CODE OF CONDUCT – POLICY ON THE PREVENTION OF VIOLENCE AND HARASSMENT & ON THE MANAGEMENT OF INTERNAL COMPLAINTS
(Pursuant to Articles 9 and 10 of Law 4808/2021)

1.
Standards of Conduct – Diversity Management

  1. The human resources of our company constitute the driving force of the business and represent the most important factor for its growth and development. At “PATIKAS AP. – CHATSIOS VAS. O.E.”, employment relationships are governed by a spirit of teamwork and solidarity and are based on mutual trust, honesty, and respect. Within this framework, the conduct of the company’s personnel must be characterized by ethics, transparency, responsibility, and integrity, while any form of violent, intimidating, or offensive behavior is unacceptable and will not be tolerated, regardless of position or level in the company hierarchy.
  2. Η “PATIKAS AP. – CHATSIOS VAS. O.E.” supports respect for diversity and the avoidance of discrimination. National origin, social background, political, ideological or religious beliefs, gender, family status, age, sexual orientation, and physical abilities do not constitute criteria for discrimination within the company, but rather offer opportunities for new ideas and better results.
  3. The company’s personnel must avoid behaviors that could be characterized as discriminatory or as unequal treatment, while every employee must immediately communicate with their supervisor or the company’s management in the event that they perceive such an incident.

2.
Zero Tolerance Statement on Violence and Harassment

  1. Η “PATIKAS AP. – CHATSIOS VAS. O.E.” εκφράζει τη δέσμευσή της για την αντιμετώπιση και την εξάλειψη της βίας και της παρενόχλησης στους χώρους εργασίας, με σκοπό τη δημιουργία ενός εργασιακού περιβάλλοντος, όπου θα κυριαρχεί ο σεβασμός στην ανθρώπινη αξιοπρέπεια. Προς το σκοπό αυτό, ρητά και κατηγορηματικά δηλώνεται ότι απαγορεύεται αυστηρά κάθε μορφής βία και παρενόχληση που εκδηλώνεται, κατά τη διάρκεια της εργασίας, είτε συνδέεται με αυτήν είτε προκύπτει από αυτή, συμπεριλαμβανομένης της βίας και της παρενόχλησης λόγω φύλου, καθώς και της σεξουαλικής παρενόχλησης.

Indicatively and not restrictively, the Company declares that the following are strictly prohibited:

  • Innuendos, mockery, obscene, sexual or racist jokes or comments.
  • The use of offensive language when referring to persons with disabilities.
  • Comments on a person’s appearance or character that cause embarrassment or discomfort.
  • Stalking, pursuit, and unwanted verbal or physical attention towards an individual.
  • Sending messages of a sexually explicit nature via SMS, electronic mail (e-mail), social media, fax, or letters.
  • Offensive and persistent questions regarding a person’s age, family status, personal life, sexual interests or preferences, as well as similar questions regarding their race or nationality, including their cultural identity and religion.
  • Sexual gestures or persistent invitations for dates or threats.
  • Implications that sexual favors may advance a person’s career or that refusal to engage in a sexual relationship may negatively affect their professional course within the company.
  • Rude gestures, touching, and any kind of unwanted physical contact.
  • The dissemination of malicious comments or insults, particularly due to discrimination based on age, gender, type of marriage, civil partnership, pregnancy and motherhood, any disability, sexual preferences, religion, or beliefs.
  • Verbal threats or threats through gestures, insults in public or in private.
  • The belittling or ridiculing of an individual or their abilities, either privately or in the presence of others.
  • Outbursts of anger directed at an individual.
  • The exercise of persistent or unjustified criticism.
  • Exclusion from social events, team meetings, discussions, and collective decision-making or planning.
  • Cyberbullying.
  • Offensive electronic messages, letters, and phone calls.
  1. Η “PATIKAS AP. – CHATSIOS VAS. O.E.” is committed to receiving, investigating, and managing every complaint or relevant report, demonstrating zero tolerance towards violence and harassment, with confidentiality and respect for human dignity. Furthermore, it undertakes not to obstruct the receipt, investigation, and management of such complaints or reports.. 
  2. Η “PATIKAS AP. – CHATSIOS VAS. O.E.” is committed to providing assistance and access to any competent public, administrative, or judicial authority during the investigation of any incident of violence and harassment.
  3. Violation of the obligations arising from this Code constitutes grounds for termination of the employment contract.

3.
Scope of Application

  1. This policy applies:

    a) to the Management and members of “PATIKAS AP. – CHATSIOS VAS. O.E.”

    b) to the employees of the company, regardless of their employment status (fixed-term or indefinite-term, part-time or full-time)

    c) to individuals engaged by the company under contracts for work, independent services, or salaried mandate

    d) to persons employed through third-party service providers

    e) to interns and trainees

    f) to volunteers

    g) to employees whose employment relationship with the company has ended

    h) to job applicants

    i) to other persons who transact or cooperate with the company

4.
Useful Terms and Definitions

  1. “Violence and Harassment” means forms of behavior, acts, practices, or threats thereof, which aim at, result in, or are likely to result in physical, psychological, sexual, or economic harm, whether occurring as isolated incidents or repeatedly.

  2. “Harassment” means forms of behavior that have the purpose or effect of violating the dignity of a person and creating an intimidating, hostile, degrading, humiliating, or offensive environment, regardless of whether they constitute a form of discrimination, and includes harassment based on gender or other grounds of discrimination.

  3. “Gender-based Harassment” means forms of behavior related to a person’s gender that have the purpose or effect of violating the dignity of that person and creating an intimidating, hostile, degrading, humiliating, or offensive environment. Such behavior includes sexual harassment, as well as conduct related to a person’s sexual orientation, expression, gender identity, or characteristics.

5.
Risk Assessment of Violence and Harassment at Work

For the purpose of preventing violence and harassment, “PATIKAS AP. – CHATSIOS VAS. O.E.” may conduct anonymous and confidential surveys, through questionnaires regarding the workplace climate and the assessment of risks related to violence and harassment at work.

6.
Measures for the Prevention, Control, Limitation, and Management of Risks of Violence and Harassment at Work

  1. This Code is communicated to employees and to all persons falling within its scope of application, and the necessary measures are taken in cases of non-compliance.
  2. Η “PATIKAS AP. – CHATSIOS VAS. O.E.” ensures a working environment that is accessible, safe, and friendly, where relationships between employees, partners, Management, and company members are characterized by mutual respect, courtesy, honesty, understanding, trust, cooperation, and support.
  3. The Company, in cooperation with the occupational physician, informs employees about the risks of violence and harassment, including sexual harassment, as well as ways of preventing them. In particular:
  • It offers training and educational programs to all its personnel, in cooperation with the occupational physician.
  • It posts notices in the workplace and distributes informational material to combat violence and harassment, ensuring that all persons within the scope of this Code are aware of the Company’s policy and procedures and know where to turn if affected.
  1. Η “PATIKAS AP. – CHATSIOS VAS. O.E.” designates as the responsible person for information and advisory guidance on issues relating to the prevention and handling of violence and harassment in the workplace the respective employee representative.
  2. Η “PATIKAS AP. – CHATSIOS VAS. O.E.” trains its executives and department heads to recognize violence and harassment at work and to provide the necessary support.
  3. Η “PATIKAS AP. – CHATSIOS VAS. O.E.” encourages its employees to report incidents of violence and harassment of which they become aware.
  4. Any person who reports such incidents is protected against retaliation or unfavorable treatment, provided that the report was made in good faith and with reasonable belief in its truth.

7.
Internal Complaints Management System

  1. Η “PATIKAS AP. – CHATSIOS VAS. O.E.”with the aim of addressing and eliminating incidents of violence and harassment at work, establishes clear procedures for the submission of complaints, reports and grievances related to such phenomena and ensures the resolution of these matters in an immediate and effective manner.

  2. The internal procedure for resolving issues related to incidents of violence and harassment in the workplace may be either informal or formal.

  3. The procedure for submitting complaints or reporting incidents of violence and harassment has as its sole purpose to inform all persons falling within the scope of this policy of the ways in which such incidents, as well as any violations or non-compliance with the provisions hereof, may be reported.

  4. Any violation of this policy will result in the adoption of fair disciplinary measures, in accordance with applicable legislation and the relevant company procedures, regardless of the position of the offender.

  5. For every complaint or report of incidents of violence and harassment received by the company, all necessary measures will be taken in order to maintain the confidentiality of the identity of the person disclosing any relevant information. All information provided will be subject to strict confidential handling and will be assessed for its reliability by appropriately trained persons who have signed a confidentiality agreement.

  6. By way of exception, the identity of the complainant may be disclosed when: a) the complainant provides written consent, b) disclosure is required by law, c) the complaint clearly involves malicious intent, and d) disclosure of the identity is deemed necessary for the prevention or mitigation of a threat to the safety of the company’s personnel.

  7. .Employees who report incidents of violence or harassment and, in general, unacceptable forms of behavior in relation to this Code, shall be protected against any conduct of a retaliatory nature.

  8. Complaints or reports of incidents of violence and harassment must be made in good faith. Complaints or reports that knowingly contain false, malicious or reckless allegations and claims may, as the case may be, be subject to disciplinary and/or criminal sanctions, in accordance with applicable legislation.

  9. Complaints or reports of incidents of violence and harassment must be based on reasonable suspicions and not on unfounded elements or rumors. Nevertheless, full proof of the complaint or report is not expected from the complainant himself/herself, as this constitutes the subject of investigation by the competent bodies and services of the company.

A. Internal Informal Complaint Procedure:

  1. The complainant, if he/she so wishes, has the option to address and submit his/her complaint in writing to the employees’ representative, who is hereby designated as the “Complaints Policy Officer – Whistle Blowing”. The internal informal procedure does not concern the submission of a complaint – report, but only the submission of a grievance and, under no circumstances, does it replace the formal procedure for submitting and examining a complaint. The complainant may, at any stage of the internal informal procedure, if he/she so wishes, proceed with the formal complaint submission process.
  2. During the internal informal complaints procedure, the “Policy Officer” records the history of the incident and examines the possibility of direct communication between the complainant and the alleged perpetrator or the possibility of mediation.
  3. .The complainant declares in writing his/her preference either for direct communication with the alleged perpetrator or for mediation. In the event that the complainant chooses direct communication with the alleged perpetrator, then the “Policy Officer” is responsible for monitoring the outcome of the communication.
  4. The “Policy Officer” has the right to invite the complainant in order to obtain further information regarding the content of the complaint.
  5. The “Policy Officer” proceeds with mediation actions only in the event that the complainant declares in writing his/her wish for mediation to take place. In the case of mediation, the “Policy Officer” assumes responsibility for communication with the alleged perpetrator.
  6. The “Policy Officer” is obliged to demonstrate full confidentiality and objectivity during the above procedure, which must be completed within a reasonable period of time. Upon completion of the procedure, the “Policy Officer” must inform the complainant of the outcome of the resolution of his/her complaint, as well as of his/her right to submit a formal complaint.
  7. The complainant is protected from any form of retaliation and unequal or adverse treatment in the workplace, provided that the complaint was made “in good faith” and “on reasonable grounds or belief” that the information was true at the time it was obtained. This protection does not have specific time limits and excludes any kind of adverse consequences against the complainant, such as: a) termination of the employment contract, b) suspension, c) disciplinary penalties, d) change of duties or working hours, e) deprivation of the right to promotion, f) loss of benefits.

B. Formal Complaint Procedure

  1. In order to initiate the formal procedure for examining a complaint – report regarding an incident of violence or harassment in the workplace, the complainant must submit a written complaint to the Board of Directors of “PATIKAS AP. – CHATSIOS VAS. O.E.” via electronic mail (e-mail) at the address social@alfa-vita.gr. The submitted complaint will be examined in accordance with the manner and procedures provided by the applicable Legislation.
  2. The Management of “PATIKAS AP. – CHATSIOS VAS. O.E.” is obliged to investigate and examine every complaint with impartiality, confidentiality and objectivity and on the basis of the principles and measures provided for in this Code.
  3. In the event that, during the examination of the complaint – report, conduct of violence and harassment is established that offends the health of the individual or affects the proper working environment, the Management of “PATIKAS AP. – CHATSIOS VAS. O.E.” shall decide on the termination of the employment contract of the perpetrator.