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  • POLICY FOR THE PREVENTION

POLICY FOR THE PREVENTION AND COMBAT OF DISCRIMINATION, VIOLENCE, AND HARASSMENT IN THE WORKPLACE AND PROCEDURE FOR SUBMITTING AND INVESTIGATING COMPLAINTS

 

  1. PURPOSE

The Employer Company DG THIRA LTD (hereinafter referred to as “the Company”) complies fully with all measures and obligations concerning the implementation of the provisions of Part II of Law 4808/2021 on the prevention and combat of all forms of violence and harassment, including gender-based violence and harassment and sexual harassment.

The Company affirms its commitment to maintaining a workplace in which all individuals are treated with respect and dignity. Every person has the right to work in a professional environment that promotes equal employment opportunities and strictly prohibits unlawful discriminatory practices, including any form of violence or harassment.

Accordingly, the Company expects that all interpersonal relationships within its premises shall be conducted in a professional manner, free from discrimination, prejudice, violence, or harassment.

This Policy has been developed to ensure that all employees can work in an environment free from violence, unlawful harassment, discrimination, and retaliation. The Company shall make every reasonable effort to ensure that all persons bound by this Policy are familiar with its contents and are aware that any complaint relating to its violation will be duly investigated and appropriately resolved.

It is hereby expressly and unequivocally stated that any form of discrimination, violence, or harassment occurring in the course of employment, in connection with work, or arising therefrom, is strictly prohibited.

This Policy shall not and cannot be used as a basis for the exclusion or segregation of individuals on the grounds of gender or any other protected characteristic.

The law and the Company’s internal policies prohibit differential treatment on the basis of gender or any other protected attribute with respect to the terms, conditions, privileges, or rights of employment. The prohibitions against violence, harassment, discrimination, and retaliation are intended to supplement and reinforce these protections, not to serve as a basis for exemption from them.

  1. SCOPE

All employees and any persons in any way associated with the Company are required to comply with this Policy.

This Policy applies to the Management and members of the Company, to all job applicants, employees under contracts of dependent employment, and individuals providing services under contracts of retainer, project-based work, independent service agreements, or temporary employment.

It also applies to:

  • Former employees whose employment relationship with the Company has ended;
  • Persons engaged through third-party service providers;
  • Interns and apprentices;

and it governs conduct originating from either colleagues or third parties not directly affiliated with the Company (such as external vendors, consultants, or clients).

Behavior prohibited under this Policy is deemed unacceptable in all work-related contexts, whether:

  • On Company premises or during remote work (including online or telephone communication); or
  • In any professional setting outside the workplace, such as business travel, meetings, or work-related social events.
  1. DEFINITIONS

3.1 Discrimination

“Discrimination” refers to any unequal treatment based on gender, race, color, ethnic or social origin, genetic features, language, religion or belief, political opinion, disability or health condition, age, or sexual orientation.

Any form of harassment or threat based on these or any other protected characteristics is strictly prohibited, particularly where such behavior aims at, leads to, or is likely to result in physical, psychological, sexual, or economic harm, whether isolated or repeated.

3.2 Harassment

“Harassment” refers to any form of behavior that has the purpose or effect of violating the dignity of a person and creating an intimidating, hostile, degrading, humiliating, or offensive environment, regardless of whether such behavior constitutes a form of discrimination.

It includes harassment based on gender or any other protected ground.

For the purposes of this Policy, harassment may take the form of verbal, written, or physical behavior that demeans, intimidates, or shows hostility or aversion toward an individual on the basis of race, color, religion, gender, sexual orientation, gender identity or expression, national origin, age, disability, marital status, citizenship, genetic information, or any other legally protected characteristic, as well as toward persons associated with such individuals (e.g. relatives, friends, or colleagues).

Harassment exists when such behavior:
a) has the purpose or effect of creating an intimidating, hostile, or offensive work environment;
b) has the purpose or effect of unjustifiably interfering with an individual’s work performance; or
c) otherwise negatively affects an individual’s employment opportunities.

Indicative — but not exhaustive — examples of harassing behavior include:

  • Verbal or written comments, insults, or negative stereotypes, threats, intimidation, or hostile acts, as well as demeaning jokes or the circulation of offensive written or graphic materials that demean or show hostility or aversion toward an individual or group. Such materials may be displayed on walls or other areas of the workplace, or circulated during working hours using Company equipment or systems (e.g. email, telephone—including voicemail—text messages, social media platforms, or other electronic means).
  • Physical harassment, including but not limited to physical interference with normal work or movement, or moral harassment (“mobbing”), that is, the systematic, deliberate, and continuous exercise of psychological or moral pressure through actions such as exclusion, malicious remarks regarding alleged poor performance, or assignment to a “dead-end” position without duties or meaningful work, with the aim of creating a hostile or humiliating environment that offends the employee’s personality, dignity, or mental and physical integrity, in order to induce resignation.
  • Retaliation or intimidation against any person who reports or threatens to report any of the above forms of harassment, or who cooperates in the investigation of such incidents.

3.3 Gender-Based and Sexual Harassment

“Gender-based harassment” refers to behavior connected to a person’s gender that has the purpose or effect of violating that person’s dignity and creating an intimidating, hostile, degrading, humiliating, or offensive environment.

Such behavior includes sexual harassment and conduct related to a person’s sexual orientation, gender identity, gender expression, or gender characteristics.

“Sexual harassment” is defined as unwanted conduct of a sexual nature, which includes unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature, when for example:
a) submission to such conduct, explicitly or implicitly, becomes a condition of employment;
b) submission to or rejection of such conduct by an individual is used as the basis for employment decisions affecting that individual; or
c) such conduct has the purpose or effect of unreasonably interfering with an individual’s work performance or creating an intimidating, hostile, or offensive work environment.

Sexual harassment may involve a wide range of behaviors, both subtle and overt, and may occur between individuals of the same or different gender. Depending on the circumstances, such behavior may include, but is not limited to:

  • Unwelcome sexual advances or requests for sexual favors;
  • Sexual jokes, comments, or innuendos;
  • Verbal references to sexual conduct or physical attributes;
  • Display or circulation of sexually suggestive objects or images;
  • Any other conduct of a sexual nature that undermines professional integrity and personal dignity.

The above acts are indicative and not exhaustive.

Any employee or third party who engages in such prohibited behavior shall bear full responsibility and consequences for their actions.

  1. ASSESSMENT OF RISKS OF VIOLENCE AND HARASSMENT IN THE WORKPLACE

The risks arising from incidents of violence and harassment in the workplace may prove to be extremely serious, affecting both employees and the Company itself.

Specifically, for employees, such risks include, in particular:
a) Violation of human dignity and moral harm;
b) Stress, anxiety, anger, and fear experienced during work performance;
c) Psychosomatic symptoms, such as headaches, palpitations, increased blood pressure, and sleep disorders.

At the same time, the Company faces risks such as:
a) Disruption of labor relations and interference with the smooth operation of the business;
b) Reduced productivity;
c) Legal and financial consequences; and
d) Negative publicity and reputational damage.

However, the preventive, monitoring, and corrective measures implemented by the Company to manage and mitigate risks of workplace violence and harassment, together with the awareness and education initiatives it conducts for its personnel on these issues — in conjunction with effective work organization methods, the nature of its business activities, and strict compliance with applicable occupational health and safety legislation — contribute substantially to enhancing employee protection and effectively addressing these risks.

4.1 Safe and Respectful Work Environment

The Company is committed to maintaining a safe, friendly, and inclusive working environment, where interpersonal relationships are characterized by respect for human dignity, cooperation, trust, and mutual support.

The Company conducts annual inspections of its facilities to assess and identify any vulnerabilities or potential exposure to violence or harassment in the workplace, and it takes any necessary corrective actions to minimize such risks.

Within its means, the Company adopts appropriate measures to guide, support, and facilitate the reintegration of employees who are victims of domestic violence, including, where feasible, reasonable adjustments to working conditions to safeguard employment and provide assistance.

4.2 Education, Awareness, and Training

The Company employs a variety of methods to inform, educate, and sensitize its staff on issues related to violence and harassment in the workplace. These include, but are not limited to:

  • Distribution of printed and electronic informational materials;
  • Participation in training sessions, seminars, or mental health workshops; and
  • Ensuring all employees are aware of the Company’s Policies, the procedures in place, and the appropriate points of contact for reporting incidents of violence or harassment.

The Company also organizes targeted group and individual meetings with employees to discuss relevant issues and to proactively address potential risks. Employees are encouraged to participate in training and educational programs aimed at the recognition and management of workplace violence and harassment phenomena.

4.3 Reporting and Continuous Improvement

The Company encourages all employees and any third parties associated with it, in any capacity, to report incidents of discrimination, violence, or harassment that they experience, witness, or become aware of in the workplace.

The Company periodically assesses the effectiveness of this Policy and proceeds with its update or revision whenever deemed necessary.

4.4 Zero-Tolerance Commitment

The Company declares its zero-tolerance stance toward any form of violence or harassment and undertakes the following actions to raise awareness among its personnel:

  1. a) Provides information to employees regarding the risks of violence and harassment, the relevant preventive and protective measures, the procedures available within the Company, and the legal options available under current legislation;
    b) May organize targeted staff meetings to discuss related issues and proactively address potential risks;
    c) May conduct seminars with mental health professionals or providers of counseling and support services; and
    d) Encourages the participation of employees and management representatives in training and educational programs concerning the identification and management of risks of violence and harassment in the workplace.
  2. INFORMATION ON THE RIGHTS AND OBLIGATIONS OF EMPLOYEES AND THE COMPANY IN CASES OF VIOLENCE AND HARASSMENT, AND RELATED PROCEDURES

5.1 Rights of Persons Affected by Incidents of Violence or Harassment

5.1.1 Available Remedies

In the event that an individual experiences an incident of violence or harassment during recruitment, throughout the course of employment or cooperation with the Company, or even after the termination of the employment or cooperation under which such conduct occurred, the affected person shall have the following rights:

  1. a) The right to judicial protection;
    b) The right to file a complaint or request a labor dispute resolution with the Labor Inspectorate, within the scope of its legal authority;
    c) The right to submit a report to the Greek Ombudsman, acting within its statutory authority as the body responsible for promoting and monitoring the principle of equal treatment;

In all such cases, the affected individual retains the full right to seek recourse before any competent authority for the protection of their legal rights.

5.1.2 Temporary Withdrawal from the Workplace

Any individual subject to this Policy who is a victim of violence or harassment at work shall have the right to withdraw from the workplace for a reasonable period of time, without loss of pay or other adverse consequence, provided that the individual reasonably believes there is an imminent and serious threat to their life, health, or safety — particularly where:

  • The perpetrator of such behavior is a person exercising managerial authority or representing the Company, or
  • The Company fails to take appropriate and effective measures to restore workplace peace, or such measures prove insufficient to eliminate the violent or harassing behavior.

In such cases, the withdrawing employee must inform the Company’s Designated Liaison Officer in writing, stating the incident of violence or harassment and the facts justifying their belief that there is an imminent and serious danger to their life, health, or safety.

If it is established that the risk no longer exists or has ceased, and the affected person refuses to return to the workplace, the Company may refer the matter to the Labor Inspectorate requesting resolution of the dispute, in accordance with the provisions of Article 18 of Law 4808/2021, as amended and in force.

5.2 Contact Details of Competent Administrative Authorities

Persons affected by incidents of violence or harassment have the right to contact the following competent authorities:

  1. Labor Inspectorate (ΣΕΠΕ)
    • Regional Directorates of Labor Relations Inspection: [Contact details available through official SEPE website]
    • Citizens’ service and complaints hotline: ☎️ 1555
  2. Greek Ombudsman (Συνήγορος του Πολίτη)
    • Email: press@synigoros.gr
  3. SOS Helpline 15900 – National support line for gender-based violence victims

5.3 Consequences of Non-Compliance

Any failure to comply with this Policy within the context of the employment relationship shall be subject to the provisions set out in Part C of this document.

  1. DESIGNATION OF REFERENCE PERSON (“LIAISON OFFICER”)

For the purposes of this Policy, the Designated Reference Person (“Liaison Officer”) is:

Ms. Rodothea Ververi
📞 Tel.: +30 210 810 5290
📧 Email: ververi@thiradg.com

In this capacity, the Liaison Officer is responsible for guiding and informing all persons covered by this Policy regarding the prevention and management of violence and harassment in the workplace, whether or not the individual contacts them in connection with a specific incident or complaint.

The Liaison Officer shall exercise discretion in determining when to inform Company Management of issues brought to their attention. Furthermore, the Liaison Officer is obliged to ensure the protection of Personal Data (PD) that may come to their knowledge in the course of performing their duties, in full compliance with applicable data protection laws and the Company’s internal data privacy policies.

  1. PROTECTION OF EMPLOYMENT AND SUPPORT FOR EMPLOYEES WHO ARE VICTIMS OF DOMESTIC VIOLENCE THROUGH ANY APPROPRIATE MEANS OR REASONABLE ADJUSTMENT

As a tangible expression of its corporate social responsibility toward the phenomenon of domestic violence, the Company, upon the request of an employee who is a victim of domestic violence, may, on a case-by-case basis and taking into account the nature of the employee’s duties and the Company’s organizational capabilities, examine the adoption of appropriate measures aimed at supporting the employee in maintaining employment and facilitating a smooth reintegration into the workplace following such incidents.

  1. PROCEDURE FOR SUBMITTING, INVESTIGATING, AND HANDLING COMPLAINTS

8.1 Designated Responsible Person

The person designated to receive, review, and manage complaints or reports by affected individuals concerning incidents of violence or harassment is Ms. Rodothea Ververi, member of the Board of Directors of DG Thira Ltd (hereinafter “Liaison Officer”).

Complaints or reports may be submitted to the Liaison Officer:

  • In person (verbally), or
  • By telephone at +30 210 810 5290, or
  • By email at ververi@thiradg.com.

8.2 Investigation and Examination of Complaints — Impartiality, Confidentiality, and Data Protection

The Company and the Liaison Officer are committed to:

  • Receiving, investigating, and managing every complaint concerning violence or harassment without obstruction and without undue delay,
  • Conducting inquiries impartially, objectively, and with respect for human dignity, and
  • Taking immediate measures to protect the affected individual.

Within this framework:

  1. a) Complainants shall be notified of receipt of their complaint and periodically informed about the progress of the investigation. Upon completion of the inquiry, the Company shall inform the complainant of the outcome of the investigation.
  2. b) The Liaison Officer, assisted when deemed necessary or appropriate by the Company’s Legal Counsel and/or other authorized executives, shall investigate the allegations using any lawful and ethical means available. Where necessary, the Liaison Officer shall inform Company Management of the matter.
  3. c) Where feasible, the Liaison Officer shall seek to resolve the issue amicably before escalation.
  4. d) To ensure workplace peace and the integrity of the investigation, the Company may, among other measures, temporarily reassign either the complainant or the respondent, or modify their working hours, location, or conditions until the investigation is concluded.
  5. e) For the purposes of establishing the facts, the Liaison Officer may, where appropriate, access Company records, audiovisual material, and other relevant information or evidence lawfully collected.
  6. f) Before taking any disciplinary or corrective action, the Liaison Officer shall invite the respondent to provide an explanation, unless it is justifiably determined that doing so would:
  • Endanger the safety of the affected person, or
  • Be unnecessary due to the existence of clear and indisputable evidence concerning the alleged act, or
  • Be otherwise inappropriate under the specific circumstances.
  1. g) If the incident also constitutes a criminal or administrative offense, the Liaison Officer shall cooperate with the competent authorities (including but not limited to judicial, prosecutorial, labor inspection, and Ombudsman authorities).
  2. h) The Company and the Liaison Officer are committed to maintaining confidentiality and ensuring the protection of personal data collected during the performance of the above duties, in compliance with applicable data protection legislation.
  3. PROHIBITION OF RETALIATION AGAINST AFFECTED PERSONS

The Company strictly adheres to its obligation to prohibit retaliation against affected persons, in accordance with Article 13 of Law 4808/2021 and relevant labor legislation.

Accordingly, any form of adverse treatment, reprisal, or retaliatory conduct against an individual who has filed a complaint regarding an incident of violence or harassment is strictly prohibited, including but not limited to:

  • Dismissal or threat of dismissal,
  • Demotion, transfer, or disciplinary action, or
  • Any other measure constituting punitive or discriminatory treatment due to the complaint or participation in the investigation.
  1. CONSEQUENCES IN CASE OF VIOLATIONS OF THIS POLICY

If an investigation confirms a violation of this Policy, the Company shall take appropriate corrective and preventive measures to ensure that such incidents do not recur.
Such measures may include, but are not limited to:

  1. a) Issuance of a compliance warning or recommendation,
    b) Imposition of disciplinary sanctions,
    c) Change of position, working hours, location, or manner of work, whether temporarily or permanently, or
    d) Termination of the employment or cooperation relationship, subject to the prohibition of abuse of rights under Article 281 of the Civil Code.

If a complaint is found to have been submitted maliciously or in bad faith, the Company reserves the right to take any lawful measures against the complainant, within the framework of the employment or cooperation agreement and applicable law.

  1. COOPERATION AND PROVISION OF INFORMATION TO COMPETENT AUTHORITIES

The Company, the Liaison Officer, and any other designated individuals responsible for the reception and management of complaints shall cooperate fully with all competent public, administrative, or judicial authorities that, either ex officio or upon request by an affected person, seek relevant data or information within their jurisdiction.

They are obligated to provide assistance and access to such information, maintaining records of all collected data in accordance with data protection legislation.

  1. COMMUNICATION AND REVIEW OF THIS POLICY

This Policy shall be communicated to all Company employees by all appropriate means and posted in the workplace and on the Company’s website.

The Policy may be updated periodically at the discretion of DG Thira Ltd, in accordance with legislative developments and the Company’s operational needs.