POLICY OF THE COMPANY “AMMON ZEUS HOTEL & TOURISM ENTERPRISES S.A.” FOR THE PREVENTION AND COMBAT OF VIOLENCE, DISCRIMINATION, AND HARASSMENT IN THE WORKPLACE, AS WELL AS FOR THE HANDLING AND MANAGEMENT OF INTERNAL COMPLAINTS REGARDING INCIDENTS OF VIOLENCE, DISCRIMINATION, AND HARASSMENT IN THE WORKPLACE

POLICY OF THE COMPANY “AMMON ZEUS HOTEL & TOURISM ENTERPRISES S.A.” FOR THE PREVENTION AND COMBAT OF VIOLENCE, DISCRIMINATION, AND HARASSMENT IN THE WORKPLACE, AS WELL AS FOR THE HANDLING AND MANAGEMENT OF INTERNAL COMPLAINTS REGARDING INCIDENTS OF VIOLENCE, DISCRIMINATION, AND HARASSMENT IN THE WORKPLACE

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Company Policy

“AMMON ZEUS HOTEL AND TOURISM ENTERPRISES S.A.”
for the prevention and combating of violence, discrimination, and harassment in the workplace, as well as for the handling and management of internal complaints concerning incidents of violence, discrimination, and harassment in the workplace

Introduction

  1. The company “AMMON ZEUS HOTEL AND TOURISM ENTERPRISES S.A.” (hereinafter the “Company”) complies with all measures and obligations related to the implementation of the provisions of Part II of Law 4808/2021 for the prevention and response to all forms of violence and harassment, including gender-based violence and harassment and sexual harassment. In compliance with Law 4808/2021 and Ministerial Decision No. 82063/2021, and demonstrating zero tolerance toward incidents of violence and harassment in the workplace, it adopts this policy, which is already in force in due time, pursuant to Article 23 of Law 4808/2021, after first informing employees of the draft content and posting it in a visible place in the workplace (central notice board) for ten (10) working days in order to receive comments and observations, in fulfillment of its legal consultation obligation. The final text of this policy is the present one, in accordance with Law 4808/2021, which ratified International Labour Organization Convention 190 of 21/06/2021 concerning the elimination of violence and harassment in the world of work, the text of which was annexed verbatim to the law and which shall henceforth apply in parallel with the above-mentioned Policy.

Article 1

Purpose – Notification

  1. 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 work without violence and harassment. A more specific purpose is the prevention and combatting of any form of discrimination based on physical characteristics and personal choices, as well as any violence and harassment manifested during work, whether connected with it or arising from it in any way. Through the provisions of this policy, the proper procedure to be followed in the event of such incidents will also be highlighted.
  2. This Policy is communicated to the Company’s staff and to any third party connected in any way with it, as specified for such persons in Article 2 of this document, namely:
    a) by permanent posting, as required by law, on the Company’s website accessible to all employees, and
    b) by posting it in visible and accessible places in the workplace, as appropriate (e.g., central notice board).
    By cumulatively observing the above notification requirements, knowledge of the content of this policy by each person subject to it is presumed.
  3. The Company is obliged to provide a copy of this policy to any person subject to it who requests it. Instead of delivering a copy, this may be communicated by email to an address that has been notified to the Company or that will be notified for this purpose. No person subject to this policy may invoke ignorance of it, which they are obliged to know and observe. Matters not regulated by the provisions of this policy are governed by the law in force at any given time, as well as by special rules, instructions, and procedures of the Company for the prevention and handling of incidents of discrimination, violence, and harassment in the workplace.

Article 2

Scope of Application

  1. The scope of this policy includes staff and associates connected with the Company in any way, namely the management and members of the Company, employees under dependent employment contracts, persons providing services under paid mandate, contract for work, independent services, and temporary employment agreements, persons employed through third-party service providers, interns and trainees, volunteers, job applicants, employees whose employment relationship with the Company has ended, and other persons who transact or cooperate with the Company.

Article 3

Statement of Zero Tolerance – Definitions

  1. The Company expresses its commitment to addressing and eliminating discrimination, violence, and harassment in the workplace, with the aim of ensuring a work environment where respect for human dignity prevails and discrimination based on physical or personal characteristics and personal choices will not be permitted. It is expressly and categorically stated that any form of discrimination, violence, and harassment due to gender or for any other reason occurring during work, whether connected to it or arising from it, is strictly prohibited.
  2. For clarity, and together with the following indicative examples of prohibited behavior, the following definitions apply:

A. “Workplace” means a broader spatial framework in which incidents of discrimination, violence, and harassment may occur or be threatened, specifically:

  • At the workplace, including public and private spaces and places where the employee performs work, receives pay, takes breaks or rests, and in individual hygiene and care areas.
  • During travel to and from work, other travel, business trips, training, and work-related events and social activities.
  • During work-related communications, including those carried out through information and communication technologies (company emails and mobile phones).

B. “Discrimination” includes, indicatively, discrimination based on sex, race, color, nationality or social origin, genetic characteristics, language, religion or political beliefs, disability or special abilities and health status, age, sexual orientation, and financial status.

C. “Violence and harassment” means forms of behavior, acts, practices, or threats thereof, which aim to cause, lead to, or may lead to physical, psychological, sexual, or financial harm, whether occurring individually or repeatedly.

D. “Harassment” means forms of behavior that aim to or result in the violation of a person’s dignity and the creation of an intimidating, hostile, degrading, humiliating, or aggressive environment, regardless of whether they constitute discrimination, and include harassment based on gender or for other discriminatory reasons.
The harassment prohibited by this policy includes, but is not limited to: verbal harassment, including abusive or offensive remarks, insults, or accusations; physical harassment, including, for example, physical interference with normal work or movement; visual forms of harassment, such as posters, cartoons, caricatures, photographs, or drawings that are derogatory on the basis of characteristics protected by law and this policy; retaliation or intimidation in the event of reporting or threatening to report any of the aforementioned forms of harassment or cooperating in the investigation of a harassment incident, as specified in a later article of this policy.

E. “Gender-based harassment” means forms of behavior related to a person’s gender that aim to or result in the violation of that person’s dignity and the creation of an intimidating, hostile, humiliating, degrading, or aggressive environment. These forms of behavior include sexual harassment under Law 3896/2010, as well as forms of behavior related to a person’s sexual orientation, expression, identity, or gender characteristics.

F. “Sexual harassment” is defined as unwanted behavior of a sexual nature, including unwanted sexual advances, requests for sexual acts, and any other unwanted physical or verbal act of a sexual nature. Such behavior may be expressed by a person of any gender and includes harassment of a person of any gender.
For explanatory purposes, some indicative examples of sexual harassment are:
i. Offering benefits (e.g., promotion or salary increase) in exchange for sexual acts or creating an environment that promotes “sexual contact” as a means of career advancement in the workplace.
ii. Retaliation or threats of retaliation after rejection of sexual advances.
iii. Visual behavior, namely obscene gestures, display of offensive sexual materials in electronic and printed form (e.g., email, voicemail, messages, books, files, photographs, etc.), cartoons or posters, or any material with obscene or sexual insinuations.
iv. Verbal behavior, namely derogatory remarks, sexual innuendo, use of sexual “language” or “jokes” of sexual content.
v. Oral sexual harassment or propositions.
vi. Sexual verbal abuse, namely sexual comments about a person’s body, derogatory sexual comments used to describe a person, sexually suggestive or obscene remarks in conversation, letters, invitations, notes or other remarks, epithets and labels.
vii. Physical contact of any kind, for example touching, pinching, sexual gestures, grabbing, pushing, etc.
The above acts are indicative and do not constitute an exhaustive list of prohibited acts. An employee or third party engaging in such prohibited conduct shall bear full responsibility for their actions.

G. “Domestic violence” means all acts of physical, sexual, psychological, or economic violence occurring within the family or home, regardless of biological or legal family ties, or between former or current spouses or partners or cohabitants, and regardless of whether the perpetrator shares or previously shared the same residence as the victim.
Domestic violence taking place in the workplace, for example through physical violence, sexual harassment, and stalking by current or former partners, constitutes a serious form of violence in the workplace. Acts of domestic violence, including stalking, may also be committed by people in the same work environment with whom the victim has (or had) close relationships. Domestic violence, in any of the above forms, is also deemed to include violence committed against the employee during teleworking.

Article 4

Prohibited Forms of Conduct – Distinction of Workplace Conduct

  1. Indicatively, and not exhaustively, in addition to what is analyzed in Article 3, innuendo, mockery, obscene, sexual, or racist jokes or comments, the use of offensive language, comments about someone’s physical characteristics or character that cause shame or embarrassment, surveillance, stalking, and unwanted verbal or physical attention toward a person, the sending of sexual messages via SMS, email, social media, fax, or letter, offensive and persistent questions about a person’s age, marital status, personal life, sexual preferences, as well as persistent questions about their race or origin, including their cultural identity and religion, sexual gestures or persistent propositions for personal meetings implying that they will help career advancement and financial benefits, threats that refusal to enter into a sexual relationship or engage in any sexual act may negatively affect one’s professional course in the Company, rude gestures, touching and any kind of unwanted physical contact, spreading malicious remarks or insulting someone mainly because of discrimination based on age, sex, marital status, civil partnership, pregnancy and motherhood outside marriage, any disability, sexual preferences, religion or beliefs, threats whether verbal or by gesture, insults in public or in private, belittling or ridiculing a person or their abilities and generally insulting their personality, whether privately or in front of others, expressions of anger toward someone, persistent or unjustified criticism of all the above, exclusion from social events, work-group meetings, discussions and collective decisions or planning, cyberbullying, offensive emails, letters, and phone calls, are strictly prohibited.
  2. To ensure proper understanding and to preserve both professional balance and the safety of all employees, it is clarified, indicatively and case by case, which behaviors do not constitute incidents of violence and harassment when carried out in the exercise of lawful and contractual rights and obligations:
  • direct supervision of employees, including setting performance expectations;
  • measures to correct performance, such as placing an employee on a performance improvement plan;
  • assigning tasks and giving guidance on when and how they should be done, requesting updates or progress reports, approving or denying leave, requesting documentation of absence for health reasons under the applicable provisions, and any moral or financial reward for excellent performance through additional voluntary benefits from the Company, as well as constructive feedback about work performance.
  1. The Company undertakes to receive, investigate, and manage every relevant complaint, demonstrating zero tolerance for discrimination, violence, and harassment, with confidentiality and respect for human dignity. It also undertakes not only not to obstruct, but also to assist in the receipt, investigation, and handling of such complaints. The Company undertakes to provide assistance and access to any competent public, administrative, or judicial authority in the investigation of any incident of violence and harassment. For employees and any persons connected with the Company in any way who violate the obligations arising from this policy, appropriate and proportionate measures are taken as necessary, as the case may be, to prevent and avoid repetition of a similar incident or behavior. With the aim of combating discrimination, violence, and harassment, the Company has created a comprehensive reporting, management, and investigation mechanism, by establishing specific reporting channels, as analyzed in the following articles. The individual procedures for reporting, handling, and internal investigation include the detailed steps that any complainant must follow, as well as the responsibilities of the Company’s bodies and the actions they must take to ensure effective handling of relevant incidents.

Article 5

Obligations of the Company – Preventive Measures Against Violence and Harassment

  1. The Company once again declares zero tolerance for any incident of discrimination, violence, and harassment, in whatever form it may occur at work or in connection with work, whether by one employee against another, by a supervisor, by an authorized person acting as employer, by a customer, visitor, supplier, or any third party.
  2. All employees and persons connected with the Company in any way, as provided in Article 2, must comply with this policy. The policy applies both in workplaces, as defined in Article 3, and in places related to corporate meetings, conferences, and events connected with work, whether at the Company’s facilities (at its corporate headquarters in Thessaloniki and its hotel facilities in Kallithea, Municipality of Kassandra, Halkidiki) or outside, and whether in person, online, or by telephone. The Company ensures an accessible, safe, and friendly work environment where relationships among employees, associates, management, and Company members are characterized by mutual respect, courtesy, sincerity, understanding, trust, cooperation, and support.
  3. Within the limits of its capabilities, the Company takes every appropriate measure and makes every reasonable adjustment to working conditions to protect work and support employees who may be subjected to any form of discrimination, violence, or harassment. The Company takes all suitable and necessary measures for both prevention and for addressing and managing such incidents and forms of behavior. Specifically, the Company:
    A. Provides information and appropriate training to employees regarding the handling and management of incidents of discrimination, violence, and harassment, and informs them of their rights and obligations.
    B. Maintains open communication with employees and encourages them to maintain an appropriate working climate in which respect for human dignity, cooperation, and mutual assistance are fundamental principles.
    C. Monitors the implementation of this policy, ensuring that everyone knows the policy and the Company’s procedures regarding incidents of violence and harassment and knows where to turn in the event of violence or harassment.
    D. Ensures a safe and fair working environment, encouraging employees and any third party connected with it in any way to report incidents of discrimination, violence, and harassment in the workplace that they witness and/or are indirectly affected by.
    E. Takes measures regarding employees who do not comply and imposes the necessary and appropriate sanctions in the event of confirmed prohibited behavior by any employee, customer, associate, supervisor, etc.

Article 6

Obligations of Managers / Supervisors and Senior Executives

The Company’s Directors, Supervisors, and generally its senior executives must:
A. Ensure the implementation of this policy within their area of responsibility.
B. Form appropriate conduct standards within their area of responsibility.
C. Refrain themselves from exhibiting unwanted and prohibited behavior in the performance of their duties.
D. Act immediately when they become aware of any prohibited behavior.
E. Encourage employees to report any incidents of violence and harassment that they themselves suffered or witnessed.
F. Immediately inform the Company’s Management of any incidents of violence and harassment that took place in their area of responsibility.

Article 7

Obligations and Rights of Employees

  1. With the aim of preventing and addressing incidents of violence and harassment in the workplace, each employee is obliged to:
    A. Seek complete and objective information about the legislation and the policies implemented by the Company regarding violence, harassment, and protection mechanisms. The Company may provide assistance and information on these matters.
    B. Comply with this policy and all applicable and current procedures for the protection of both themselves and other persons employed by the Company.
    C. Immediately report any incident of violence and harassment to the competent Supervisor overseeing their area of work, or to the competent Director, and in any case to the Company’s Management.
    D. Cooperate in the event of an investigation into a complaint filed against them under the procedure below.
    E. Participate in the Company’s training actions and programs concerning incidents of violence and harassment.
    F. Correct their behavior when they realize it is annoying or offensive to a colleague, associate, or any person connected with the Company, and when such correction is pointed out to them.
    G. Set their own personal boundaries with those around them.
  2. Every employee is entitled to:
    A. Be treated with respect and courtesy.
    B. Not be subjected to violent behavior, harassment, including sexual and gender-based violence, adverse discrimination, and bullying.
    C. Report any incident of prohibited behavior in the workplace under this policy, as analyzed below, without being victimized or suffering any other adverse consequence or retaliation.

Article 8

Reporting, Investigation, and Handling of Complaints – Contact Person

  1. If any employee of the Company or third party connected with it in any way believes they have been subjected to discriminatory treatment, violence, or any form of harassment (hereinafter the “directly affected person”) or if they have become aware that such behavior is taking place in the work environment (hereinafter the “indirectly affected person”), they must follow the procedure in this article to report the incident. The Company has created appropriate mechanisms for conducting a fair, timely, thorough, and objective investigation, following the proper procedure for diagnosing and addressing such incidents.
  2. Within this framework, and for the more complete handling of the above incidents, the Company must, by any appropriate means, continuously assess existing workplace risks, including psychosocial risks, for the safety and health of employees, in accordance with Article 43 of Law 3850/2010, as well as the protection measures that must be taken to address the issues regulated by this policy, in accordance with its terms.
  3. In the case of paragraph 1 of this article, the directly or indirectly affected person may submit a verbal or written complaint (hereinafter also the “complainant”) to the Chairwoman and CEO, Ms. Efrosyni Psychopoulou of Alexandros, who is also designated as the “contact person” for this policy. The complaint may be submitted in person or by email to “[email protected]”. Every complaint, whether named or anonymous, will be investigated immediately.
  4. The complaint must state the details of the accused person, namely the person who engaged in a prohibited form of behavior, as well as the specific incident(s) supporting it.
  5. The contact person, themselves or a person specially authorized by them for this purpose, thoroughly investigates each complaint and collects any necessary evidence relating to it. Complaints and investigations remain strictly confidential to the maximum possible extent, taking into account the sensitivity of the case and the privacy of all involved.
  6. In examining the complaint, the contact person has the right to speak with the complainant and the accused person, examine witnesses, request the production of documents that may exist and that prove whether or not any incident of violence and harassment took place, and communicate with the Supervisors of each department if the complainant approached them.
  7. To preserve workplace safety and the integrity of investigations, the Company may, among other things, relocate employees or modify their working hours pending the outcome of the investigation, with the consent of the employee concerned. During this period, partial or full access to buildings and/or facilities may not be permitted.
  8. Once the contact person completes the investigation, they submit a written report to the Company’s Board of Directors stating the outcome of the investigation. The results of the investigation are simultaneously communicated to both the complainant and the accused person so that they may be informed. The investigation and the submission and notification of the contact person’s findings must take place as soon as possible and in any case no later than fifteen (15) working days from the date of submission of the complaint by the complainant.
  9. If the investigation actually establishes the occurrence of discrimination, violence, and/or harassment in the workplace, in violation of any term of this policy, the Company’s Management shall, as appropriate, take all necessary, suitable, and proportionate measures against the accused person. These measures may include, indicatively and not exhaustively:
    a) a compliance notice (verbal or written),
    b) a change in the employee’s position, working hours, place, and method of work,
    c) disciplinary sanctions, as may be provided by the applicable Work Regulations,
    d) termination of the accused person’s employment contract, subject to Article 281 of the Greek Civil Code regarding abuse of rights,
    e) legal action against the accused person.
  10. In any case, the accused person may also incur criminal or civil liability under applicable law. This policy applies in parallel with the general law in force for the protection of the employee’s personality and does not affect their legal rights under civil and criminal law, nor their right to file a complaint before the competent Inspection Authority.

Article 9

Obligation of Impartiality and Confidentiality

  1. The contact person is obliged to act during the complaint investigation process in an objective and impartial manner. In addition, they must behave with respect and discretion toward all parties involved, in a confidential and discreet manner. Disclosure or communication to uninvolved parties of information relating to any complaint under examination is strictly prohibited.
  2. The above obligations also apply to the Company’s Management during the final stage of taking measures and decisions.

Article 10

Rights of Affected Persons

  1. According to the applicable law, any person who suffers an incident of discrimination, violence, or harassment has the right to leave the workplace for a reasonable period without loss of pay or other adverse consequence, provided that, in their reasonable belief, there is an imminent serious risk to their life, health, or safety, especially when the employer is the perpetrator of such conduct or when the employer does not take the necessary appropriate measures to restore workplace peace, or when such measures are not capable of stopping the violent or harassing behavior.
  2. In that case, the person leaving must first notify the contact person in writing, describing the incident of violence or harassment and the facts that justify their belief that there is an imminent serious risk to their life, health, or safety.
  3. If no solution is reached regarding the complaint concerning violent or harassing conduct in the workplace, the affected persons have the right to resort to the competent authorities, as provided by law, namely:
    a) judicial protection,
    b) recourse to and filing of a complaint and a request for the conduct of a labor dispute before the Labor Inspectorate within its legal competence,
    c) a report to the Ombudsman within his legal competence.

Article 11

Prohibition of Retaliation Against the Affected Person / Complainant

  1. Termination, or any other form of termination of the legal relationship on which employment is based, as well as any other detrimental treatment of a person referred to in Article 3 of Law 4808/2021, is prohibited and void if it constitutes retaliatory behavior or countermeasure within the meaning of Article 14 of Law 3896/2010 for an incident of violence and harassment under Article 4 of Law 4808/2021, in accordance with the relevant provisions of this policy.
  2. Any act of retaliation, reprisal, and victimization of the directly or indirectly affected person, who opposes violence or any form of harassment, has claimed their rights as an affected person and filed a complaint regarding an incident of violence and harassment, or gave testimony, assisted, or participated in any investigation process, is also prohibited for any person subject to this policy. Retaliation and victimization of the affected person/complainant constitute a serious violation of this policy and entail consequences under Article 8(9) of this policy for the person acting in such a manner.
  3. If any affected person believes that they have suffered retaliatory conduct due to filing a complaint or assisting in the investigation of incidents of discrimination, violence, and/or harassment, they must immediately inform the contact person and report the retaliatory incident.

Article 12

Malicious Complaints

  1. Complaints that are proven to be manifestly malicious shall be deemed not to have been filed and may be further investigated, at the Company’s discretion, both as to motives and as to the persons involved, in order to restore order by every lawful means and method.

Article 13

Cooperation with Administrative and Judicial Authorities

  1. If the affected person has filed a complaint concerning an incident of violence and harassment before any administrative or judicial authority, the Company undertakes to provide any necessary assistance and support, as well as any information it may have, to the competent authorities.
  2. The same obligation is deemed appropriate for the Company’s employees, as well as any third party connected with it in any way.

Article 14

Cases of Domestic Violence

  1. The Company takes, to the extent possible, measures to protect employment and support employees who are victims of domestic violence in the workplace.
  2. Any employee who has suffered domestic violence that also affects the workplace may report this verbally or in writing to the Supervisor of the department to which they belong, or to the competent Director, so that the Company may be informed and take the appropriate and necessary measures, in the manner legally and substantively possible.

Article 15

Further Information and Guidance

  1. All questions related to the implementation or interpretation of this policy should be directed to the Contact Person, namely the Chairwoman and CEO, Ms. Efrosyni Psychopoulou of Alexandros, for information, guidance, and advisory support to staff, as well as for matters concerning the prevention and handling of discrimination, violence, and harassment in the workplace.

For the Company,
The Legal Representative

Appendix I

External Information Sources of Nationwide Scope

Contact Details of Competent Authorities

  • Labor Inspectorate complaints line: Call 1555 citizen service line (operates 24/7)
  • Hellenic Police: Call 100 (operates 24/7)
  • Domestic violence: Call 100 (operates 24/7). If you cannot speak, send SMS to 100. Visit the Citizen’s Guide on the Hellenic Police website. Call the SOS line 15900 for domestic violence (operates 24/7)
  • General Secretariat for Demographic and Family Policy and Gender Equality: Call 15900 (operates 24/7). If you cannot speak, send email to [email protected]
  • Useful websites: https://isotita.gr and http://womensos.gr
  • Ombudsman (Independent Authority): Call 213 1306 600, email [email protected], website www.synigoros.gr

For the Company,
The Legal Representative