1. Preamble.

1.a. Integrity and respect for all individuals are of paramount importance to Evivios Med EE (hereinafter the “Company”) and constitute an integral part of its corporate environment.

1.b. The Company has established a workplace in which the individuality of all employees is valued, and in which equal opportunities for advancement and development are afforded to all. The respect and dignity of each individual employee represent a primary and immediate priority.

1.c. The Company’s corporate social policy is grounded in human rights, which define minimum working standards and serve as a complement to its corporate values.

1.d. Upholding a zero-tolerance stance toward incidents of violence and harassment in the workplace, the Company adopts the present Policy in compliance with Article 62 of the Labour Code (Presidential Decree 62/2025), which ratified International Labour Convention No. 190 of 21 June 2021 of the International Labour Organization (ILO) concerning the elimination of violence and harassment in the world of work, the text of which has been appended hereto in its entirety.

2. Purpose.

The purpose of this Policy is to maintain a high-quality work environment that respects, promotes, and safeguards human dignity and every person’s right to a world of work free from violence and harassment. The Company declares that it recognises and respects the right of every employee to a workplace free from violence and harassment, and that it tolerates no such conduct of any kind, by any person, in any form.

3. Scope of Application – Covered Persons.

This Policy applies to the persons referred to in Article 59(1) of the Labour Code (Presidential Decree 62/2025). Its scope of application and protection extends to all workers and persons engaged by the Company, irrespective of their contractual status, including those employed under contracts of dependent employment (of indefinite or fixed duration, full-time or part-time), under contracts for services, for independent services, or under paid mandate arrangements, as well as persons engaged through third-party service providers, individuals undergoing training — including trainees and apprentices —, volunteers, individuals whose employment relationship has terminated, persons seeking employment, and any other individuals who transact or cooperate with the Company.

4. Prohibited Forms of Conduct – Definitions.

4.a. All forms of violence and harassment are prohibited, whether occurring during, connected with, or arising out of work, including gender-based violence and harassment and sexual harassment.

4.b. Violence and Harassment. “Violence and harassment” means a range of unacceptable behaviours, acts, practices, or threats thereof, that aim at, result in, or are likely to result in physical, psychological, sexual, or economic harm, whether occurring as isolated incidents or on a repeated basis.

4.c. Harassment. “Harassment” means forms of conduct whose purpose or effect is to violate the dignity of a person and to create an intimidating, hostile, degrading, humiliating, or offensive environment, irrespective of whether such conduct constitutes a form of discrimination, and includes harassment on grounds of gender or on other discriminatory grounds.

4.d. Gender-Based Harassment. “Gender-based harassment” means forms of conduct related to a person’s sex or gender, whose purpose or effect is to violate the dignity of that person and to create an intimidating, hostile, degrading, humiliating, or offensive environment, within the meaning of Article 2 of Law 3896/2010 (Government Gazette A’ 107) and Article 2(2) of Law 4443/2016 (Government Gazette A’ 232). Such forms of conduct include sexual harassment as defined in Law 3896/2010, as well as conduct related to a person’s sexual orientation, gender expression, gender identity, or gender characteristics.

4.e. Discrimination. “Discrimination” means differential treatment of individuals arising from prejudice or vested interests — any act by which individuals are unjustifiably set apart on the basis of the groups, classes, or categories to which they belong or are perceived to belong. By way of illustration: discrimination on grounds of sex, age, language, nationality, race or ethnicity, disability, religious belief, or sexual orientation.

4.f. Incidents. The forms of conduct prohibited under this Policy include, by way of illustration and without limitation: offensive conduct based on discrimination on grounds of sex, race, religion, physical appearance, sexual orientation, disability, age, or other personal characteristics and choices; verbal or gestural threats; insults, whether public or private; the denigration or ridicule of a person or their abilities, whether in private or in the presence of third parties; threatened or actual physical violence; the imposition of persistent or unjustified criticism; insulting, malicious, demeaning, obscene, or derisory remarks and their dissemination; insinuations and sexist or racist “jokes” and comments; the use of offensive language; verbal sexual harassment or propositions; insinuations that a person’s sexual favours may advance their career, or that refusal to engage in sexual relations may adversely affect their professional trajectory within the Company; the offer of benefits — such as promotion or salary increases — in exchange for sexual favours, or the creation of an environment that promotes sexual contact as a means of professional advancement; retaliation or threats of retaliation following the rejection of sexual advances; cyberbullying; the sending of harassing or offensive messages via SMS, email, social media, fax, or letter; persistent or offensive questions, without legitimate reason or justification, regarding a person’s age, marital status, personal life, or sexual orientation, as well as similar questions regarding race or ethnicity, including cultural identity and religion. Prohibited conduct further encompasses visual forms of harassment, such as posters, animated content, cartoons, photographs, or illustrations that are demeaning on the basis of legally protected characteristics; unwanted physical contact, including touching, pinching, sexually suggestive gestures, hitting, grabbing, or pushing, as well as physical violence of any kind; violations of privacy; the intentional partial or total destruction of personal belongings, vehicles, or property; interference with or obstruction of a person’s normal work, freedom of movement, or physical integrity; physical exclusion or confinement; sexually suggestive gestures; physical surveillance; and stalking. The foregoing acts are illustrative and do not constitute an exhaustive list of prohibited conduct.

4.g. Permissible Conduct. The following conduct does not constitute an incident of violence and harassment: direct supervision of employees, including the setting of performance expectations; the implementation of measures to address performance, such as the placement of an employee on a performance improvement plan; the assignment of tasks and guidance as to how and when they are to be completed; requests for updates or progress reports on work tasks; the granting or duly justified refusal of leave; requests for medical documentation of absence in accordance with applicable legal provisions; the moral or financial recognition of outstanding employee performance; the provision of constructive feedback on work performance.

5. Scope of Application – Definition of the Workplace.

5.a. For the purposes of this Policy, “workplace” is understood in a broad spatial sense encompassing all locations in which incidents of violence and harassment may occur. The forms of conduct described above may take place at any of the Company’s premises throughout Greece where employees perform their services, as well as in locations where employees receive remuneration, take rest or meal breaks, in personal hygiene and care facilities, in changing rooms, or in accommodation provided by the Company to its personnel. This Policy further applies to all travel to and from work, other travel, trips, conferences, training, and work-related social events and activities connected to the Company’s operations. It also applies to all work-related communications, including those conducted via information and communication technologies (e.g. emails, video conferences via Zoom or Microsoft Teams, social media, etc.).

5.b. Domestic Violence. Domestic violence encompasses all acts of physical, sexual, psychological, or economic violence occurring within the family or household, irrespective of biological or legal family ties, or between former or current spouses or partners, regardless of whether the perpetrator shares or has previously shared a residence with the victim. Domestic violence that manifests in the workplace — for example, through physical violence, sexual harassment, or stalking by a current or former partner — constitutes a serious form of workplace violence. Acts of domestic violence, including stalking and surveillance, may also be perpetrated by individuals within the same work environment with whom the affected person has, or has previously had, a close relationship. This Policy also applies to domestic violence in any of the above forms experienced by an employee during the course of remote working.

6. Employer Obligations for the Prevention and Addressing of Violence and Harassment.

The Company, as well as those persons exercising managerial authority or acting as representatives of the employer, has adopted a Complaint Submission and Investigation Procedure, through which it: (a) receives, investigates, and manages any complaint or related report with zero tolerance for violence and harassment, in a manner that is confidential and respectful of human dignity, and does not obstruct the receipt, investigation, or management of such complaints or reports; (b) provides assistance and access to any competent public, administrative, or judicial authority in the investigation of any such incident or conduct, upon request; (c) provides employees with information regarding potential risks of violence and harassment in the workplace and the relevant prevention and protection measures, including the rights and obligations of employees and the employer in connection with such incidents; (d) posts in the workplace and makes accessible information on the procedures existing at company level for reporting and addressing such forms of conduct, as well as the contact details of the competent administrative and judicial authorities pursuant to applicable law.

7. Assessment of Risks of Violence and Harassment in the Workplace.

7.a. Risk Factor Assessment and Mitigation. The Company, in collaboration with all its departments, conducts studies concerning potential risk factors commensurate with the nature and subject matter of the work performed, including psychosocial risks, and specifically risks of violence and harassment in the workplace, with the aim of assessing existing working conditions and adjusting them so as to minimise as far as possible the likelihood of an incident of violence and harassment occurring. Risk scenarios include, by way of illustration: high workplace stress; isolated or enclosed working environments; the distribution of workstations; facility security and access control; inadequate training; individuals with a history of violent behaviour; the delivery of goods or services; solitary or isolated working; work performed late at night or in the early morning hours; and personal or domestic matters that encroach upon the workplace.

7.b. Organisation of Seminars, Publication of Informational Materials, and Regular Staff Training on Violence and Harassment. All employees must be made aware of the forms of conduct that constitute violence and harassment, which are unacceptable and censurable. The designated reference person for matters of violence and harassment shall ensure that staff receive appropriate awareness-raising on these issues and shall communicate this Policy both within and outside the Company.

8. Prevention Measures.

8.a. Information on the Rights of Affected Persons. The Company declares that, in the event a person is affected by an incident of violence and harassment in connection with access to employment, during the employment relationship, or even after the contract or employment relationship in the context of which the incident is alleged to have occurred has terminated, such person has: (a) the right to judicial protection; (b) the right to appeal, file a complaint, and request the conduct of a labour dispute before the Labour Inspectorate, within the scope of its legal competence; (c) the right to refer a matter to the Ombudsman, within the scope of its legal competence; and (d) the right to file an internal complaint with the Company in accordance with its complaints management policy. The individual procedures for the submission, management, and internal investigation of reports set out in detail the steps to be taken by any complainant, as well as the competencies of the Company’s bodies and the actions required to ensure the effective management of relevant incidents. In any case, where a report or complaint of such conduct is submitted within the Company, the affected person retains all rights to refer the matter to any competent authority. Any employee who is subjected to domestic violence with ramifications in the workplace may report this fact, orally or in writing, to their line manager, so that the Company may be informed and take all appropriate and necessary measures.

8.b. Information, Awareness-Raising, and Staff Support Activities. By means of the present Policy, the Company informs its personnel and maintains, in a prominent location, the contact details of the competent administrative authorities to which any affected person may have recourse (the Labour Inspectorate; the Ombudsman), and in particular provides information on the SEPE (Labour Inspectorate) complaint hotline (15512), the citizen service line 1555 and the online platform https://1555.gov.gr/, as well as the immediate psychological support and counselling service for women victims of gender-based violence, accessible via the SOS 15900 Helpline (operated by the General Secretariat for Demographic and Family Policy and Gender Equality – G.G.I.F.). Within the bounds of its capabilities, the Company takes all appropriate measures and makes all reasonable adjustments to working conditions in order to protect the employment and support employees who are victims of domestic violence. It also takes all necessary measures to inform and raise awareness among its personnel, employing the appropriate means described above to combat violence and harassment, ensuring that all persons are aware of the Company’s policy and procedures with respect to incidents of violence and harassment, know to whom they may turn in the event of violence or harassment, and are informed of the rights available to them under the law. The Company trains its personnel by all appropriate means to enable them to recognise discrimination, violence, and harassment in the workplace and to provide the required support to employees and associates. It further encourages the participation of employee representatives and management personnel in training programmes and seminars related to the identification and management of potential risks of violence and harassment, and may organise seminars delivered by mental health specialists or counselling service providers. 

9. Internal Complaint Submission and Management Procedure – Reference Person.

9.a. Any employee who has been subjected to any incident of violence and harassment may submit an oral or written complaint to the General Manager, who is designated as the “reference person” for the purposes of this Policy. Complaints may be submitted in person or by electronic mail to info@eviviosmed.gr. Complaints may not be submitted anonymously.

9.b. The complaint must include the particulars of the respondent — i.e. the person alleged to have engaged in prohibited conduct — as well as the specific incident or incidents on which the complaint is founded.

9.c. The reference person shall conduct a thorough investigation of each complaint and shall collect all information necessary in connection therewith. Complaints and investigations shall remain strictly confidential to the greatest extent possible, having regard to the sensitivity of the matter and the privacy of all parties involved.

9.d. In particular, the reference person may conduct interviews with the complainant and the respondent, examine witnesses, request the production of any documents that may exist and from which it may be established whether or not an incident of violence and harassment occurred, and liaise with the heads of the relevant departments in the event that the complainant has previously approached them.

9.e. Upon completion of the investigation, the reference person shall submit a written report to the Company’s Management setting out the findings of the investigation. The findings shall be communicated simultaneously to both the complainant and the respondent for their information. The completion of the investigation and the submission and notification of the reference person’s report must take place as expeditiously as possible, and in any event no later than three (3) weeks from the date on which the complaint was submitted by the complainant.

9.f. Should an incident of discriminatory treatment, violence, harassment, or retaliation be substantiated, the Company’s Management shall take, on a case-by-case basis, all necessary, appropriate, and proportionate measures against the respondent. Such measures may include, by way of illustration: (a) a compliance recommendation; (b) a change of position, working hours, place, or manner of work; (c) termination of the employment or cooperation contract with the Company, subject to the prohibition on abuse of rights under Article 281 of the Greek Civil Code. In any event, the perpetrator may also be subject to criminal or civil liability in accordance with applicable law.

9.g. Complaints that are demonstrably malicious in nature shall be deemed inadmissible and shall be subject to further investigation at the Company’s discretion, both as to the motives involved and the parties concerned, with a view to restoring order by all lawful means and measures.

10. Rights of Affected Persons.

10.a. In accordance with applicable law, any person subjected to an incident of violence and harassment has the right to leave the workplace for a reasonable period of time, without loss of pay or any other adverse consequence, where, on the basis of their reasonable belief, there exists an imminent serious risk to their life, health, or safety — in particular where the employer is the perpetrator of such conduct, where the employer fails to take the necessary and appropriate measures to restore workplace peace, or where such measures are insufficient to bring the conduct of violence and harassment to an end. In such cases, the person departing the workplace is required to first notify the reference person in writing, specifying the incident of violence and harassment and the circumstances justifying their belief that an imminent serious risk to their life, health, or safety exists. Where such risk no longer exists or has ceased to exist and the affected person nonetheless refuses to return to the workplace, the employer may apply to the Labour Inspectorate for resolution of the dispute.

10.b. Employees who are subjected to incidents of violence and harassment in the workplace have the right to have recourse to the competent authorities as provided by law — namely: (a) the right to judicial protection; (b) the right to appeal, file a complaint, and request the conduct of a labour dispute before the Labour Inspectorate, within the scope of its legal competence; and (c) the right to refer a matter to the Ombudsman, within the scope of its legal competence.

11. Obligation of Impartiality and Confidentiality.

The reference person is required to conduct the complaint investigation process in an objective and impartial manner. Furthermore, they are obliged to treat all parties involved with respect, and to act in a confidential and discreet manner. The disclosure or communication of information relating to any complaint under investigation to parties not involved therein is strictly prohibited. Applicable legislation on the protection of privacy and personal data shall be observed without exception. The foregoing obligations are equally binding upon the Company’s Management at the final stage of decision-making and the implementation of measures.

12. Prohibition of Retaliation – Non-Victimisation of Complainants.

Retaliation against and victimisation of a complainant who, as an affected person, has exercised their rights and submitted a written complaint regarding an incident of violence and harassment are strictly prohibited. Retaliation against and victimisation of a complainant constitute a serious violation of this Policy and shall give rise to consequences for the person engaging in such conduct. Any employee or third party connected in any capacity to the Company who considers that they have been subjected to retaliatory conduct as a result of having submitted a complaint or having assisted in the investigation of an incident of discrimination, violence, and/or harassment, is required to follow the above procedure for reporting such an act of retaliation.

13. Cooperation with Administrative and Judicial Authorities.

The Company, as well as any person or service competent for the receipt and management of such complaints at corporate level, shall cooperate with any competent public, administrative, or judicial authority which, either on its own initiative or upon the request of an affected person and within the scope of its competence, requests the provision of data or information, and undertakes to provide assistance and access to such data. To this end, all data collected, in any form, shall be maintained in a relevant file in compliance with the provisions of Law 4624/2019 (Government Gazette A’ 137) on the “Hellenic Data Protection Authority, measures implementing Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data.”

14. Derogations.

No derogations from the application of this Policy are permitted.

15. Contact Person.

For further information regarding this Policy, any interested person may contact the General Manager.