A’ Industrial Area of Volos
POLICY TO COMBAT DISCRIMINATION, VIOLENCE AND
HARASSMENT AT WORK
FOR SIOURAS SA. Processing, standardization and marketing of agricultural products
Siouras SA., (hereinafter referred to as the Company) complies with all measures and obligations relating to the implementation of the provisions of Part II of Law 4808/2021 on the prevention and combating of all forms of violence and harassment, including gender-based violence and sexual harassment, and for this reason has drafted and adopted this policy, in accordance with Articles 9 and 10 and the regulatory legislation pursuant to these.
Purpose
The purpose of this policy is to create and maintain a work environment that respects, promotes, and ensures human dignity and the right of every person to a workplace free from discrimination, violence, and harassment. The Company declares that it recognizes and respects the right of every employee to a working environment free from violence and harassment and that it does not tolerate any such behavior, in any form, from any person.
Scope of Application
This policy applies to members of Management and all employees of the Company, whether they work under a fixed-term or indefinite-term employment contract, or provide their services under a salaried contract, a work contract, an independent service contract, a temporary employment contract, a traineeship contract, an employment contract through a third party (service provider).
This policy applies to workplaces within the company’s premises, at its headquarters and any future branches, in places where corporate meetings, conferences and events take place, whether in person, online or by telephone.
Statement
Through this policy, the Company is committed to ensuring a working environment where respect for human dignity prevails and discrimination based on personal characteristics or choices is not permitted.
The company states that it strictly prohibits any form of discrimination, violence, and harassment manifested within the workplace and during working hours. By way of example and without limitation, the company states that it prohibits within its premises physical, verbal and emotional violence, abusive, racist and offensive behavior, the submission and dissemination of comments relating to appearance, age, character, marital status, race, ethnicity, religious beliefs, health, or sexual orientation. It also prohibits the sending of abusive or offensive messages, in particular via its networks and devices, threats, insinuations or innuendo relating to
1 As per the Appendix
sexual favors, which can advance or terminate the individual’s career within the company.
The Company undertakes to investigate seriously and judiciously any complaint concerning violent behavior and harassment in the workplace and to take all appropriate and proportionate measures to address and prevent its recurrence in the future. For the effective management of such complaints, the company follows a specific procedure.
The Company undertakes to provide assistance and access to any competent public, administrative or judicial authority throughout the investigation of incidents of violence and harassment.
The Company prohibits any employee or third party in any way connected with it, to take retaliatory action against another employee or third party who opposes violence or any form of harassment, files a complaint, or assists or participates in the investigation of any incident.
The Company undertakes to provide support by all reasonable and appropriate means to its employees who are victims of domestic violence.
Measures to prevent, control and mitigate risks
Information and awareness-raising actions
The company requires those who are professionally involved with it to follow this policy.
The company, within the limits of its capabilities, takes all appropriate measures
to protect employment and support its employees.
As part of its work culture, the company ensures that the workplace is a place where people trust the people they work for, feel proud of what they do, and enjoy working with their coworkers. The company strives to create a climate of mutual respect, honesty, and courtesy.
The company informs and raises awareness among its staff through printed or electronic material, so that employees are aware of the company’s policies and how it deals with any incidents of violence and harassment.
The company trains its executives to recognize such behavior and encourages them to report incidents in which they are involved, either as victims or witnesses.
Reporting, investigating and handling complaints
In the event that any employee believes that he or she has been subjected to discriminatory treatment, violence, or any form of harassment, or if they have observed such behavior taking place in the workplace, they must report and file a complaint about the incident. Complaints of discrimination, violence, and harassment are investigated promptly, judiciously, and in complete confidentiality. Commenting on confidential information or spreading rumors is expressly prohibited. All employees are protected from victimization, unfair treatment, and adverse changes in conditions as a result of contributing in any way to the investigation of a complaint of harassment or sexual harassment.
Procedure:
- Complaints regarding conduct that constitutes a violation of this policy shall be submitted in writing, either anonymously or otherwise, to the Production Manager, who shall inform the Board of Directors.
- The individual who submitted the complaint shall be informed of its receipt and the progress of its review.
- Communication with the persons involved shall be conducted with discretion and objectivity.
- If deemed necessary, medical and psychological evaluation and support shall be provided.
- The situation is assessed and decisions shall be made.
- Upon completion of the investigation, the company shall announce the results of the investigation, provided that this is practically feasible and appropriate.
- If necessary, the legal representative shall submit a report to the competent authorities for guidance. Depending on the case, proceedings may also be initiated before the Courts.
Action taken
In order to maintain safety and peace in the workplace, as well as the objectivity and integrity of the investigations, the company may, among other things, transfer employees, adjust their working hours, or prohibit access to the company’s premises, either partially or entirely.
If the investigation confirms that an incident contrary to this policy has occurred, the company is entitled to take the following actions:
- Imposition of strict recommendations
- Change of position, working hours, place or manner of performing work
- Termination of employment or partnership agreement
- Recourse to the courts. This policy applies in conjunction with the applicable provisions of Civil and Criminal Law.
Malicious Allegations
Allegations that are proven to be manifestly malicious shall be deemed unacceptable and shall be investigated further at the company’s discretion, both in terms of motives as well as those involved, in order to restore order through all legal means.
Contact persons
All questions relating to the implementation or interpretation of this policy should be submitted to the company’s Human Resources department, specifically to Mr. Nikolaos Siouras, who is designated as the person responsible (Contact Person) for informing and advising staff and for issues relating to the prevention and handling of violence and harassment in the workplace.
This policy was drafted by the legal department on 15/05/2025 and approved by the Board of Directors
APPENDIX
Definitions
Discrimination
Discrimination occurs when a person, on grounds of race, color, national or ethnic origin, ancestry, religious or other beliefs, disability or chronic illness, age, marital or social status, sexual orientation, gender identity or characteristics, is treated less favorably than another person is, has been or would be treated in a comparable situation.
Similarly, discrimination occurs when an apparently neutral provision, criterion, or practice may place persons with certain characteristics of race, color, national or ethnic origin, ancestry, religion or other beliefs, disability or chronic illness, age, marital or social status, sexual orientation, gender identity or characteristics, at a disadvantage compared to other persons.
Violence and Harassment
Violence and harassment are defined as behaviors, actions, practices, or threats thereof, which are intended to, lead to, or are likely to lead to physical, psychological, sexual, or financial harm, whether occurring on a single occasion or repeatedly, and including gender-based violence and harassment.
Harassment constitutes behavior that aims to or may lead to violating an individual’s dignity and creating a problematic environment for the victim.
Harassment prohibited by this policy includes but is not limited to:
- Verbal harassment (abusive comments, insults or accusations, fabricated incidents of intimidation)
- Physical harassment (physical interference with normal work or movement, aggressive gestures or repeated gestures)
- Visual forms of harassment (posters, cartoons, caricatures, photographs, or drawings that are derogatory on the basis of characteristics protected by law).
- Retaliation or intimidation for reporting or threatening to report any of the above forms of harassment or for cooperating in the investigation of an incident of harassment.
Gender-based Harassment & Sexual Harassment
Any unwanted verbal, nonverbal, or physical behavior of a sexual nature that aims to or ends up offending an individual’s dignity, especially by creating an intimidating, hostile, humiliating, degrading, or aggressive environment.
Specifically, sexual harassment is defined as unwanted conduct of a sexual nature, including unwanted sexual advances, requests for sexual favors, and any other unwanted physical or verbal conduct of a sexual nature. Such behavior can be expressed by a person of any gender and includes harassment of a person of any gender.
What is harassment & violence What is not harassment & violence
| Aggressive or threatening behavior, verbal threats or abuse | Direct supervision of employees,
including setting performance expectations |
| Physical assault, highly charged innuendo, sexual photos, offensive language, obscene gestures | Taking measures to correct performance, such as placing an employee on a performance improvement plan |
| Spreading malicious rumors about an individual or group, socially excluding or isolating someone | Assigning tasks and providing guidance on how and when they should be done |
| Destruction, concealment, or theft of personal belongings or work equipment | Requesting updates or progress reports |
| Abuse of power by publicly ridiculing a subordinate | Approving or denying leave |
| Abuse of power by arbitrarily rejecting requests for leave, training, or promotion | Requesting documentation of absences for health reasons based on applicable provisions |
| Abuse of power by soliciting a sexual relationship from a subordinate or making social invitations with sexual overtones to a subordinate | Moral or financial reward for excellent employee performance
|
| Abusive or derogatory comments or jokes about gender, gender identity or gender expression, sex or sexual orientation (e.g. homophobic remarks ) | Providing constructive feedback on job performance |
This policy is approved today 15/05/2025
For SIOURAS SA
Charis Siouras
CEO
