Policy for the Prevention and Elimination of Violence and Harassment at Work

POLICY FOR THE PREVENTION AND COMBATING OF VIOLENCE AND HARASSMENT IN THE WORKPLACE

INTRODUCTION

Our company, “MENTOR HELLAS IKE”, having its registered office at 10th km Thessaloniki–Katerini, VAT No. 800645480 – Tax Office of Ionia, Thessaloniki, General Commercial Registry No. 9311082918, contact telephone number +30 2310 703193, e-mail address form@mentor-hellas.gr, complies with all measures and obligations relating to the implementation of the provisions of Part II of Law 4808/2021 on the prevention and addressing of all forms of violence and harassment, including gender-based violence and harassment and sexual harassment.

PURPOSE OF THIS POLICY

The purpose of this policy is to create and establish a working environment that respects every person in a world of work free from violence and harassment. Our company declares that it recognizes and respects the right of every employee to a working environment free from violence and harassment and does not tolerate any form of violence and harassment occurring during work or arising from it, including gender-based violence and harassment and sexual harassment.

SCOPE OF APPLICATION

This policy is adopted in accordance with Articles 9 and 10 of Law 4808/2021 and the legislation issued under authorization thereof, and applies to employees and persons performing work, regardless of their contractual status. IN PARTICULAR:

A. PREVENTION AND ADDRESSING OF VIOLENCE AND HARASSMENT

1. The company assesses the risks of violence and harassment at work, taking into account any inherent risk arising from the nature of the activity, the job position, factors such as gender and age or other characteristics constituting grounds for discrimination, as well as risks concerning specific groups of employees (e.g. newly hired employees, night workers).

2. The company takes measures for the prevention, control, limitation and addressing of these risks, as well as for the monitoring of such incidents or forms of conduct, demonstrating zero tolerance for violence and harassment, acting with confidentiality and respecting human dignity. Indicatively, the company’s core values include dignity, cooperation and mutual support. It undertakes actions to raise employees’ awareness of healthy standards of conduct and of issues concerning vulnerable categories of employees. It also takes technical measures at its facilities for the prevention of risks, such as, for example, adequate lighting of the premises. The company also provides for a reporting/complaints handling procedure and regularly evaluates the effectiveness of its actions.

3. The company undertakes actions to inform and raise awareness among personnel regarding the possible risks of violence and harassment in the workplace and the relevant prevention and protection measures in relation to such incidents. In the context of staff awareness, targeted meetings are organized for the discussion of relevant issues and the timely addressing of potential risks. Participation of management executives and employee representatives in training seminars concerning the identification and management of risks of violence and harassment at work is also encouraged.

4. The company provides information on the rights and obligations of employees and the employer, as well as of persons exercising managerial authority or representing the employer, within the scope and extent of their own responsibility, in the event of occurrence or reporting or complaint of such incidents, as well as on the relevant procedure for receiving and examining complaints. In particular, any person affected by an incident of violence or harassment during access to employment or during the employment relationship has the right to file a complaint with the Labour Inspectorate within the framework of its legal competencies, to submit a report to the Greek Ombudsman within the framework of its legal competencies, as well as to file a complaint within the company, in accordance with the complaints handling policy. The contact details of the competent authorities are as follows: Greek Ombudsman hotline: 213 13 06 600 (e-mail: press@sinigoros.gr), Labour Inspectorate hotline through the citizens’ service line 1555 (e-mail: helpdesk@sepenet.gr), SOS line 15900 for immediate psychological support and counselling for women victims of gender-based violence.

5. The company appoints as contact person (“liaison”) at company level, responsible for guiding and informing employees on the prevention and addressing of violence and harassment at work, Ms. Chatzopoulou Nikoleta, to whom employees may address themselves for relevant matters (telephone +30 2310 703193 and e-mail address form@mentor-hellas.gr). The role of the contact person is informative and consists in guiding and informing employees, regardless of whether they approach her in connection with an incident or complaint concerning an incident of violence and harassment or not. The contact person is obliged to protect any personal data that may come to her knowledge in the exercise of her role.

6. The company ensures the protection of employment and the support of employees who are victims of domestic violence, where possible, by every appropriate means or reasonable accommodation, such as, indicatively, flexible working arrangements following a request by the employee who is a victim of domestic violence.

B. PROCEDURE FOR RECEIVING AND EXAMINING COMPLAINTS

1. The company guarantees safe and easily accessible communication channels for the receipt and examination of complaints and the information of complainants, and facilitates the relevant procedures. In particular, the person responsible for receiving, examining and handling complaints or grievances of affected persons regarding violent or harassing behaviour is designated as Ms. Chatzopoulou Nikoleta. Relevant communication shall take place through the e-mail address form@mentor-hellas.gr. In any case, the affected person shall be informed, at any stage of the procedure followed within the company, of the possibility of also submitting a complaint to the competent authorities within the framework of their competence (Labour Inspectorate and Greek Ombudsman), as well as to the judicial authorities, at their discretion.

2. The receipt, investigation and handling of complaints is conducted promptly and impartially, in a manner that respects human dignity and ensures the protection of confidentiality and of the personal data of victims and accused persons collected in the exercise of the above duties.

3. The company undertakes to comply with the obligation to prohibit retaliation, in accordance with Article 13 of Law 4808/2021 and the provisions of labour legislation.

4. In the event that a violation is established, the company shall take, as appropriate, the necessary, suitable and proportionate measures against the person complained against, in order to prevent and avoid the recurrence of a similar incident or behaviour. These measures include, indicatively, a recommendation for compliance, modification and termination of the employment or cooperation relationship, subject to the prohibition of abuse of rights under Article 281 of the Greek Civil Code.

5. The company and every person responsible for receiving and handling complaints undertake to provide their cooperation and assistance, as well as any relevant information, to the competent public, administrative and judicial authorities, if requested by them, which shall be kept in a relevant file in compliance with the provisions of Law 4624/2019.