INTRODUCTION

Our company “ORGANIZATION LEMENOS PATRON SA“, located in the Services Building of Patras N. Port of Patras, Tax ID 090017574 – Tax Office of Patras No. G.E.M.H. 123457916000, telephone number 2610 365 113, e-mail addressinfo@patrasport.gr, comply with all measures and obligations relating to the application of the provisions of Part II of Law No. 4808/2021 , on preventing and responding to 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 consolidate a working environment that respects, promotes and safeguards human dignity and the right of every person to a world of work free from violence and harassment. Our company declares that it recognizes and respects the right of every employee to a work environment free of violence and harassment and will not tolerate any form of violence and harassment, whether related to or arising out of work, including gender-based violence and harassment and sexual harassment.

FIELD OF APPLICATION

This policy is adopted in accordance with the provisions of articles 4 to 8, 13, 14, 15 and, by analogy, article 12 of Law 4808/2021 and in particular the provisions authorised by par. 4 of article 22 of the same law, decisions of the Minister of Interior (No. DIDAD/F.64/946/ok.858/19-1-2023/B’343; No. DIDAD/F.64/996/ok.858/19-1-2023/B’343; No. DIDAD/F.64/996/ok. 6766/19-4-2023/B 2561 ) and covers employees and staff, irrespective of their employment status and their employment relationship within the institution. ( Article 3 of the Decree ).

TERMS

For the purposes of this policy:

(a) “violence and harassment” means any form of conduct, acts, practices or threats thereof, intended to cause, resulting in or likely to result in physical, psychological, sexual or economic harm, whether occurring in isolation or repeatedly,

(b) ‘harassment’ means any form of conduct which has the purpose or effect of violating the dignity of a person and of creating an intimidating, hostile, degrading, humiliating, dehumanising or offensive environment, whether or not it constitutes a form of discrimination, and includes harassment on grounds of sex or other grounds of discrimination,

(c) “gender-based harassment” means forms of conduct related to the gender of a person, which have the purpose or effect of violating the dignity of that person and creating an intimidating, hostile, degrading, humiliating, humiliating or aggressive environment as defined in Article 2 of Law No. 3896/2010 (A’ 107) and par. 2 of Article 2 of Law No. 4443/2016 (Α` 232). These forms of conduct include sexual harassment under Law no. 3896/2010, as well as forms of conduct related to the sexual orientation, expression, identity or gender characteristics of the person.

For the purposes of the application of this Article, forms of violence and harassment against the persons referred to in Article 3 may take place in particular:

(a) at the workplace, including public and private places and places where the worker performs work, receives pay, takes a break, in particular for rest or eating, in personal hygiene and care facilities, changing rooms or accommodation provided by the employer,

(b) travel to and from work, other travel, travel, education, and work-related events and social activities; and

(c) in work-related communications, including those carried out through information and communication technologies.

SPECIFICALLY:

1. INFORMATION AND PREVENTION MEASURES ON VIOLENCE AND HARASSMENT

1. The company, with the assistance of the relevant safety engineer and the company’s occupational physician, assesses the risks of violence and harassment at work, taking into account any inherent risk arising from the nature of the activity, the workplace, factors such as gender and age or other discriminatory characteristics, as well as risks relating to specific groups of workers (e.g. new recruits).
2. The company takes measures to prevent, control, mitigate and address such risks, as well as to monitor such incidents or forms of behaviour, demonstrating zero tolerance of violence and harassment, acting with confidentiality and respecting human dignity. By way of illustration, the company encourages the maintenance of a working climate where respect for human dignity, cooperation and mutual assistance are core values. It undertakes actions to raise awareness among employees of healthy standards of behaviour and of issues concerning vulnerable categories of employees.

The company also has a reporting/complaint management procedure and regularly evaluates the effectiveness of its actions.

1. The company undertakes actions to inform and raise awareness among staff about the potential risks of violence and harassment in the workplace and the relevant prevention and protection measures in the event of such incidents. Targeted meetings may be organised as part of staff awareness-raising to discuss relevant issues and address potential risks in a timely manner. Participation of management and employee representatives in in-house training seminars on the identification and management of risks of violence and harassment at work is also encouraged.
2. The company shall provide information on the rights and obligations of employees and the employer, as well as of persons exercising managerial authority or representing the employer, to the extent and to the extent of their responsibility, in the event of the occurrence, reporting or reporting of such incidents, as well as on the relevant procedure for receiving and investigating complaints.

Β. PROCEDURE AND BODIES FOR REPORTING INCIDENTS OF VIOLENCE AND HARASSMENT

1. Any person affected by an incident of violence or harassment in access to employment, during the employment relationship or even if the contract or employment relationship under which the incident or conduct is alleged to have occurred has ended, in addition to judicial protection, has the right to lodge a complaint:

1.1. before the Ombudsman

1.2. within the Company where the work is provided, in accordance with the complaints handling policy.

1.3. before the National Transparency Authority, if a complaint has been lodged with the competent bodies and persons referred to in para. 1.1 and 1.2, and have not been duly dealt with after three months from the date of submission of the complaint.

The contact details of the competent authorities are as follows:

Ombudsman line: 213 13 06 600 (e-mail: press@sinigoros.gr),

National Transparency Authority 213 2129 700 (e-mail: info@aead.gr ),

1. The company ensures safe and easily accessible communication channels for receiving and addressing complaints and keeping complainants informed, facilitating the relevant processes. Specifically, the person responsible for receiving (with a confidentiality protocol), examining, and managing complaints or grievances related to acts of violence or harassment is the current Chief Executive Officer of the Company, as the highest administrative authority responsible for staff (Article 5, Paragraph 2 of the relevant Ministerial Decision). The communication should be directed to the email address manager@patrasport.gr.

In any case, the affected person will be informed, at any stage of the procedure followed within the company, of his/her possibility to submit a complaint to the competent administrative authorities within their competence (Ombudsman, National Transparency Authority) as well as to the competent judicial authorities of his/her choice.

1. The receipt, investigation and examination of the validity of complaints is carried out promptly and impartially within five (5) working days from the submission of the complaint ( paragraph 3 of Article 5 of the MOU ), in a manner that respects human dignity and ensures the protection of the confidentiality and personal data of complainants and complainants collected in the exercise of the above duties.
2. If the conclusion of the above examination results in disciplinary responsibilities, this conclusion is forwarded within three (3) days to the disciplinary head of the complainant, for disciplinary action ( paragraph 3 of Article 5 of the YA ).
3. The company and any person responsible for receiving and handling complaints undertake to provide their cooperation and assistance and any relevant information to the competent public, administrative and judicial authorities, if requested by them, which they shall keep in a file in accordance with the provisions of Ν. 4624/2019 .
4. The National Transparency Authority, in addition to the actions referred to in par. 3 of Article 5 of the YA, investigates any disciplinary responsibilities of the institution before which the complaint was submitted and which culpably delayed the examination of the complaint, with the exception of cases where the complaint was submitted to the Ombudsman.

Γ. PROTECTIVE MEASURES – PROHIBITION OF RETALIATION

1. In the event that a violation is found, the company will take the necessary, appropriate and proportionate measures against the complainant, as the case may be, in order to prevent a similar incident or behaviour from happening again. Such measures include, but are not limited to, recommending compliance, changing the position, changing the hours, changing the place or manner of work, or terminating the employment or cooperation relationship, without prejudice to the prohibition of abuse of right in Article 281 CC.

1. The measure of transfer to another organisational unit, change of workplace or working hours may also be applied to the affected person if a request is made and in this case the company is obliged to consider this request as a priority.

1. The affected person has the right to be excused from the workplace for a reasonable period of time, not exceeding three (3) working days, without loss of pay or other adverse consequence, if, in his/her reasonable belief, there is an imminent serious risk to his/her life, health or safety, in particular where the perpetrator of such conduct is his immediate superior or where, despite the lodging of a complaint, the necessary and appropriate measures have not been taken to restore the normal functioning of the Office or where such measures are not sufficient to stop the behaviour of violence and harassment.

1. In the case referred to in paragraph C.3, the staff member concerned shall inform the bodies referred to in paragraph B.1 beforehand, stating the incident of violence and harassment and the circumstances which justify his belief that there is a serious risk to his life, health or safety. Where the risk does not exist or has ceased to exist or the Agency has taken the necessary measures referred to in paragraph C.1 and the person refuses to return to the place of work, the absence shall cease to be excused.

1. The company undertakes to comply with the obligation of non-retaliation, in accordance with Article 7 of the SO and the provisions of labour law.

1. The company shall ensure employment protection and support for employees of victims of domestic violence, as far as possible, by any appropriate means or reasonable accommodation, including but not limited to flexible working arrangements at the request of an employee of a victim of domestic violence.

This policy may be revised – amended to bein full compliance with the relevant legislation.