Company:
The company known as “ENDOSCOPIKI COMMERCIAL S.A. OF MEDICAL SUPPLIES” and the distinctive title “ENDOSCOPIKI S.A.”
Employer – Legal Representative Details:
- Last Name: Kaloglou
- First Name: Kimonas
- Father’s Name: Theofanis
- Contact Telephone: +30 210 7488820
Certified by: Kimonas Kaloglou, son of Theofanis
*****
Policy on Prevention and Management of Workplace Violence and Harassment
1. Policy Scope:
The company known as “ENDOSCOPIKI COMMERCIAL S.A. OF MEDICAL SUPPLIES” (hereinafter referred to as the “Company”) complies with all measures and obligations concerning 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 and sexual harassment.
Forms of behavior categorized as violence and harassment may occur:
- (a) In the workplace, including public and private spaces where the employee works, receives remuneration, takes breaks (e.g., for rest or meals), in hygiene facilities, changing rooms, or accommodations provided by the employer.
- (b) During commuting to and from work, during business trips, training, events, and social activities related to work.
- (c) During work-related communications, including those conducted through information and communication technologies.
2. Purpose of this Policy:
The aim is to create and establish a work environment that respects, promotes, and ensures human dignity and the right of every individual to a workplace free from violence and harassment. The Company declares its recognition and respect for every employee’s right to a workplace free of such behavior and states that it does not tolerate any such conduct by anyone under any circumstances.
3. Legal Framework:
This policy is adopted in accordance with Articles 9 and 10 of Law 4808/2021 and the applicable regulatory legislation, and it applies to all persons under Article 3(1) of Law 4808/2021.
Section A: Prevention and Combating of Workplace Violence and Harassment
a) Conceptual Approach:
All forms of violence and harassment are prohibited, occurring during work or arising from it, including gender-based violence and sexual harassment.
- Violence and harassment: Actions, practices, or threats that may result in physical, psychological, sexual, or economic harm, whether occurring as isolated or repeated incidents.
- Harassment: Behavior aiming to violate the dignity of a person and create an intimidating, hostile, humiliating, degrading, or offensive environment, regardless of whether it constitutes discrimination. This includes gender-based harassment.
- Gender-based harassment: Behavior related to a person’s gender, aiming to violate dignity and create an intimidating or offensive environment, including harassment based on sexual orientation, gender identity, or gender expression.
b) Risk Assessment:
The Company assesses the risks of workplace violence and harassment, considering factors such as the inherent risks of activities, job positions, gender, age, or other characteristics that may lead to discrimination. Risks involving specific employee groups (e.g., newly hired employees) are also considered.
Risk assessment tools such as the OIRA (Online Interactive Risk Assessment) platform are used for these evaluations.
c) Measures for Prevention and Management:
- Encouraging a work environment where respect, cooperation, and mutual support are core values.
- Open communication between employees and management.
- Clear procedures for reporting and managing complaints.
- Providing necessary training and information to employees, particularly for high-risk roles.
- Implementing technical measures (e.g., emergency alert systems, improved lighting).
- Raising awareness about healthy behaviors and supporting vulnerable employee groups.
- Guidance and support for victims of violence or harassment to reintegrate into the workplace.
- Regular evaluation of measures’ effectiveness and updating risk assessments.
d) Employee Information and Awareness:
- Providing accessible information about risks, prevention measures, and legal options.
- Organizing targeted staff meetings to discuss relevant issues and address risks proactively.
- Conducting seminars with mental health professionals and other specialists.
- Encouraging participation in training programs to recognize and manage workplace violence and harassment risks.
e) Information on the Rights and Obligations of Employees and Employers, as well as Individuals Exercising Managerial Authority or Representing the Employer, Within Their Scope of Responsibility in Cases of Reports, Complaints, or Incidents
If an individual is affected by an incident of violence or harassment during the process of gaining employment, during their employment relationship, or even after the termination of the employment contract or relationship under which the incident or behavior allegedly occurred, they have the following rights:
- Right to Judicial Protection
- Right to File Complaints or Seek Resolution
The individual may lodge complaints, file reports, or request a labor dispute resolution through the Labor Inspection Authority within the scope of its statutory duties. - Right to Contact the Ombudsman
They may report the incident to the Ombudsman, acting within their statutory responsibilities as the authority promoting and monitoring the principle of equal treatment. - Right to Internal Complaint Submission
They may file a complaint within the organization according to the company’s policy for managing such complaints. In any case, if such a report or complaint is made internally, the affected person retains the right to approach any competent authority. - Right to Leave the Workplace Temporarily Without Penalty
If the individual reasonably believes there is an imminent and serious danger to their life, health, or safety, they have the right to leave the workplace for a reasonable amount of time without forfeiting their wages or facing other adverse consequences.
The contact details of the relevant administrative authorities, such as the Labor Inspection Authority and the Ombudsman, are prominently displayed within the workplace. Additionally, individuals can access:
- The SEPE Complaints Hotline via the citizen service line 1555, and
- The SOS Line 15900, offering immediate psychological support and counseling services for women who are victims of gender-based violence.
The designated contact person, listed below, is responsible for informing staff about their rights and the consequences of non-compliance in the context of employment, as outlined in Articles 12-15 of Law 4808/2021.
The procedure for reporting or filing complaints regarding incidents of violence or harassment is detailed in Chapter B, below.
f) Designated Reference Person:
The designated reference person for these matters is Ms. Aikaterini Chli, an Office Clerk at the Company, who provides guidance and information to employees. She can be contacted in person or via phone at +30 210-7488820.
The reference person is obligated to protect the Personal Data (PD) that may come to their knowledge while performing their role. This includes ensuring that such data is handled in compliance with applicable data protection laws and regulations, safeguarding its confidentiality, and preventing unauthorized access, use, or disclosure.
g) Special Provisions for Victims of Domestic Violence:
Special leave or flexible work arrangements can be provided upon request to support employees facing domestic violence, especially those with minor children or dependents.
Section B: Procedure for Receiving and Handling Complaints
a) Communication Channels:
The designated reference person handles all complaints regarding violence or harassment. Complaints must be submitted in writing to ensure the security of the information. Employees are also informed of their right to report incidents to external authorities.
b)Investigation and Examination of Complaints with Impartiality and Protection of Confidentiality and Personal Data
The reference person is obligated to accept and not obstruct the submission of complaints, to promptly investigate and manage every complaint, to examine the reported incidents with impartiality and respect for human dignity, to inform the complainant accordingly, and to take immediate measures for their protection when required.
In all cases, it is the commitment of the reference person to ensure confidentiality and to protect the Personal Data (PD) of the complainant, collected in the course of performing these duties.
Specifically, the procedure to be followed is as follows:
- Submission: Complaints must always be submitted in writing and forwarded to the reference person.
- Evaluation and Data Collection: The reference person will assess the content of the complaint, collecting necessary evidence and information. This person may access company records, audiovisual material collected by the company, and other appropriate means to gather information and evidence during the examination of the complaint and to verify the reported incidents.
- Resolution: Complaints may be withdrawn at any time, or the issue may be resolved through mediation and reconciliation, involving discussion and hearings of both parties, leading to a simultaneous resolution of the incident.
This procedure ensures a thorough, fair, and confidential approach to handling complaints in accordance with the established policies and applicable legal framework.
c) Protection from Retaliation:
The Company prohibits retaliation against complainants, ensuring their safety and dignity are protected.
d) Consequences for Violations:
The Company may take measures such as issuing compliance directives, changing job conditions, or terminating employment to prevent repeat incidents.
e) Collaboration and Provision of Relevant Information to Competent Authorities Upon Request
The reference person, designated as the individual responsible for receiving and managing such complaints, is committed to cooperating with any competent public, administrative, or judicial authority. This includes cases where an authority, acting either ex officio or upon the request of an affected individual, within the scope of its jurisdiction, requests the provision of evidence or information. The reference person is obligated to provide assistance and grant access to relevant information (Article 5(1) of Law 4808/2021).
To this end, any information collected, in any form, is maintained in an appropriate file in compliance with the provisions of Law 4624/2019 (A’ 137) governing data protection.
SIGNATURE & SEAL
Kimon Kaloglou
President and CEO
31 / 01 / 2022