PART I: GENERAL POLICY AGAINST VIOLENCE AND HARASSMENT (Article 9, Law 4808/2021)

1. DEFINITIONS

Discrimination

Discrimination refers to distinctions made based on gender, race, color, ethnic origin or social background, genetic characteristics, religion or beliefs, political opinions, disability or health condition, age, or sexual orientation.

Violence and Harassment

Violence and harassment constitute forms of behavior, acts, practices, or threats that aim at, lead to, or may lead to physical, psychological, sexual, or economic harm, whether manifested individually or repeatedly. Harassment also includes forms of behavior intended to or resulting in the violation of a person’s dignity and the creation of an intimidating, hostile, degrading, humiliating, or offensive environment, regardless of whether such conduct constitutes discrimination, and includes harassment based on gender or for other reasons.

Harassment prohibited under this Policy includes, but is not limited to:

• Verbal harassment, including, for example, insulting comments, offensive remarks, or accusations.
• Physical harassment, including, for example, physical interference with normal work activity.
• Visual forms of harassment, such as posters, cartoons, caricatures, photographs, or drawings that are degrading based on characteristics protected by law.
• Retaliation or intimidation in the event of reporting incidents involving the above forms of harassment or for cooperating in the investigation of harassment incidents.

Gender-Based Harassment and Sexual Harassment

Gender-based harassment constitutes forms of behavior related to a person’s gender, which aim at or result in violating that person’s dignity and creating an intimidating, hostile, degrading, humiliating, or offensive environment. Such forms of behavior include sexual harassment, as well as conduct related to sexual orientation, gender identity/expression a person’s gender identity or gender characteristics. More specifically, sexual harassment is defined as any unwanted conduct of a sexual nature, including unwelcome sexual advances, requests for sexual favors, and any other unwanted physical or verbal conduct of a sexual nature. Such conduct may be expressed by a person of any gender and may involve the harassment of a person of any gender.

For illustrative purposes, some examples of sexual harassment include the following:

• Offering benefits (e.g., career advancement or salary increases) in exchange for sexual favors or creating an environment that promotes “sexual relations” as a means of professional advancement in the workplace.
• Retaliation or threats of retaliation following the rejection of sexual advances.
• Visual conduct: obscene gestures, display of sexually offensive graphic materials in electronic or printed form (e.g., e-mails, voicemail messages, books, files, photographs, etc.), cartoons or posters, or any material containing obscene or sexual insinuations.
• Verbal conduct: degrading comments, sexual innuendos, use of sexual language, or jokes of a sexual nature.
• Physical contact: touching, pinching, sexually suggestive gestures, hitting, grabbing, pushing, etc.

The above acts are indicative and do not constitute an exhaustive list of prohibited acts.

Retaliation

The Company also prohibits any employee or third party, in any way associated with it, from engaging in retaliatory actions against another employee or third party who opposes violence or any form of harassment, files a complaint, provides testimony, assists, or participates in any investigation procedure related to an incident.

2. PURPOSE

Septona S.A. complies with all measures and obligations relating to the implementation of the provisions of Part II of Law 4808/2021 concerning the prevention and addressing of all forms of violence and harassment, including gender-based violence and harassment as well as sexual harassment.

The purpose of this Policy is to prevent and combat all forms of discrimination based on personal characteristics and choices, and to create and maintain a working environment that respects, promotes, and safeguards human dignity and every individual’s right to a workplace free from violence and harassment.

Septona S.A. declares that it recognizes and respects every employee’s right to a working environment free from violence and harassment and does not tolerate any such behavior, in any form, from any person, occurring during work, related to work, or arising from work.

This Policy is adopted in accordance with Articles 9 and 10 of Law 4808/2021 and the regulatory legislation issued pursuant thereto and applies to the persons referred to in paragraph 1 of Article 3 of Law 4808/2021.

3. SCOPE OF APPLICATION

This Policy applies to the Company’s management, employees under dependent employment contracts, individuals providing services under salaried mandate agreements, project contracts, independent services agreements, and temporary employment arrangements, individuals employed through third-party service providers, interns and trainees, employees whose employment relationship with the Company has ended, job applicants to the Company, as well as other individuals who transact or cooperate with the Company.

4. ZERO-TOLERANCE STATEMENT ON DISCRIMINATION, VIOLENCE AND HARASSMENT – RISK ASSESSMENT

The Company expresses its commitment to addressing and eliminating discrimination, violence, and harassment in the workplace, with the aim of ensuring a working environment where respect for human dignity prevails and where discrimination based on employees’ personal characteristics and personal choices will not be tolerated. It is expressly and unequivocally stated that any form of discrimination, violence, and harassment occurring during work, related to work, or arising from work is strictly prohibited.

Indicatively and not restrictively, the Company declares that the following are strictly prohibited: insinuations, mockery, obscene, sexual, or racist jokes or comments, the use of offensive language, comments regarding someone’s appearance or character that cause embarrassment or discomfort, monitoring, stalking, and unwanted verbal or physical attention toward an individual, sending messages of a sexual nature via SMS, e-mail, social media, fax, or letter, offensive and persistent questions regarding a person’s age, marital status, personal life, sexual interests or preferences, as well as similar questions regarding race or nationality, including cultural identity and religion, sexual gestures or persistent requests for dates or threats, suggestions that sexual favors may advance someone’s career or that refusal to engage in a sexual relationship may negatively affect their professional development within the Company, rude gestures, touching, and any kind of unwanted physical contact, spreading malicious comments or insulting someone 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 threatening gestures, insults made publicly or privately, belittling or ridiculing an individual or their abilities either privately or in front of others, angry outbursts directed at someone, persistent or unjustified criticism, exclusion from social events, work group meetings, discussions, collective decisions or planning activities, cyberbullying, offensive electronic messages, letters, and telephone calls.

The Company is committed to providing assistance and access to any competent public, administrative, or judicial authority during the investigation of any incident of violence or harassment.

For employees and any persons connected in any way with the Company who violate the obligations arising from this Policy, the necessary appropriate and proportionate measures shall be taken, as applicable, to prevent and avoid the recurrence of similar incidents or behavior.

5. MEASURES FOR THE PREVENTION, MONITORING, MITIGATION AND MANAGEMENT OF RISKS – AWARENESS & INFORMATION ACTIONS

All employees and any individuals connected in any way with the Company are required to comply with this Policy.

This Policy applies both within the workplace and in locations related to corporate meetings, conferences, and work-related events, whether conducted in person, online, or by telephone.

The Company ensures the creation of, and encourages the maintenance of, an accessible, safe, and supportive working environment where relationships among employees, partners, and management are characterized by mutual respect, courtesy, honesty, understanding, trust, cooperation, and support.

Within the limits of its capabilities, the Company takes all appropriate measures and makes every reasonable adjustment to working conditions to protect employment and support employees who are victims of domestic violence.

The Company takes all necessary measures to inform and raise awareness among its personnel by using appropriate means to combat violence and harassment (e.g., through printed and electronic materials, organizing targeted staff meetings to discuss relevant issues and address potential risks in a timely manner, conducting seminars with mental health specialists or counseling service providers, representatives of voluntary organizations, etc., encouraging the participation of employee representatives and management executives in training programs and educational seminars regarding the identification and management of risks related to violence and harassment in the workplace), ensuring that everyone is aware both of the Company’s policy and procedures regarding incidents of violence and harassment, and of where they may seek assistance in such cases.

The Company trains its executives to identify discrimination, violence, and harassment in the workplace and to provide the necessary support to its personnel and partners.

The Company encourages its employees and any third party connected with it in any way to report incidents of discrimination, violence, and harassment in the workplace of which they may become witnesses.

6. RIGHTS AND OBLIGATIONS OF EMPLOYEES AND THE EMPLOYER IN THE EVENT OF OCCURRENCE, REPORTING, OR COMPLAINT OF SUCH INCIDENTS

Regarding the options available to the affected person: in the event that an individual 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 within which the alleged incident or behavior occurred has ended, they have:

1. a) the right to judicial protection,
2. b) the right to file an appeal, submit a complaint, and request the initiation of a labor dispute procedure before the Labor Inspectorate, within the scope of its legal competencies,
3. c) the right to report the matter to the Greek Ombudsman, within the scope of its legal competencies, and
4. d) the right to submit a complaint within the Company in accordance with the complaint management policy (Article 10 Policy).

In any case, when a report or complaint regarding such conduct arises within the Company, the affected person retains the right to seek recourse before any competent authority.

Regarding Contact Information:

The contact details of the competent administrative authorities to which any affected person has the right to submit a complaint or seek recourse are displayed in a visible location (Labor Inspectorate, Greek Ombudsman), particularly the SEPE complaints hotline through the citizen service line 1555, as well as the immediate psychological support and counseling service for women victims of gender-based violence, SOS Helpline 15900.

Regarding Rights and Consequences of Non-Compliance within the Employment Relationship:

Articles 12–15 of Law 4808/2021 shall apply, namely:

Article 12: Rights of Affected Persons – Consequences of Violating the Prohibition of Violence and Harassment

1. Any person referred to in Article 3 who is affected by an incident of violence and harassment against them under Article 4, even if the employment or cooperation relationship within which the alleged incident or behavior occurred has ended, has the right— in addition to judicial protection — to seek recourse before the Labor Inspectorate and the Greek Ombudsman, acting as the body responsible for promoting and supervising the principle of equal treatment, in accordance with Laws 3896/2010 (Government Gazette A’ 207) and 4443/2016 (Government Gazette A’ 232), as well as the right to submit a complaint within the Company in accordance with the policy of Article 10. 
2. When an employee or any other person engaged under another working relationship, as defined in Article 3, violates the prohibition of violence and harassment under Article 4, the employer is required to take all necessary, appropriate, and proportionate measures against the reported individual, as applicable, in order to prevent and avoid the recurrence of a similar incident or behavior. Such measures may include a recommendation for compliance, change of position, working hours, workplace, or method of work provision, or termination of the employment or cooperation relationship, subject to the prohibition of abuse of rights under Article 281 of the Greek Civil Code.
3. Any person referred to in Article 3 who is subjected to an incident of violence and harassment against them has the right to leave the workplace for a reasonable period of time, without loss of salary or any other adverse consequence, provided that, based on their reasonable belief, there is an imminent serious risk to their life, health, or safety, particularly when the employer is the perpetrator of such behavior or when the employer fails to take the necessary appropriate measures under paragraph 2 to restore workplace peace, or when such measures are not sufficient to stop the violent or harassing behavior. In such case, the person leaving the workplace is required to notify the employer in writing in advance, describing the incident of violence and harassment and the circumstances that justify their belief that there is an imminent serious risk to their life, health, or safety. If the risk does not exist or has ceased to exist and the person referred to in paragraph 3 refuses to return to the workplace, the employer may refer the matter to the Labor Inspectorate and request resolution of the dispute. In such case, Article 18 shall apply.
4. When an employer or a person exercising managerial authority or representing the employer violates the prohibition of violence and harassment under Article 4 during the establishment or refusal to establish a legal relationship with a person referred to in Article 3, or during the development, duration, or termination of such relationship, this constitutes a violation of labor legislation and the administrative sanctions provided under Article 19, paragraph 2(a) shall be imposed.
5. In any case, a violation of the prohibition under Article 4 gives rise, among other things, to a claim for full compensation by the affected person, covering both actual damages and loss of profits, as well as moral damages.

Article 13: Prohibition of Retaliation

The termination or dissolution in any way of the legal relationship on which employment is based, as well as any other adverse treatment of a person referred to in Article 3, is prohibited and shall be deemed null and void where it constitutes retaliatory behavior or a countermeasure within the meaning of Article 14 of Law 3896/2010 (Government Gazette A’ 207) in relation to an incident of violence and harassment under Article 4.

Article 14: Legal Action by Legal Entities and Associations of Persons

Where legal entities and associations of persons, including trade union organizations, demonstrate a relevant legal interest and possess the written consent of the affected person referred to in Article 3 regarding violations of this law, paragraph 2 of Article 22 of Law 3896/2010 (Government Gazette A’ 207) shall apply. In any case, the affected person may intervene in or terminate the procedure.

Article 15: Burden of Proof

When the affected person claims that they have been subjected to violence and harassment in accordance with this Part, paragraph 1 of Article 24 of Law 3896/2010 (Government Gazette A’ 207) shall apply.

The rights relating to the complaint procedure are further outlined in the Policy of Article 10.     

7. FURTHER INFORMATION – CONTACT PERSONS

Through this Policy, Eleana Trikardou is designated as the responsible person to guide and inform employees regarding the prevention and handling of violence and harassment in the workplace, regardless of whether employees contact her in relation to an incident or complaint concerning violence and harassment.

Communication with the above-mentioned person may be made in person by:
(a) visiting the Human Resources Department office,
(b) sending an e-mail to etrikardou@septona.gr, or
(c) calling +30 22620 31205, extension 215.

The above-mentioned Contact Person, as well as any other individual involved in this process, is obligated to protect any Personal Data (PD) that may come to their knowledge during the performance of their role.

PART II – COMPLAINT MANAGEMENT POLICY REGARDING VIOLENCE AND HARASSMENT (Article 10 of Law 4808/2021)

1. RECEIPT OF COMPLAINTS

The Company is committed to providing safe and accessible communication channels for the receipt of complaints. Details regarding the responsible persons and the relevant procedure are set out below in section 3.3.
For the avoidance of doubt, the persons who initially receive the complaint shall also inform the affected individual that they retain the right, at any stage of the procedure followed within the Company, to also submit a complaint either to the competent administrative authorities (Labor Inspectorate, Greek Ombudsman) or to the judicial authorities, at their sole discretion.

2. GUARANTEES OF IMPARTIAL AND CONFIDENTIAL INVESTIGATION OF COMPLAINTS

The Company is committed to receiving, investigating, and handling every relevant complaint by demonstrating zero tolerance toward discrimination, violence, and harassment, with impartiality, confidentiality, and respect for human dignity, while taking immediate measures to protect the affected individual.

The Company has established a comprehensive mechanism for the submission, management, and investigation of reports through the implementation of dedicated reporting channels.

For the purpose of combating discrimination, violence, and harassment, this Policy and Reporting Procedures set out the Company’s principles through which it seeks to prevent and address issues of violence and harassment in the workplace.

The specific procedures for the submission, management, and internal investigation of Reports include the detailed steps that any complainant must follow, as well as the responsibilities of the Company’s bodies and the actions they are required to take in order to ensure the effective handling of relevant incidents.

3. INVESTIGATION AND HANDLING – MANAGEMENT OF COMPLAINTS/REPORTS

3.1 GENERAL PRINCIPLES

The Company has established appropriate mechanisms to conduct a fair, timely, thorough, and objective investigation.

Furthermore, all necessary measures have been taken to ensure the cooperation of all involved parties, whether employees or third parties, in accordance with the internal reporting investigation procedure described below.

The Company handles all incidents involving complaints of discrimination, violence, and harassment with absolute confidentiality and discretion.

Complaints regarding conduct that constitutes a violation of this Policy shall be accepted in writing, either on a named or anonymous basis, and shall be investigated promptly and thoroughly.

Anonymous Reports may be submitted by telephone, in writing, or via electronic mail (e-mail).

In all cases, a prerequisite is that the Report is submitted in good faith, meaning a firm belief in the accuracy of the reported incidents.

Following the receipt of a Report, the Company ensures that:

• confidentiality is maintained and the identity of the person submitting the report is protected in cases where the reporter has chosen not to remain anonymous. However, disclosure of the reporter’s identity may be required during judicial or other legal proceedings in the context of the investigation of the case by the competent authorities.
• Reports are disclosed only to predetermined individuals who are deemed necessary for the investigation of the case and who, by virtue of their duties, are bound to comply with rules of secrecy and confidentiality and to protect any Personal Data (PD) that may come to their knowledge in the performance of their role. In this way, individuals who are the subject of the Report are protected until the examination of the actual facts has been completed.
• The person submitting the Report is appropriately protected from potential adverse consequences, such as acts of retaliation and/or reprisals, other forms of discrimination, or any type of unfavorable treatment. If any employee of the Company or any third party connected with it in any way believes that they have been subjected to retaliatory behavior as a result of submitting a complaint or assisting in the investigation process of incidents involving discrimination, violence, and/or harassment, they are required to report the matter to the person referred to in Section 3.3 for the immediate reporting of such retaliatory conduct.
• The person against whom the Report has been made is, on the one hand, protected from potential adverse consequences, and on the other hand, no measures shall be taken against them if no violation is proven. Furthermore, even in cases where a violation is confirmed following an investigation and measures are taken against that person, the Company undertakes to protect them from unintended adverse consequences beyond the measures imposed by the Company and/or the competent authorities.

However, in order to maintain workplace safety and the integrity of investigations, the Company may, among other things, reassign reported employees or modify their working hours pending the outcome of the investigation. During this period, partial or full access to buildings and/or facilities may be restricted for the reported individuals.

Reports, in order to facilitate the investigation and their proper assessment, may include, indicatively and not restrictively, the facts that constituted discriminatory treatment, violence, or any form of harassment, including references to names, dates, locations, potential witnesses, and any other supporting evidence.

It is clarified that the Report is not expected to fully prove incidents of discriminatory treatment, violence, harassment, etc., on the part of the reporting individual. However, it is recommended that all available information be provided in order to facilitate the investigation of the case as described above.

Individuals who have submitted Reports will be informed of the receipt of their Report and will be updated at regular intervals regarding the progress of its examination.

Upon completion of the investigation, the Company will communicate the results of the investigation as soon as this is practically feasible and appropriate.

If the outcome of the investigation indicates that an incident of discriminatory treatment, violence, harassment, or retaliation has occurred, the Company shall take appropriate corrective, disciplinary, and/or other actions against the offender.

Such actions may include (indicatively and not restrictively):
(a) change of position, working hours, workplace, or method of work provision,
(b) termination of the employment contract or cooperation agreement,
(c) legal action.

In any case, the offender may also incur criminal and/or civil liability in accordance with applicable legislation.

This Policy applies in parallel with the applicable general legislation concerning the protection of employees’ personality rights and does not affect the lawful rights of the affected person under civil and criminal law, nor their right to submit a complaint before any competent supervisory authority (Greek Ombudsman, Labor Inspectorate, either in writing or through the citizen service hotline at 1555, as well as the immediate psychological support and counseling service for women victims of gender-based violence through the SOS Helpline at 15900, etc.).

Any person responsible for receiving and managing such complaints, in accordance with this Policy and the Reporting Procedures, shall cooperate with any competent public, administrative, or judicial authority which, either ex officio or following a request from an affected person and within the scope of its authority, requests the provision of data or information, and they are obligated to provide assistance and access to such information.

For this purpose, any information collected in any form shall be maintained in a relevant file in compliance with the provisions of Law 4624/2019 (Government Gazette A’ 137).

3.2 INFORMAL PROCEDURE

If any employee of the Company or any third party connected with it in any way believes that they have been subjected to discriminatory treatment, violence, or any form of harassment, or if they have observed that such behavior is taking place in the workplace environment and wish to address the incident through an informal process, the affected person is encouraged to follow the steps outlined below:

• Request that the individual (or individuals) causing the problem stop their behavior.
• Submit their complaint in writing to the individual causing the problem.
• Ask a friend or colleague to speak to the individual (or individuals) on their behalf.
• Discuss the situation with their supervisors or with a member of the Human Resources Department and request that an informal approach be made to the individual (or individuals) committing the violation.

The Company encourages affected individuals to keep records of all incidents, the actions they have taken to stop the harassment, and details of any requests for assistance they have made.

3.3 FORMAL PROCEDURE – REPORTING

If any employee of the Company or any third party connected with it in any way believes that they have been subjected to discriminatory treatment, violence, or any form of harassment, or if they have identified that such behavior is taking place in the workplace environment and wish to pursue formal handling of the incident, they must follow the steps described below in order to report the incident.

For reasons of independence, the written Report shall be submitted to the Director of the Company’s Human Resources Department, who is responsible for informing the members of the Report Evaluation Committee.

The Report Evaluation Committee shall be established specifically for the particular case and shall consist of two employees of the Company who are neither the complainants nor the reported individuals.

The Report shall be submitted to the Human Resources Department as follows:

• By telephone at +30 22620 31205, extension 215.
• By sending an email to etrikardou@septona.gr.

The above communication channels operate exclusively as reporting communication lines.

The telephone line is available throughout all working hours during the week, while the e-mail channel is available 24/7.

Access to report-related information is granted exclusively to the authorized officers, under the terms described below and solely for the purpose of managing submitted Reports.

The Report Evaluation Committee is responsible for reviewing all Reports and shall examine all reported incidents of violence and harassment.

If a complaint concerns a member of the Committee, that individual shall abstain from the relevant meeting due to a conflict of interest and shall be replaced by an alternate member.

The Report Evaluation Committee is informed of all submitted Reports by the Authorized General Director of Human Resources.

Subsequently, the Committee conducts an initial review of the issues raised and assigns the case for further investigation to the Heads of the relevant Company Unit where the incident occurred, or to the Internal Audit Department.

The relevant investigation must be completed within two (2) weeks from the assignment of the case to the aforementioned parties.

The findings report shall be submitted to the Report Evaluation Committee.

The Report Evaluation Committee shall convene within seven (7) days from the submission of the relevant findings report and, where the complaint is found to be substantiated, it shall decide on the necessary measures to be taken.

Decisions shall be made by majority vote and shall be promptly communicated to both the affected person and the reported individual.

The individuals responsible for investigating the issues raised may have access to Company records, audiovisual material collected by the Company, and other appropriate means for gathering information and evidence during the examination of the complaint and for verifying the reported allegations.

The Report Evaluation Committee may also handle matters arising outside the present procedure where independent management of such matters is required.

Such matters may arise, among other things, through complaints submitted by Supervisory Authorities or through the complaint procedures of Customers, Suppliers, and Employees originating from different communication channels.

4. MALICIOUS COMPLAINTS

Complaints that are proven to be manifestly malicious shall be deemed inadmissible and may be subject to further investigation at the Company’s discretion, both in relation to the motives behind such complaints and the individuals involved, in order to restore order through any lawful means and measures.

5. FURTHER INFORMATION – CONTACT PERSONS

All questions relating to the implementation or interpretation of this Policy should be submitted to the Personnel Director, who is designated as the responsible person (Contact Person) for informing and providing advisory guidance to personnel, as well as for matters concerning the prevention and handling of violence and harassment in the workplace.

The role of the Contact Person is strictly informational, and employees may contact them:

(a) in person by visiting the Human Resources Department office,

(b) by sending an email to etrikardou@septona.gr, or

(c) by calling +30 22620 31205, extension 215.

The above-mentioned Contact Person, as well as any other individual involved in this process (e.g., the person receiving the complaint, the Report Evaluation Committee, etc.), is obligated to ensure the full protection of any Personal Data (PD) that may come to their knowledge in the performance of their role.