Objective:

Establishing a workplace that respects, promotes and ensures every person’s right to a workplace free from discrimination, violence and harassment.

Key Points:

• Objective
• Definitions
• A) Prevention and Fight against Violence and Harassment at Work
  B) Procedures for SpeakUp and Complaints Handling

Beneficiaries:

Members of the Management, members of staff and employees regardless of their contractual status – including those under contracts for work, rendering services, salaried employees, those employed through third party service providers. Beneficiaries also include the trainees and the interns, as well as the employees whose term of employment has expired, and those in search of working positions, and those trading or collaborating with the company.

1. Objective

Incidents of bullying, discrimination, harassment and violence still constitute a serious issue n various social realities, including the workplace, public spaces, virtual spaces such as internet, and social life in general. At the other end of the scale, work and interaction within the work environment can offer us the opportunity to contribute to society, achieve personal development, business progress and build up a dignified workplace with zero tolerance of discrimination. The workplace should not serve as the ground on which behaviors of all kinds of violence, harassment or intimidation are cultivated. Any form of harassment, intimidation and violence against employees, whether exercised by colleagues or third parties, is unacceptable, since it violates, inter alia, Law 4808/2021 – Government Gazette 101/A/ 19-6-2021 «On Labor Protection – Establishment of an Independent Authority “Labor Inspection” – Ratification of ILO Convention 190 on eliminating Violence and Harassment in the world of work – Ratification of Convention 187 », as well as DEMO values – adversely affecting mental and/and physical health of those involved.

DEMO complies with all the effective measures and obligations related to applying the provisions of Part II of Law 4808/2021 on prevention and elimination of all forms of violence and harassment, including violence and harassment due to sex and sexual harassment.

This policy aims to put in place and maintain a work environment that respects, promotes and ensures human dignity and the right of every person to a world of work without violence and harassment. DEMO states that it recognizes and respects the rights of every employee to enjoy a work environment free of discrimination, violence and harassment and that it does not tolerate any such conduct, of any kind, by any person.

This policy is applied at all the company’s facilities in Athens, Thessaloniki, every future facility to be establishes domestically and abroad, as well as in places hosting corporate meetings, conferences and all kinds of company, either live or online and as teleconference.

2. Definitions

Violence and harassment are forms of behavior, acts, practices or threats that are intended and impose or potentially impose physical, psychological, sexual or financial harm, whether manifested separately or repeatedly.

Harassment refers to forms of behavior aimed at violating the person’s dignity and generating an intimidating, hostile, degrading, humiliating or aggressive environment, whether or not such behaviors constitutes discrimination, including sexual harassment or any other form of discrimination.

Sexual harassment is defined as any form of undesired verbal, non-verbal or physical behavior under which sexual acts are committed with the intent or effect of infringing on the person’s dignity and generating an intimidating, hostile, humiliating, degrading or aggressive environment.

Gender-related harassment means the forms of gender-related behavior, resulting in violation of the person’s dignity and and generating an intimidating, hostile, humiliating, degrading or aggressive environment as defined in Article 2, Law 3896/2010 (A ‘107) and Par. 2, Article 2, Law 4443/2016 (A’ 232). Such behavior includes sexual harassment under Law 3896/2010, as well as forms of behavior related to a person’s sexual orientation, its expression, identity or gender characteristics.

Discrimination refers to discrimination based on gender, race, color, origin, social status, genetic characteristics, language, religion or belief, political opinion, disability or health status, age or sexual orientation.

Βullying is defined as offensive, intimidating, vicious behavior and/or abuse of power, aiming to undermine or humiliate a person. Examples of bullying include rude treatment of a person, isolating him/her from colleagues, unreasonable threats or comments about the safety of his/her work, etc.

Indicative examples of harassment:

Physical harassment ranging from unwanted tactical contact to severe assault, undesired sexual acts, derogatory comments about a person’s appearance, unwanted jokes or comments of a sexual or racial nature or comments on a person’s age, adverse isolation of a person because of a relationship with another person with a special feature, repeated references related to a person’s religion or beliefs, adverse isolation of a person because he/she is considered to have a specific feature (whether actual or not), use of obscene gestures, etc.

A behavior can be considered harassment, whether the person behaving in this way intends to offend the counterpart or not. Something intended as “funny” can easily offend another person. People are entitled to decide on their own what kind of behavior is acceptable to them and have their feelings respected by the others. Behavior that any reasonable person would perceive to be likely to offend would be considered harassment without the recipient having to explain in advance that the behavior was unacceptable.

Even an isolated incident can be considered harassment if it is rather serious

Where can violence and harassment happen?

• In the workplace, including public and private areas where the employee works, takes a break in order to have a rest or a snack, in personal hygiene and care areas, locker rooms provided by the employer.
• During trips to and from work, other trips, travelling, training, out-of-company areas, through related to corporate meetings as well as at work-related events and in social activities.
• During work-related communications, including those carried out through information and communication technologies.

Discrimination in the workplace

The company avoids discrimination in all fields of employment, including recruitment, promotion, opportunities for training and development, payroll and benefits. We press the equality ahead throughout our human resources.

Altogether, we promote an ethical and professional work environment. We have all developed a sense of honesty.

Job specifications are limited to the requirements necessary to ensure efficient working and meeting the objectives. Candidates for employment or promotion are evaluated based on their skills, competencies, work experience and technical knowledge related to the job description, taking into account any reasonable adjustments that may be required for candidates with a disability.

DEMO provides equal opportunities to all its employees regardless of age, disability, gender, race (including skin color, nationality, origin), sexual orientation, religion or belief. We promote fair treatment, and ensure that talent, skills and achievements of all employees are well recognized, valued and developed.

All DEMO employees and collaborates shall comply with our policy.

3.A/Prevention and Fight against Violence and Harassment at Work

a) Assessing the risk of violence and harassment incidents at work

Demo aims to ensure a safe workplace and strives to prevent and fight against violence and harassment in the workplace and repetitively assesses the existence of such risks at work. In particular, in the context of assessing violence and harassment risk, with the help of an external collaborator, the Company performed an initial assessment of risk sources, focusing on severity, probability and frequency of risk exposure, at its facilities, both in Kryoneri Attica and Thermi Thessaloniki. The report has been received and kept at the Human Resources Department.

b) Measures to prevent, control, limit and address the risks, as well as to monitor such incidents or forms of behavior.

DEMO undertakes to prevent, combat and eliminate discrimination, violence and harassment at work in order to ensure a work environment where human dignity is respected and there is no discrimination based on personal characteristics or choices.

In particular, the Company:

• Ensures that prevention and management measures are adapted to changes in circumstances and strives to improve the existing conditions.
• Follows the instructions of health and safety inspectors and fully facilitates their work during the inspections.
• Supervises sound implementation of employee health and safety measures.
• Informs employees about the issues of occupational risk from their work.
• Prepares plan recording preventive actions and improvement of working conditions, taking into account in particular, organization of work, social relations, environmental and technological factors as well as psychosocial risks.
• Ensures maintenance and monitoring of safe operation of facilities.
• Encourages and facilitates training of employees and their representatives.
• Takes collective measures in order to protect its employees.

Sound provision of information and training of the Company’s its employees will increase their risk awareness and will make them more eager to address the person-in-charge specifically appointed for this purpose by the Company.

Should an informal approach not resolve an arising issue or if the employees deem the situation too serious to be addressed informally, they can file a formal report/complaint directly following the Company’s SpeakUp procedures.

The Company is determined to receive, examine and address all the relevant complaints, demonstrating zero tolerance for discrimination, violence and harassment with respect for human dignity.

In addition, the Company is committed to providing assistance and access to data to any public authority investigating incidents of violence and harassment. This policy is applied in line with the effective legislation on protection of the employee’s personality and does not affect their legal rights at the level of civil and criminal legislation or their rights to file a complaint to any competent authority on a case basis.

c) Initiatives aimed at raising awareness and providing information

DEMO will take initiatives aimed at raising its employees awareness of issues related to discrimination, violence and harassment at work, starting with the establishment of a specific policy, thus highlighting the significance of the issue and its primary role in terms of management.

The Company will inform and train executives and employees in issues regarding identification, prevention and addressing incidents of violence and harassment at work.

It is to be indicatively mentioned that such initiatives include training seminars, competent bodies recommendations or distributing other information material in printed or electronic form.

d) Information regarding rights and obligations of employees and employer, as well as those exercising managerial rights or represent the employer, to the extent of their own responsibility, in case such incidents occurred or were reported.

Our values determine the way we behave and define the relationships between employees, collaborates and management. Our values are distinguished by morality, kindness, mutual trust, respect and honesty.

All Team Leaders/Heads of Departments shall treat their team members fairly, without discrimination, in line with promoting a work environment with zero tolerance of discrimination, incidents of violence and harassment. It’s their duty to raise their teams’ awareness and inform then about the above issues. Should the Team Leaders/Heads perceive or witness such an incident, they shall highlight it and report it following the SpeakUp procedure established by the Company.

Every employee is obliged to help the Company fulfill its commitment to fair treatment, non-discrimination and elimination of incidents of violence and harassment at work.

Employees can be held personally liable for any act of discrimination that violates this policy or the effective legal and regulatory framework. Employees who commit serious acts of harassment may be charged with criminal offense and subject to civil and legal liability in accordance with the applicable legislation.

Incidents of discrimination, harassment, intimidation or victimization against employees or customers/collaborates constitute disciplinary offenses and will be addressed in accordance with the disciplinary procedure, established by the Company, as listed below. In any case, discrimination, harassment, intimidation or victimization can constitutes a serious misconduct and can lead to a complaint being submitted without prior notice.

Employee rights

In case someone has been affected by an incident of violence and harassment at work, during the employment relationship or even if the contract or employment relationship – under which the incident allegedly occurred or such a conduct was experienced – has expired, such a person is entitled to:

• Reporting the incident inside the Company to the person-in-charge or through the SpeakUp procedure, established by the Company
• Right to judicial protection
• Submitting an application for initiating a labor dispute procedure to the Hellenic Labour Inspectorate (SEPE) in the context of his/her legal responsibilities through the Citizens’ Service Phone Line 1555
• Report to the Greek Ombudsman, in the context of his/her legal responsibilities either electronically through the website, or by mail: Chalkokondyli, 17, PC 104 32

e) Appointing a person-in-charge of providing guidance and information to employees regarding preventing and addressing violence and harassment at work

Employees are encouraged to express the concerns – in the context of this policy – they would like to discuss, receive information and/or guidance to Mrs. Betty Arabatzi – Human Resources Department, the person-in-charge of counseling on issues of discrimination, violence and harassment.

The person-in-charge guides and informs the employees regardless of whether they are reporting a specific incident or making a complaint regarding an incident of violence and harassment or not.

The person-in-charge shall place priority on requests arising in the course of one-on-one meetings.

f) Protection of employment and supporting domestic violence victims, in full measure, applying any appropriate means or reasonable adjustment

Demo commits to actively support the employees who fall victims to domestic violence, protecting their employment, informing them about the available counseling support telephone lines (such as direct psychosocial support for women – victims of domestic and gender based violence, SOS 15900 Line of the General Secretariat for Demography and Family Policy and Gender Equality) enabling them to be absent from work (granting special leave) or making temporarily flexible working arrangements if deemed appropriate.

3.Β/Procedures for SpeakUp and Complaints Handling

a) Communication channels – persons-in-charge

The company encourages its employees and collaborates to report incidents of violence, harassment and discrimination in the workplace either directly (when they fell victims themselves) or indirectly (when they witnessed such incidents).

To this end, the Company has established the SpeakUp procedure through an easily accessible communication channel to receive the complaints, made through the telephone line 8004000005

How it works

An incident can be reporter calling the line 8004000005 (24/7), managed by an independent external collaborate who ensures confidentiality and full anonymity of those, who wish to report violations of DEMO Code of Conduct or incidents of discrimination, violence and harassment and provide as much information as possible. The aforementioned communication channel also protects the complainants from potential retaliation or revenge.

b) Impartial investigation and examination of complaints, protecting the victims and complainants confidentiality and personal data

DEMO has established a three-member committee for issues of violence and harassment in the workplace, which will be the guardian of the relative policy. The committee includes the Directors of the following Departments: Legal Compliance, Human Resources and Corporate Governance.

The Company can appoint a Deputy member of the committee on a case basis, if necessary.

The Committee undertakes the responsibility to investigate complaints – promptly and impartially – and protect the confidentiality of the information and victims and complainants personal data, unless otherwise provided by the effective legislation. All the incidents can be reported anonymously or by name.

While examining and evaluating the complaints in order to collect information and data, the committee members are granted access to the Company records, audiovisual material and other appropriate means in order to verify or not verify the complaint.

Once the thorough investigation has been completed, the Committee prepares the report, which will include proposing the measures for protecting the claimant as well as the disciplinary penalties for the offender – if deemed appropriate – to the Company Management that will confirm implementing measures and imposing penalties.

The Committee term of service is set at 12 months and will be annually renewed by the Company’s Board of Directors.

The company fully compliance with the GDPR legislation and the data is processed under its provisions.

c) Prohibition of retaliating the affected person

The committee members act as ambassadors of violence and harassment issues and shall ensure prohibition of retaliating the affected person directly or indirectly, in accordance with Article 13, Law 4808/2021 and the provisions of the Labor Law.

d) The description of the consequences of detection violations

Under Par. 2, Article 12, Law 4808/2021, when an employee or a person employed under another type of job relationship violates the prohibition of violence and harassment set in Article 4 of the same law, the employer is obliged to take the necessary and appropriate measures to address every complaint to ensure that a similar incident or conduct will not repeat in the future. Once the three-member committee has verified the incident of violence and harassment, it can apply the following disciplinary measures regarding the offender:

• Compliance
• Change of job and/or working hours
• Change of place or way of providing services
• Temporary suspension of the employment contract
• Termination of the employment or collaboration contract without prior notice, without prejudice to the prohibition of abuse of right under Article 281 of the Civil Code

However, it is to be noted that malicious submission of a false allegation constitutes a disciplinary offense. The SpeakUp procedure shall not be misused for making reckless accusations or personal complaints.

e) Collaboration with the competent authorities and provision of any relevant information, if requested

The Company, the three-member committee that manages complaints internally and every employee shall collaborate with any competent public, administrative or judicial authority which, either ex officio or at the request of a person concerned, within the scope of its competence, requests data or information and undertake the obligation to provide assistance and access to the data.