOR THE MANAGEMENT OF INTERNAL COMPLAINTS OF INCIDENTS OF VIOLENCE AND HARASSMENT
The Technical Department Store Aslanidis Theodoros & Co. O.E. 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 International Labor Convention 190/21.06.2021 of the International Labor Organization (ILO), on the elimination of violence and harassment in the world of work, the text of which he annexed verbatim to the text of the law.
1.Purpose
The purpose of this policy is to create and consolidate a work environment that respects, promotes and ensures human dignity and the right of every person to a world of work free of discrimination, violence and harassment. Aslanidis Theodoros & Co. O.E. declares that it recognizes, respects and protects the right of every employee to a work environment free of violence and harassment and that it does not tolerate any such behavior, of any form, by any person.
2. Scope of Application – Subordinate Persons
This policy covers the persons of par. 1 of no. 3 of Law 4808/2021 and its scope of application and protection includes all types of workers and those employed by Aslanidis Theodoros & Co. O.E., regardless of their contractual status, (including those employed under a project contract, independent services, salaried mandate, employed through third-party service providers, persons attending training, including trainees and apprentices, volunteers), persons whose employment relationship has ended, persons applying for work and other persons who deal with or cooperate with it .
3. Prohibited forms of conduct – Definitions
Violence and harassment. "Violence and harassment" means the forms of behavior, acts, practices or threats thereof, which are intended, lead to or may lead to physical, psychological, sexual or financial harm, whether manifested individually or repeatedly, Harassment. "Harassment" means forms of behavior that have the purpose or effect of violating a person's dignity and creating an intimidating, hostile, humiliating, humiliating or aggressive environment, regardless of whether they constitute a form of discrimination, and include harassment based on gender or other grounds of discrimination.
Gender based harassment. "Gender-based harassment" means forms of behavior linked to a person's gender, which have the purpose or effect of violating the dignity of that person and creating an intimidating, hostile, humiliating, humiliating or aggressive environment in accordance with Article 2 of Law 3896/2010 (A' 107) and paragraph 2 of Article 2 of Law 4443/2016 (A' 232). These forms of behavior include the sexual harassment of Law 3896/2010, as well as forms of behavior linked to the person's sexual orientation, expression, identity or gender characteristics.
Discrimination. "Discrimination" means different treatment of people arising from prejudices or interests, any act by which individuals are unjustifiably separated on the basis of the groups, classes or other categories to which they belong or are perceived to belong. For example, discrimination based on sex, age, language, nationality, race or ethnicity, disability, religious beliefs or sexual orientation.
Incidents. The forms of conduct prohibited by this policy include, but are not limited to: Insults based on discrimination based on gender, race, religion, appearance, sexual orientation, disability, age, or other personal characteristics and choices, threats, verbal or by gestures, Insults in public or in private, belittling or ridiculing a person or their abilities, whether in private or in front of others, threatened or actual physical violence, persistent or unjustified criticism. Abusive, malicious, derogatory, obscene or derisive comments and their dissemination, innuendos, sexist or racist "jokes" and comments, use of offensive language, verbal sexual harassment or suggestions, insinuations that someone's sexual favors can advance one's career or that refusing to engage in sexual intercourse may negatively affect one's career path within the Company, offering benefits (e.g., promotion or salary increase) in exchange for sexual favors, or creating an environment that promotes "sexual contact' as a means of professional development in the workplace, retaliating or threatening retaliation after rejecting sexual advances. Cyberbullying, sending messages with harassing and offensive content via SMS, e-mail, social media, fax or letter, persistent or even offensive questions about age, marital status, personal life, without legal reason or reason, sexual orientation, and similar questions about race or ethnicity, including cultural identity and religion. Also included are visual forms of harassment such as e.g. posters, cartoons, photographs or designs that are derogatory based on characteristics protected by law. Unwanted physical contact such as touching, pinching, gestures of a sexual nature, hitting, grabbing, pushing as well as physical violence of any kind. Invasion of privacy, intentional partial or total destruction of personal belongings, vehicles or property, interference with or obstruction of a person's normal work, movement and physical integrity, physical exclusion or confinement, sexual gestures, physical surveillance, the pursuit. The above acts are indicative and do not constitute an exclusive list of prohibited acts.
Fair behaviors. The following behaviors do not constitute incidents of violence and harassment. Directly supervise employees, including setting performance expectations. Taking action to correct performance, such as placing an employee on a performance improvement plan. Assigning tasks and guidance on how and when they should be done. Request for updates or progress reports. The approval or justified refusal of permission. Request for documentation of absence for health reasons based on the applicable legal provisions. The moral or financial reward of excellent employee performance. Providing constructive feedback on work performance.
4. Scope – Determination of the Workplace
4.a. A workplace is a wider spatial context in which incidents of violence and harassment can take place. The above forms of behavior may take place in all company facilities nationwide, in which employees provide their services, as well as in those areas where employees receive their pay, take a break for rest or food, in personal hygiene areas and care. Also, this policy covers all types of travel to and from work, other travel, travel, conferences, training, as well as social events and activities related to work or connected to the actions of the company. Finally, it also applies to all communications related to the company, including those carried out through IT and communication technologies (e.g. e-mails, zoom or team meetings, social media, etc.).
4.b. Domestic violence – All acts of physical, sexual, psychological or financial 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 previously shared the same residence as the victim. Domestic violence that takes place in the workplace, for example through physical violence, sexual harassment and stalking by current or former partners, is a serious form of workplace violence. Acts of domestic violence, including stalking, can also be committed by people in the same work environment, with whom they have (or have had) close relationships. Domestic violence, in any of the above forms, inflicted on the employee during telework.
5. Assessing the risks of violence and harassment at work
5.a. Assessment of risk factors and their improvement.
Aslanidis Theodoros & Co. O.E. studies in collaboration with all its departments and the competent occupational physician the possible risk factors depending on the nature and scope of the work provided, the psychosocial risks, including the risks of violence and harassment at work, in order to evaluate the existing conditions work and their adjustment in a way to limit as much as possible the chances of an incident of violence and harassment taking place in the workplace.
Indicative cases of risk are mentioned such as: high stress in the workplace, isolated or closed workplaces, distribution of jobs, safety of facilities and their control, lack of appropriate training, people with a history of violent behavior, delivery of goods or services, working individually or in an isolated area , working late at night or in the morning hours, domestic or personal life issues spilling over into the workplace.
5.b. Organization of seminars, publication of informational forms and regular training of the staff in matters of violence and harassment.
All employees must understand that those behaviors that constitute violence and harassment are not tolerated and frowned upon. The appropriate reporting person for matters of violence and harassment will ensure that staff receive appropriate awareness of matters of violence and harassment and will make this policy known within and outside the company.
6. Measures to prevent incidents of violence and harassment.
6.a. Information on the rights of affected persons.
Aslanidis Theodoros & Co. O.E. states that in the event that a person is affected by an incident of violence and harassment during access to employment, during the employment relationship or even if the contract or employment relationship in the context of which the incident or conduct allegedly occurred has ended, he has :
a) right to judicial protection,
b) appealing, submitting a complaint and applying for a labor dispute to the Labor Inspectorate, within the framework of its legal powers,
c) reporting to the Ombudsman, within the framework of his legal powers, as well as
d) complaint within the company in accordance with the complaint management policy.
The individual procedures for submission, management and internal investigation of reports include the detailed steps that any complainant must take, as well as the responsibilities of the bodies of Aslanidis Theodoros & Co. O.E. and the actions they must take to ensure effective related event management. In any case, when there is a report or complaint of such behavior within the company, the affected person retains every right to appeal to any competent authority. Any employee who experiences domestic violence, which also extends to the workplace, can report this fact verbally or in writing to his supervisor in order for the company to be informed and to take the appropriate and necessary measures.
6.b. Actions to inform, raise awareness and support staff.
Aslanidis Theodoros & Co. O.E. hereby informs the staff and maintains in a visible place the details of the competent administrative authorities, to which any affected person has the right to appeal (Labour Inspectorate, Ombudsman), in particular informs about the SEPE complaint hotline (15512) but also through the citizen service line 1555 and https://1555.gov.gr/, as well as for the service of immediate psychological support and counseling for female victims of gender-based violence who can contact the SOS Line 15900 (General Secretariat of Demographic and Family of Politics and Gender Equality [G.G.I.F.].
Aslanidis Theodoros & SIA O.O., within the limits of its capabilities, takes every appropriate measure and makes every reasonable adjustment of working conditions to protect employment and support employees - victims of domestic violence. It also takes all necessary measures to inform and sensitize the staff, using the appropriate means, as above, to combat violence and harassment, ensuring that everyone is aware of the company's policy and procedures against incidents of violence and harassment, they know who they can turn to in case of violence or harassment, as well as the possibilities given to them by law.
Aslanidis Theodoros & Co. O.E. trains its executives in every possible way and means to recognize discrimination, violence and harassment at work and to provide the required support to its staff and partners. It also encourages the participation of management executives in training programs and educational seminars regarding the recognition and management of potential risks of violence and harassment, as it may also hold seminars with mental health specialists or counseling service providers.
7. Procedure for Submission and Management of Internal Complaints – Reporting Person
Any employee against whom any incident of violence and harassment has occurred, may submit a verbal or written complaint to ASLANIDIS CHRISTOS (CEO and Full Member of Aslanidis Theodoros & Co. O.E.), who is also defined as a "person of reference", for this policy. The complaint can be submitted in person or via e-mail to the e-mail address info@aslanidisbuild.gr. The complaint cannot be made anonymously. The complaint should include the details of the person complained of, i.e. the person who engaged in a form of prohibited behavior, as well as the specific incident(s) that substantiate it.
The reporting person thoroughly investigates each complaint and collects any necessary information about it. Complaints and investigations remain strictly confidential to the greatest extent possible, taking into account the sensitivity of the case and the privacy of all involved.
In particular, they may speak with the complainant and the person complained of, examine witnesses, request the production of documents that may exist and from which it is proven that any incident of violence and harassment took place or not and communicate with the heads of each department, in case the complainant addressed them. Once the reporting person has completed his investigation, he submits a written report to the company's Management, in which he states the result of the investigations. The results of the investigation are simultaneously communicated to both the complainant and the complained-of, in order for them to become aware of them. The completion of the investigation and the submission and communication of the reporting person's conclusion must take place as soon as possible and in any case no later than the period of 3 weeks from the date of submission of the complaint by the complainant.
-In the event that an incident of discriminatory treatment, violence or harassment or retaliation actually occurs, the Company's Management will, on a case-by-case basis, take all necessary, appropriate and appropriate measures against the person complained of.
These measures may include but are not limited to:
a) the compliance recommendation,
b) changing his job position, hours, place and way of providing work,
c) the termination of the contract of employment or cooperation with the company, subject to the prohibition of the abuse of rights of Article 281 of the Civil Code.
-Complaints which prove to be clearly malicious will be considered unacceptable and will be further investigated at the company's discretion, both in terms of motives and those involved, in order to restore order by any legal means.
8. Rights of victims
According to the current legislation, every person who experiences an incident of violence and harassment against him has the right to leave the workplace for a reasonable time, without loss of salary or other adverse consequence, if in his reasonable belief there is an imminent serious risk to the his life, health or safety, in particular, when the employer is the perpetrator of such behavior or when he does not take the necessary appropriate measures to restore work peace, or when these measures are not sufficient to stop the violent behavior and harassment.
In this case, the person leaving is obliged to inform the reporting person beforehand in writing, mentioning the incident of violence and harassment and the incidents that justify his belief that there is an imminent serious risk to his life, health or safety. Employees who face incidents of violence and harassment at work have the right to appeal to the competent authorities, as defined by the legislation (a. right to judicial protection, b. right to appeal and submit a complaint and request for a labor dispute to the Labor Inspectorate, within the framework of its statutory powers, c. reference to the Ombudsman, within the framework of his statutory powers).
9. Obligation of impartiality and confidentiality
The reporting person is required to act in the complaint investigation process in an objective and impartial manner. In addition, he must behave with respect to all parties involved and in a confidential and confidential manner. It is completely prohibited to publish or disclose to non-involved parties any information concerning the complaint under review. The above obligations also fall on the Management of the company during the final stage of taking measures and decisions.
10. Prohibition of Retaliation – Victimization of the Complainant
Retaliation and victimization of the complainant who, as an aggrieved person, asserted his rights and submitted a written complaint regarding an incident of violence and harassment is prohibited. Retaliating against and victimizing the complainant is a serious violation of this policy and carries consequences for the person doing so. If any employee or third party associated in any way with the company believes that they have suffered retaliatory behavior as a result of filing a complaint or providing assistance in the process of investigating incidents of discrimination, violence and/or harassment, they must follow the above procedure for reporting of the retaliation incident in question.
11. Cooperation with administrative and judicial authorities
Aslanidis Theodoros & Co. O.E., as well as any competent person or agency for the reception and management of such complaints at a corporate level, cooperate with any competent public, administrative or judicial authority, which, either ex officio or upon submission of a request by an affected person , within the scope of its competence, requests the provision of data or information and undertakes to provide assistance and access to the data. To this end, any information collected, in any form, is kept in a relevant file in compliance with the provisions of Law 4624/2019 (A' 137) "Personal Data Protection Principle, implementing measures of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons against data processing."
The CEO of Aslanidis Theodoros & Co. O.E
ASLANIDIS CHRISTOS
Economist & Supply Chain, Logistics Manager
The SEO of Aslanidis Theodoros & Co. O.E
ASLANIDIS NIKOLAOS
For more information about this policy each
interested person can contact Mr. ASLANIDIS
CHRISTOS (CEO and Associate Member of Aslanidis Theodoros & Co. O.E.)