Violence and harassment at work is a major issue. The adoption by companies of measures and policies to prevent and combat violence and harassment at work, in addition to being mandatory, is also necessary, not only for the promotion of broader social goals, such as the abolition of discrimination, respect for diversity and the preservation of the dignity of every person, but also because it contributes to the smooth and more productive operation of every business.
Law 4808/2021, in combination with other existing provisions, modernizes the institutional framework for dealing with incidents of violence and harassment, when these occur in the context (directly or indirectly) of work. The full implementation of the Law's provisions is estimated to contribute to the promotion of the above-mentioned objectives, with mutual benefits for both businesses and employees, the employed and the other categories of persons that fall within the scope of application.
The following paragraphs analyze the following:
• Purpose
• Field of application
• Basic concepts
• Institutional framework
• Scope and general obligations of employers
• Development of company policies, procedures and employee training
• Rights of victims and obligations of employers in incidents of violence and harassment
• Epilogue
01 Purpose
The purpose of this policy is to inform Employees regarding how IAMEX S.A. deals with the phenomena of violence and harassment at work and the timely prevention and treatment of such phenomena that take place during work, whether it is provided live or remotely in the form of telework. IAMEX S.A. recognizes and respects the rights of its employees and declares that it shows zero tolerance for incidents of violence and harassment, of any form and by any person, aiming to create a working environment centered on respect for human dignity. For this reason, it proceeds to adopt every possible way to prevent and combat such incidents within its workplace.
02 Field of application
This Policy binds the members of the Board of Directors, the Executives and the staff of the Company, regardless of the type of contract that connects them with the Company. This Policy also applies to the Company's counterparties in the context of project contracts, independent services, salaried mandate, those employed through third party service providers, employees whose employment relationship has ended, persons applying for work in accordance with the provisions of the applicable applicable legislation. Incidents of violence and harassment caused by third parties not subject to this policy do not fall within the scope of this policy, as they are not related to the "world of work". With regard to the protection of employees in these cases, the general provisions of labor law regarding the employer's welfare obligation apply and apply.
03 Basic concepts
a) The term "Violence and Harassment" at work means any unacceptable form of behavior, act, practice or threat of its manifestation by the person to whom it is directed, which is exercised either individually or in groups, either once or repeatedly, and aims or leads or is likely to lead to physical, psychological, sexual or financial harm. The term includes gender-based violence or harassment. The term "gender-based violence" means violence or harassment that is directed at people because of their gender, or that disproportionately affects people of a particular gender, and includes sexual harassment.
b) "Harassment" means forms of behavior that have the purpose or effect of violating the dignity of the person and creating an intimidating, hostile, humiliating, humiliating or aggressive environment, regardless of whether they constitute a form of discrimination, and include gender-based harassment or for other reasons of discrimination,
c) "Gender-based harassment" means forms of behavior related 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 duringarticle 2of n.3896/2010(A' 107) and par. 2 thereofof article 2of n.4443/2016(A' 232).
d) Sexual harassment: It includes any form of unwanted verbal, psychological or physical behavior of a sexual nature, with the result of insulting the personality of a person, in particular by creating an intimidating, hostile, humiliating, humiliating or aggressive environment around him.
According to the above, each concept is a subset of the previous one: sexual harassment is a subset of gender-based harassment, which belongs to the broader concept of harassment; the latter in turn falls under the general category of violence and harassment.
Indicative examples of violent and harassing behavior
Bullying and harassing behavior can take many forms, physical, verbal, non-verbal, direct, indirect, covert or implied, or occur in cyberspace, regardless of whether corporate or non-corporate equipment and accounts are used.
-Physical(Unwanted touching, Unwanted physical contact, Unwanted kissing, Unwanted hugging)
- Vocabulary(Offensive, intrusive questions about the person's personal life, Sexually awkward and offensive comments/jokes, Inappropriate dating suggestions)
-Non-verbal(Display of inappropriate visual material, sexual content or character, Inappropriate, persistent and indiscriminate looking with a sexually suggestive mood, Obscene gestures)
-In cyberspace(Offensive and inappropriate suggestions on websites and social networking applications, Sending emails with offensive, sexual content)
04 Institutional framework
The institutional framework in Greece for preventing, dealing with and combating all forms of violent behavior and harassment at work, including gender harassment and sexual harassment, is regulated and specialized by Law 4808/2021 and by Part II of said law, entitled "Adoption of measures and regulations on harassment and violence at work".
The Law provides general obligations, which bind all businesses, regardless of the number of people employed in them. In addition, it is foreseen, exclusively for businesses that employ more than twenty (20) people, the obligation to adopt two independent policies: the first concerns the fight against violence and harassment and the second the management of internal complaints.
These two policies are specified by Ministerial Decision 82063/2021, which includes policy models and instructions for businesses with more than twenty (20) employees.
Part II of Law 4808/2021 is harmonized with the content of Convention 190 of the International Labor Organization "On the Elimination of Violence and Harassment in the World of Work". The sanctioning of the specific contract constitutes, after all, Part I of the Law in question.
Part II of the Act prohibits in principle all forms of violence and harassment - including gender-based violence and harassment as well as sexual harassment - occurring either during, in connection with, or arising from work.
A behavior of violence and harassment is considered to take place at work when it manifests itself:
-In the workplace: the workplace includes public and private spaces in which the working person provides work, receives remuneration, takes a break for rest or feeding, as well as the areas of personal hygiene and care, changing rooms or accommodation provided by the employer.
-During commuting to and from work: this category includes business trips, as well as any other work-related social events and activities.
-During work-related communications, including those made through information and communication technologies.
05 Scope and general obligations of employers
Under Ministerial Decision 82063/2021, a distinction is made between the categories of persons of the scope, as those subject to the protection of the relevant provisions against violent and harassing behavior at work, and the companies/employers as bearers of the obligations created by the law. It is noted that the law is not limited only to the people who are the staff of the company, but also includes other categories of persons who develop any form of relationship, cooperation or even contact with the company.
Categories of persons covered by the provisions on violence and harassment at work:
• Employees in the private sector, regardless of their contractual status, including employed on a project contract, independent services, salaried mandate and employed through third party service providers.
• People undergoing training, including trainees and apprentices.
• Volunteers.
• Employees whose employment relationship with the enterprise in which the incident took place has ended.
• Prospective employees who come to the company to look for work.
General obligations of employers and completion of existing ones:
Law 4808/2021:
• It creates certain general obligations, in the sense that they bind all employers without exception, regardless of the number of people employed in the business. At the same time, in addition to the general obligations, the Law provides, exclusively for businesses employing more than twenty (20) people, the obligation to adopt two independent policies: a) a policy to prevent and combat violence and harassment at work and b) policy for the management of internal complaints.• In addition, it complements the existing relevant provisions of Law 3850/2010 ("Code of laws for the health and safety of employees"), in order to incorporate into them issues related to violence and harassment at work.
All the obligations arising under the relevant provisions of Law 4808/2021 do not only bind the employers as such, but also any other person who exercises a managerial right or represents the employer.
The Ministry of Labor and Social Affairs issued in November 2021 the Ministerial Decision 5393, according to which, as employees who hold a position of supervision or management or confidential, they are presumed where:
• They exercise the employer's managerial right against other employees of the company, or
• represent and bind the company to third parties, or
• are members of the board of directors or a corresponding administrative body of the employer, or
• if the employer is a legal entity, they are shareholders or partners, holding or representing a percentage equal to or higher than 0.5% of the voting rights, or, finally,
• comply with the minimum wage conditions, as defined in the afore mentioned Ministerial Decision.
New general obligations of employers based on Law 4808/2021, regardless of the number of employees:
Every employer, as well as every other person exercising managerial authority or representing the employer, is obliged to:
1. To receive, investigate and manage every complaint or related report with zero tolerance for violence and harassment, with confidentiality and with respect for human dignity.
2. Not to interfere with the receipt, investigation and management of complaints or reports related to incidents of violence and harassment.
3. To provide assistance and access to any competent public, administrative or judicial authority, during the investigation of such incidents and if requested by these authorities.
4. To provide working people with all necessary information regarding the possible risks of violence and harassment in the workplace, as well as prevention and protection measures, including the obligations and rights of employees and the employer in such incidents.
5. To post in the workplace and in an accessible place, information on the procedures that exist at company level regarding reporting and dealing with incidents of violence and harassment, as well as the contact information for the competent administrative and judicial authorities.
Completion of existing general obligations of employers:
Part II of Law 4808/2021 complements some of the existing obligations of employers, as provided for in Law 3850/2010 ("Sanction of the Code of Laws for the Health and Safety of Workers"), in order to integrate them into these issues relating to violence and harassment at work. Particularly:
• In addition to the employers' obligation to provide information to workers about safety and health risks in the company, the risks of violence and harassment, as well as the measures to combat them.
• In the general obligation of employers to draw up a preventive action program and improve working conditions, psychosocial risks are added to the parameters of these programs.
• In the same provision, the assessment of psychosocial risks is also added. They now include the risks of violence and harassment, including sexual harassment, while it is also foreseen to take measures to prevent, control and limit them.
• The responsibilities of the occupational physician are being expanded to include the dimension of violence and harassment in the workplace.
06 Development of company policies, procedures and employee training
In addition to the general obligations that bind all employers, Part II of Law 4808/2021 provides, exclusively for businesses that employ more than twenty (20) people, the obligation to adopt two independent policies within each business. The first concerns the prevention and combating of violence and harassment at work, and the second concerns the management of internal complaints.
6.1. Preventive measures to eliminate incidents of Violence & Harassment
In particular, IAMEX S.A.:
6.1.1. It carries out a risk assessment of Violence and Harassment in the workplace. IAMEX S.A., taking into account, among other things, any inherent risk arising from the nature of its activity, the job position, factors such as gender and age or other characteristics that can be grounds for discriminating the Employees, undertakes assessment of the risks of Violence and Harassment. Indicative risk assessment measures taken by IAMEX S.A.: conducting an autopsy in the workplace at regular intervals, regular communication with its Employees and/or conducting annual anonymous surveys to identify criminal behavior. At the same time, IAMEX SA particularly assesses the risks concerning special groups of its Employees (such as the recently hired, victims of domestic violence, etc.) through regular communications and specialized questions to them, regarding their working conditions, the behavior of other Employees and members of the management etc. For the risk assessment, IAMEX S.A. utilizes digital tools for occupational risk assessment.
6.1.2. It takes measures to prevent, control, limit and deal with the above risks, as well as to monitor related incidents or forms of behavior. The preventive measures taken by IAMEX S.A. include, but are not limited to, the following actions:
6.1.2.1. It provides encouragement to create and maintain a healthy working environment, based on mutual help, cooperation and mutual respect, where human dignity is a fundamental value. You can show respect with simple but meaningful behaviors such as:
• Encourage colleagues to express opinions and ideas.
• Promote a work environment that embraces diversity and inclusion.
• Listen carefully to what your partners have to say before expressing your opinion.
• Share information regularly and involve others in decision-making.
• Ideas-suggestions from your colleagues to change or improve your work are beneficial.
• Don't be offensive to people or their ideas, and don't undermine or ridicule them.
• Use constructive feedback and try to praise your colleagues more often.
6.1.2.2. Organization of actions and events to inform and raise awareness of Employees on issues of Violence and Harassment and implementation of policies with the relevant defined procedures for dealing with and combating incidents of Violence and Harassment as effectively as possible.
6.1.2.3. Adopting procedures that ensure the direct communication of the Employees with the reference person provided below and encouraging the Employees for direct access and communication both with the reference person and with the other colleagues as well as the head of each department.
6.1.2.4. Adopting a report/complaint management process
6.1.2.5. Information and actions to raise the awareness of Employees in healthy behavior patterns (e.g. avoiding addictions), but also for issues concerning vulnerable categories of Employees.
6.1.2.6. Guidance and support to victims of Violence and Harassment and victims of domestic violence for their smooth integration into the workplace.
6.1.2.7. Taking measures of a technical nature at the facilities of IAMEX S.A. and their surroundings, such as indicatively the sufficient lighting of all areas, video surveillance system (as foreseen and as permitted by the applicable legislation for the protection of personal data), etc.
6.1.2.8. Occupational Physician: the Occupational Physician, who visits facilities on a regular schedule, is also responsible for informing employees of their rights and the process for submitting named and anonymous reports.
IAMEX SA undertakes to evaluate on a regular basis the effectiveness of the above applied preventive measures and countermeasures to revise or update whenever deemed necessary the assessment of risks and measures.
6.1.3. It carries out actions to inform and raise awareness among Employees about the risks of Violence and Harassment through this Policy but also by any other suitable means (e.g. with information brochures in printed or electronic form, with corporate staff information meetings, with training seminars, the possibility of meetings with mental health specialists, etc.). In the context of raising awareness among Employees, IAMEX S.A. may, among other things:
6.1.3.1. Organizes staff meetings to discuss relevant issues and address potential risks in a timely manner.
6.1.3.2. Conduct seminars with mental health specialists or counseling service providers, etc.
6.1.3.3. To encourage the participation of Employee representatives and management executives in training programs and educational seminars regarding the recognition and management of the risks of Violence and Harassment at work.
6.1.3.4. To inform the Employees about the risks of Violence and Harassment, as well as about the related prevention and protection measures, about the procedures applied by IAMEX S.A. and for the possibilities given by law to Employees in the event of such incidents, ensuring that they are informed as fully as possible.
6.1.4. It provides the Employees, through this Policy but also by any other appropriate means, with information on the rights and obligations of both the Employees and the persons who exercise the managerial right or represent IAMEX S.A., to the extent of their own responsibility, in the event of occurrence or reporting of such incidents, as well as for the relevant reporting procedure to be followed.
6.2. Internal Complaint Management Policy for Incidents of Violence and Harassment at Work
6.2.1. Procedure for reporting or denouncing incidents of Violence and Harassment:
The procedure followed by IAMEX S.A. for the investigation and evaluation of Employee complaints for incidents of Violence and Harassment is described below, while at the same time it is available and posted in electronic form on the internal communication/management platform used by IAMEX S.A. and on its website (www.iamex.gr):
• Any Employee who believes that he has suffered an incident of Violence and Harassment, as well as any Employee who perceives an incident of Violence and Harassment against another employee in violation of this policy, must immediately and without any delay submit a report/complaint. The above report/complaint can be submitted by name or anonymously, orally or in writing to the contact details of the reporting person provided in this policy (the "Reporting Person"), following the procedure provided below for each case:
Written complaint: In the event that the complainant chooses to submit the complaint in writing, he/she should fill out the "Violence and Harassment Incident Complaint Form" (according to the model attached in Appendix A) and send it to the Reporting Person's email address.
Verbal complaint: In the event of a verbal complaint, the complaint will be recorded by the recipient of the complaint (i.e. the Reporting Person) on the "Violence and Harassment Incident Report Form" and then signed by the complainant (unless the complainant wishes to submit the complaint anonymously, in which case IAMEX SA is obliged to maintain the anonymity of the latter).
Anonymous complaint: In the case of an anonymous complaint, it is submitted either verbally according to the above, or by completing the "Violence and Harassment Incident Complaint Form". However, it should be noted that anonymity may, in some cases, limit the possibility of IAMEX S.A. to investigate the complaint. Anonymous complaints make a thorough investigation extremely difficult or impossible, due to the difficulty of providing information from an anonymous complainant (eg a debriefing meeting), as well as assessing the credibility of the complaint. However, even anonymous complaints will be taken seriously by IAMEX SA. and will be investigated to the extent possible. In particular, the submitted anonymous complaints are examined according to their degree of documentation and the possibility of identifying the action incompatible with this Policy that they describe.
6.2.1.1. Contact – Reference Reporting Person
As Competent person of IAMEX S.A. to receive, examine and manage the complaints or complaints of the affected persons for Violent and Harassing behaviors, Maria Chronaki is designated, with whom the Employees can contact in person at the offices of IAMEX S.A., by phone at tel. 6972624796. Alternatively, you can Submit Named and Anonymous Reports via e -mail to the “Call Out” Channel at the email address callout@iamex.gr. Employees' access to the reference person is always open, easy and immediate. Her role is informative and consists in guiding and informing the Employees on the prevention and treatment of Violence and Harassment at work, regardless of whether they contact her on the occasion of an incident of Violence and Harassment or after submitting a relevant complaint. The reporting person informs the affected Employee of his/her rights, including his/her right, at any stage of the procedure followed within IAMEX S.A., to also submit a complaint to the competent administrative authorities within their competence, i.e. to the Hellenic Labor Inspectorate and the Greek Ombudsman Independent Authority, as well as to the judicial authorities, at his/her choice.
• Upon submission of the complaint, the Employee will receive from the reporting person confirmation of receipt of the complaint and information on its progress.
• The Heads of each Department who may become aware of incidents of Violence and Harassment must immediately report the matter in writing to the reporting person, who immediately takes the appropriate measures to protect the affected Employee. The Management of IAMEX S.A. and upon agreement with the complainant, until the full investigation and final examination of the complainants, may take temporarily, depending on the case and as long as this is possible, one or more of the measures indicated indicatively in the article above, with the aim of protecting the victim.
• IAMEX SA investigates and immediately examines the complaints with impartiality and protection of the confidentiality and personal data of the affected Employees and the complainants. During the investigation of the complainants, anonymity will be sought to the extent possible, as long as there are no reasons that require its waiver, either to facilitate the investigation of the complaint (e.g. an interview with the complainant) or after the intervention of a public authority.
• Within ten (10) business days of receipt of the complaint, an investigation will be conducted by the Chief Executive Officer and the reporting person to determine if there are grounds for further investigation of the complaint. The results of the investigation will be recorded by the Reporting Person or the CEO on the "Violence and Harassment Incident Evaluation Form" (available in Appendix A of this Policy). In the event that the complaint is found to be unfounded, or material information is missing to consider its validity, the Reporting Person will inform the complainant and the complained in writing of the reason why the complaint was deemed unfounded. Otherwise, written explanations will be requested from the complainant regarding the reported incident.
• The complainant should, within ten (10) working days from the date of receipt of the above written information, complete and submit via email to the Reporting Person the "Complainant Response Form" (available in Appendix Α of this Policy) together with any supporting evidence to validate his/her claims.
• Any witnesses nominated by each party involved will be examined and their testimony will be taken into account.
• When the investigation is completed, all information will be recorded based on the material collected from the parties involved and IAMEX SA. will inform the complainant and the person complained about the results of the investigation. All procedures and actions taken will be recorded on the "Violence and Harassment Incident Evaluation Form" (available in Appendix A of this Policy).
• In the event, in whole or even in part, of confirmation of the complaints, IAMEX S.A. takes one or more of the measures mentioned above, to protect the affected complainant.
• IAMEX SA will make every reasonable effort to complete the entire process as soon as possible from the date of submission of the complaint.
6.2.2. Investigate and review complaints impartially and protect the confidentiality and personal data of affected Employees and complainants. More specifically:
6.2.2.1. IAMEX SA and the reporting person, undertake to receive and not prevent the receipt, to investigate and manage immediately and with absolute confidentiality any Employee complaint about an incident of Violence and Harassment, to investigate and examine the reported events with impartiality and respect for human dignity, as well as to take immediate measures to protect the affected Employee.
6.2.2.2. In the event that the person of complain is the Reference Reporting Person or other person involved in the process of investigation and review of complaints in accordance with this Policy, that person is excluded and will not be involved in any of the prescribed procedures and the complaint will be investigated by the Chief Executive Officer of IAMEX S.A. in cooperation with the Legal Advisor of IAMEX SA.
6.2.2.3. In the event that the complainant is the CEO and is involved in any way in the complaint of violence or harassment, the CEO will not be involved in any of the proceedings and the complaint will be investigated by the company's Board of Directors in cooperation with IAMEX's Legal Counsel S.A.
6.2.2.4. IAMEX SA and the reference reporting person undertake to observe, in any case, the obligation of confidentiality and the protection of the personal data collected or communicated to them by the Employees during the exercise of their above duties.
6.2.2.5. IAMEX SA takes additional measures to secure the information collected from the affected Employees as well as measures to deal with cases of conflict of interest.
6.2.2.6. It cooperates and provides all relevant information to the competent authorities, if requested. In particular, IAMEX S.A. as well as the reference reporting person for the reception and management of internal incidents complaints of Violence and Harassment cooperate with any competent public, administrative or judicial authority, which, either ex officio or at the request of the affected Employee, within the scope of its competence, requests the provision of information and undertake to provide assistance and access to such information. To this end, all the data collected regarding the incident of Violence and Harassment, in any form, are kept in a relevant file within IAMEX S.A., in compliance with the provisions of the applicable legislation regarding the protection of personal data [including but not limited to of Law 4624/2019 (A' 137)].
6.2.3. Interim Measures in favor of the Complainant
The HR department takes, if necessary and in agreement with the complaining person, measures to protect him, until the complaint/report is fully investigated.
Indicative measures include granting the complainant special paid leave or telecommuting depending on the nature of his duties or transfer to another work department.
6.2.4. Protection from acts of retaliation
The Group undertakes to protect the employees who in good faith made a report, from any acts of retaliation in accordance with the "Framework for the Protection of Employees from possible acts of retaliation in the event of a complaint".
IAMEX SA will never retaliate or allow retaliation against the complainant in an incident of violence or harassment. In particular, any adverse treatment of the complainant is prohibited, as long as it constitutes vindictive behavior or countermeasures within the meaning of article 14 of Law 3896/2010. Termination or in any way termination of the legal relationship on which the employment is based is invalid, as long as it constitutes vindictive behavior or countermeasure within the meaning of article 14 of Law 3896/2010 for an incident of violence and harassment under article 4.
6.2.5. Penalties for the Complainant
In the case of confirmation of complaints for violation of the principles of the Policy for the Prevention and Combating of Incidents of Violence and Harassment in the Workplace, the necessary measures are taken by the HR Department in accordance with the internal procedures of IAMEX SA. as defined in this policy.
In particular, the necessary appropriate and proportionate measures are taken against the complainant, in order to prevent and prevent a similar incident or behavior from repeating itself.
The measures include recommending compliance, changing the position, hours, place or manner of providing work, as well as disciplinary sanctions as defined in order of priority or depending on the gravity of the misconduct include:
• Oral observation
• Written observation
• Written reprimand
• Fine up to 25% of daily earnings
• Temporary break from work for up to 3 months, without pay
• Resolution of employment relationship
07 Rights of victims
7.1. In case an Employee is affected by an incident of Violence and Harassment during his working relationship with IAMEX S.A. or even if the contract or employment relationship under which the incident or conduct is alleged to have occurred has ended, has the following rights: a) right to judicial protection, b) right to appeal, submit a complaint and apply for a labor dispute to the Inspectorate Labor, within the framework of its statutory powers, c) right to report to the Ombudsman, within the framework of his statutory powers, as well as d) right of complaint within IAMEX S.A. in accordance with the company's complaint management procedure, as described here, it has been posted on the notice board of IAMEX S.A. and is also available on this website (www.iamex.gr). In any case, when such behavior is reported within IAMEX S.A., the affected Employee retains every right to appeal to any competent authority.
7.2. Contact details of the competent administrative authorities to which any affected Employee has the right to appeal:
GOVERNMENT AGENCIES FOR FILING A COMPLAINT
• GENERAL SECRETARIAT FOR EQUALITY AND HUMAN RIGHTS: SOS TELEPHONE LINE 15900 (24 hours 365 days), 8 Dragatsaniou Street, Athens
• THE GREEK OMBUDSMAN: 17 Chalkokondyli Street, Athens, tel.: 2131306600, www.synigoros.gr
• HELLENIC LABOUR INSPECTORATE (SEPE) COMPLAINT LINE 1555, helpdesk@sepenet.gr, 37 Patission Street, Athens
7.2.1.1. Employee Rights and consequences of non-compliance in the context of the employment relationship: as provided for in articles 12-15 of Law 4808/2021. More specifically:
• Any Employee who is affected by an incident of Violence and Harassment against them has the rights and possibilities described above and, in addition, has the right to leave the workplace for a reasonable time, without loss of wages or other adverse consequence, if in the reasonable belief there is an imminent serious risk to his life, health or safety, in particular, when a person who exercises the managerial right or legally represents IAMEX S.A. as an employer is the perpetrator of such behavior or when IAMEX S.A. does not take the necessary appropriate measures to restore work peace or when these measures are not sufficient to stop the behavior of Violence and Harassment. In this case, the departing Employee is obliged to inform the reference person designated by IAMEX S.A. in advance in writing, mentioning the incident of Violence and Harassment and the other incidents that justify his belief that there is an imminent danger to life, health or safety. As long as the risk does not exist or has ceased to exist and the departing Employee refuses to return to the workplace, IAMEX S.A. as an employer can appeal to the Labor Inspectorate with a request to resolve the dispute. In this case, Article 18 of Law 4808/2021 applies.
• When an Employee violates the prohibition of acts of Violence and Harassment or submits to IAMEX S.A. corresponding complaint, IAMEX S.A. is obliged to take the necessary appropriate and appropriate measures at the expense of the person complained of, in order to prevent and not repeat a similar incident or behavior. The measures include indicatively: The recommendation of compliance, the change of position, time, place or method of providing work or the termination of the employment or partnership relationship, subject to the prohibition of the abuse of rights in Article 281 of the Civil Code.
• When a person who exercises the managerial right or legally represents IAMEX S.A. as an employer, violates the prohibition of tolerating or carrying out acts of Violence and Harassment when entering into or refusing to enter into a legal relationship with an Employee or during the development, duration or termination thereof, violates the labor law, the administrative sanctions of para. a' of par. 2 of article 19 of Law 4808/2021.
• In any case, the violation of the prohibition to tolerate or carry out acts of Violence and Harassment gives rise, among other things, to a claim for full compensation of the affected Employee, which covers his positive and collateral damage, as well as moral damage.
• The termination or in any way the termination of the legal relationship on which the employment is based, as well as any other unfavorable treatment of the Employee, is prohibited and invalid, as long as it constitutes retaliatory behavior or countermeasure within the meaning of article 14 of Law 3896/2010 (A' 207) for an incident of Violence and Harassment. IAMEX SA observes the prohibition of retaliation in Article 13 of Law 4808/2021 and the further victimization of the affected Employee. IAMEX SA will not retaliate against, or permit retaliation against, any person who raises an issue or cooperates with an investigation. However, anyone who knowingly makes a false allegation or knowingly provides false information may be subject to disciplinary action. If you believe you are being retaliated against, please contact the reporting person. IAMEX SA encourages Employees to report any incident of Violence and Harassment they may have suffered and will make every reasonable effort to effectively help them at work and psychological level.
• When the affected person claims that there is Violence and Harassment, paragraph 1 of article 24 of Law 3896/2010 (Government Gazette A' 207) applies.
08 Epilogue
Violence and harassment at work is a matter of capital importance, the effective treatment of which is a necessary condition, not only for the smooth and productive operation of the company, but also for the promotion of wider social goals, such as the fight against all forms of discrimination, the respect for diversity and ensuring the dignity of individuals in the business.
With Law 4808/2021 (Part II), an attempt is made to form in Greece a modern, comprehensive and coherent institutional framework, especially for the prevention and combating of violence and harassment in the context of work. The correct application of its provisions is estimated to contribute to the promotion of the above-mentioned objectives, with mutual benefits for both businesses and employees, the employed and the other categories of persons that fall within the scope of application.
IAMEX SA undertakes to evaluate this in a manner consistent with the requirements of the applicable laws and regulations, ensuring that it is constantly updated on relevant developments.
IAMEX SA must post this policy and procedure on all internal communication media so that all employees are aware of it.