POLICY AGAINST VIOLENCE

POLICY FOR THE PREVENTION AND COMBAT OF VIOLENCE AND HARASSMENT AT THE WORKPLACE AND THE MANAGEMENT OF INTERNAL COMPLAINTS FOR INCIDENTS OF VIOLENCE AND HARASSMENT OF THE COMPANY “ARTIZAN HELLAS S.A.”

ARTISAN HELLAS S.A., 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 the International Labor Convention 190/21.06.2021 of the International Labor Organization (ILO), on the elimination of violence and harassment in the workplace, the text of which was 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 work in a world of work free of discrimination, violence, and harassment. ARTIZAN HELLAS S.A. declares that it recognizes, respects, and protects the right of every employee to work in 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 – Subject Persons
This policy covers the persons of par. 1, article 3 of Law 4808/2021 and in its scope of application and protection included all types of employees and those employed by ARTIZAN HELLAS S.A., regardless of their contractual status, including those employed under a project contract, independent services, salaried mandate, employed through third-party service providers, people undergoing training including trainees and apprentices, volunteers, people whose employment relationship has ended, people applying for work and other people dealing with or working with the company.

3. Prohibited forms of conduct – Definitions of Violence and Harassment
“Violence and harassment” refer to 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” refers to forms of behavior that have the purpose or effect of violating a person’s dignity and creating an intimidating, hostile, humiliating, or aggressive work environment, regardless of whether they constitute a form of discrimination, and include harassment based on gender or other grounds of discrimination.
“Gender-based Harassment” refers to 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, 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 mentioned in Law 3896/2010, as well as forms of behavior linked to the person’s sexual orientation, expression, identity, or gender characteristics.
“Discrimination” refers to the different treatment of people arising from prejudices or interests, as well as any act that unreasonably separates people on the basis of the groups, classes, or other categories to which they belong or are perceived to belong to. 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 assumed from 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, threats of physical violence 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 promote their career or that the refusal to enter into a sexual relationship may negatively affect their professional career in the Company, offering benefits (eg, promotion or pay raise) in exchange for sexual favors or creating an environment that promotes “sex” 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, without lawful reason and reason persistent and/or offensive questions about age, marital status, personal life, sexual orientation, as well as similar questions about race or nationality, including cultural identity and religion. Also included are visual forms of harassment such as e.g. posters, cartoons, caricatures, 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 or obstruction of one’s normal work, the movement and physical integrity of the individual, physical exclusion or confinement, sexual gestures, physical surveillance, and pursuit. The previously mentioned acts are indicative and do not constitute an exclusive list of prohibited acts.
“Appropriate Acts” 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 to allow someone to go on leave. 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 one’s 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, changing rooms or accommodation provided by the company to staff. This policy also covers all types of travel to and from work, other travel-related obligations such as conferences, and 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 and pursuit 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, is inflicted on the employee during telework.

5. Assessing the risks of violence and harassment in the workplace
5.a. Assessment of risk factors and their improvement. ARTISAN HELLAS S.A. prepares studies in collaboration with all its departments and the responsible occupational physician on 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, with the aim of evaluating the existing working conditions and their adaptation in such a way as to limit the chances of an incident of violence and harassment taking place in the workplace as much as possible.
Indicative risk cases are mentioned as follows: high levels of stress in the workplace, isolated or closed-off workplaces, distribution of employment, facility security and control, lack of proper training, people with a history of violent behavior, delivery of goods or services, working alone or in an isolated area, working late at night or in the early morning hours, domestic or personal life issues spilling over into the workplace.

5.b. Organization of seminars, publication of informational forms, and regular staff training in violence and harassment.
All employees must understand that those behaviors that constitute violence and harassment are not tolerated and are frowned upon. The person responsible for the reports regarding violence and harassment will ensure that staff receive the appropriate sensitization of violence and harassment issues 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. ARTISAN HELLAS S.A. 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 ARTISAN HELLAS S.A. and the actions they need to take to ensure effective incident 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 in writing to their 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. ARTISAN HELLAS S.A. 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 (Labor Inspectorate, Citizen’s 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.].
ARTISAN HELLAS S.A., within the limits of its capabilities, takes every appropriate measure and makes every reasonable adjustment to working conditions to protect employment and support employees – victims of domestic violence. It also takes all the necessary measures to inform and raise awareness of the staff, using the above appropriate means to combat violence and harassment, ensuring that everyone is aware of the company’s policy and procedures regarding incidents of violence and harassment, knows where to turn in the event of violence or harassment, and the options given to them by law.
ARTISAN HELLAS S.A. 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 employee representatives and 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 written complaint to the competent Accounting Department and to Mr. IOANNIS FRERIS, who is also defined as the “Person of Reference” for this policy. The complaint can be submitted in person or via e-mail to the e-mail address rightsprotection.artizan@switzgroup.gr. The complaint cannot be made anonymously.
The complaint should include the information 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 maximum extent possible, taking into account the sensitivity of the case and the privacy of all involved.
Furthermore, he 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 reached out to them.
Once the reporting person has completed his investigation, they must then submit a written report to the company’s Management, in which they state the result of the investigations. The investigation results 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, harassment, or retaliation actually occurs, the Company’s Management will, on a case-by-case basis, take all necessary 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 in Article 281 of the Civil Code.

-Complaints that prove to be clearly malicious will be considered unacceptable and will be further investigated at the discretion of the company, both in terms of motives and those involved, in order to restore order by any legal means and means.

8. Rights of Victims
According to the current legislation, every person who experiences an incident of violence and harassment at their expense has the right to leave the workplace for a reasonable time, without loss of salary or other adverse consequence, if in their reasonable belief there is an imminent serious risk to their life, health or safety, in particular, when the employer is the perpetrator of such behavior or when they do 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, stating the incident of violence and harassment and the incidents that justify their belief that a serious risk to their life, health, or safety is imminent.
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 an objective and impartial manner during the complaint investigation process. In addition, they must behave with respect to all parties involved and in a confidential and confidential manner. The disclosure of information concerning the complaint under review to non-involved parties is completely prohibited. 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 their 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

ARTIZAN HELLAS S.A., as well as any competent person or agency for the reception and management of such complaints at the 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.”

For more information about this policy, any person interested can contact the company’s contact person/link.

This Policy is posted on the company’s official website at the following link: http://www.artizanhellas.gr