Regulation against violence and harassment at work

Company Information
TECHNOPOLIS EDUCATIONAL LLLC S.A.
TECHNOPOLIS EDUCATIONAL LIFELONG LEARNING CENTER
SOLE SHAREHOLDER COMPANY
Headquarters: 31 Giannitson St., Thessaloniki
Branch: N. Plastira – M. Botsari, Komotini
Branch: 103 Dimokratias St., Ptolemaida
Branch: 4 Iroon Polytechniou St., Skydra
Legal Representative: Athanasios Papathanasiou

Introduction – Purpose

  1. TECHNOPOLIS EDUCATIONAL LIFELONG LEARNING CENTER SOLE SHAREHOLDER COMPANY (hereinafter referred to as “the Company”) takes all necessary measures and fulfills its obligations concerning the implementation of the provisions of Part II of Law 4808/2021 for the prevention and management of all forms of violence and harassment, including gender-based violence and sexual harassment. Respect for human dignity at all levels is a core component of the Company’s Policy for the Prevention and Combat of Workplace Violence, Bullying, and Harassment (hereinafter referred to as “this Policy”).
  2. The purpose of this Policy is to create and establish a working environment that respects, promotes, and ensures human dignity and the right of every individual to a workplace free of violence and harassment. The Company is committed to providing a safe and healthy working environment wherever its business activities take place. The Company enforces a zero-tolerance policy for any form of violence, bullying, or harassment occurring during work, related to work, or arising from it, including violence and harassment based on gender, race, ethnicity, religion, age, disability, political beliefs, financial status, sexual orientation, and gender identity, as well as sexual harassment.
  3. This Policy is adopted in compliance with Articles 9 and 10 of Law 4808/2021 and its implementing regulations. The purpose of this Policy is to establish a framework for preventing, addressing, and combating workplace violence and harassment, as well as managing internal complaints about incidents of violence and harassment in the workplace, fully aligned with the relevant provisions of Part II of Law 4808/2021.

Part A: Policy for the Prevention and Combat of Workplace Violence, Bullying, and Harassment

A.1 Scope – Persons
This Policy applies to:
(a) Members of the Board of Directors, the CEO, and any other person in a management position within the Company.
(b) Employees of the Company employed under a dependent employment relationship (part-time or full-time, fixed-term, or indefinite).
(c) Persons employed by the Company under a contract for services, independent services, or salaried mandate.
(d) Persons employed through third-party service providers.
(e) Interns, apprentices, and volunteers.
(f) Trainers providing training or other educational services, regardless of their contractual relationship with the Company.
(g) Individuals attending training programs or other educational activities (“trainees”).
(h) Individuals seeking employment at the Company.

A.2 Scope – Location
For the purposes of this Policy, behaviors that constitute violence, bullying, or harassment by or against the individuals mentioned in Article A.1 may occur:

(a) In the workplace, including public and private spaces, areas where employees work, receive payment, rest during breaks, as well as hygiene and care facilities, locker rooms, cafeterias, or accommodations provided by the Company.
(b) During commutes to and from work, other work-related travel, training sessions, and events or social activities associated with work.
(c) During work-related communications, including those conducted through information and communication technologies.
(d) During educational activities carried out on the Company’s premises or remotely through synchronous or asynchronous e-learning using information and communication technologies.

A.3 Definitions – Forms of Workplace Violence, Bullying, and Harassment

  1. For the purposes of this Policy, the following definitions apply:

(a) “Violence”: Behaviors, actions, practices, or threats thereof that aim to, result in, or may result in physical, psychological, sexual, or economic harm, whether occurring individually or repeatedly.
(b) “Bullying”: The deliberate and systematic provocation of distress or fear based on specific reasons, often targeting perceived “weaknesses,” and undermining the individual’s sense of security and dignity. It is rooted in power imbalances and frequently creates a hostile, degrading, or offensive environment.
(c) “Harassment”: Behaviors intended or resulting in the violation of an individual’s dignity, creating an intimidating, hostile, degrading, humiliating, or offensive environment, whether or not they constitute discrimination. This includes harassment based on gender or other discriminatory grounds.
(d) “Sexual Harassment”: Any verbal or physical behavior of a sexual nature or with sexual connotations that undermines an individual’s dignity. This includes both direct actions and indirect actions conducted through communication or information technologies.
(e) “Discrimination”: Any direct or indirect action or observation, whether face-to-face or via information and communication technologies, that results in unequal treatment or disadvantages individuals based on characteristics such as gender, race, ethnicity, religion, disability, age, sexual orientation, or gender identity.
(f) “Unwanted Behavior”: Any behavior deemed unpleasant or offensive by an individual. The intent of the person exhibiting such behavior, or whether it was previously accepted as a workplace norm, does not negate its classification as unwanted.

  1. All forms of violence, bullying, or harassment, including unacceptable or inappropriate behaviors or threats thereof, are strictly prohibited, even if they do not precisely fall within the above definitions. Examples include verbal, physical, psychological, moral, or sexual violence, demeaning or insulting conduct, the use of offensive language, threats, bullying, and creating a “hostile environment.”
  2. Specifically, prohibited sexual harassment behaviors that may be perceived as unpleasant, offensive, intimidating, or humiliating include:

(a) Verbal Behavior: Unnecessary familiarity, sexual comments, jokes, gestures, derogatory language with a gendered character, inappropriate remarks about gender or sexual orientation, discussions about sexual topics, and unsolicited suggestions or inquiries about one’s personal or sexual life.
(b) Non-Verbal Behavior: Persistent leering, unwanted touching of clothing or body parts, pinching, fondling, close physical proximity, or suggestive gestures.
(c) Intrusion into Personal Life: Attempts to distribute sexual material (images, videos, etc.), non-consensual photography, or misuse of e-learning technologies for inappropriate purposes.
(d) Other Forms of Behavior: Written romantic or sexual correspondence, inappropriate phone calls, text messages, or emails, and public display of sexually explicit content.
(e) Sexual Harassment as Quid Pro Quo: Coercion into sexual relations in exchange for employment benefits, promotions, or grades, or threats of dismissal or disadvantage if such demands are refused.

  1. Behaviors within the scope of managerial or supervisory authority, consistent with the Company’s institutional and regulatory framework (e.g., performance evaluations, feedback), do not constitute violence or harassment. Similarly, educational and evaluative roles performed by trainers or feedback provided by trainees in good faith are not classified as violence or harassment.

A.4 Assessment of Potential Risks of Workplace Violence, Bullying, and Harassment
The Company’s ongoing goal is to eliminate workplace violence and harassment while effectively addressing even the slightest suspicion of such incidents. Recognizing the potential for these behaviors, the Company considers the large number of individuals participating in its training and other activities, the frequent introduction of new participants, and changing work conditions (e.g., remote work or education).

The Company commits to regular engagement with psychologists, physicians, and legal experts to update this Policy based on risk assessments, considering new or evolving risks and workplace dynamics.

A.5 Prevention and Protection Measures – Awareness Actions
The Company has implemented measures and practices to prevent, monitor, limit, and address risks of workplace violence and harassment, as well as to manage incidents or forms of inappropriate behavior. These include:

  1. Publication of this Policy on the Company’s intranet and official website. The purpose of this publication is:
    (a) To foster a workplace culture based on respect for human dignity, collaboration, and mutual support.
    (b) To facilitate open communication with management and relevant parties to resolve and promptly address inappropriate behaviors and to mediate conflicts or misunderstandings.
  2. Training and education of personnel. Training all employees is a key means of preventing and addressing workplace violence, bullying, and harassment. Training and awareness activities will be conducted regularly and cover topics such as:
    • Forms of violence and harassment and the factors that promote them in the workplace.
    • Responsibilities related to any reported or observed problems.
    • Methods for handling incidents with confidentiality, discretion, and seriousness, while respecting the rights of the accused and the presumption of innocence.
  3. Providing information on official psychological support services in Greece. Immediate assistance mechanisms include:
    (a) SOS Helpline 15900: A national service offering immediate support to women victims of violence or third parties. Staffed by psychologists and sociologists, the service operates 24/7 and includes an email contact: sos15900@isotita.gr.
    (b) Helpline 197 – National Center for Social Solidarity: Available to individuals of all genders and ages, providing anonymous help and information on psychosocial support services. Operates 24/7.
  4. Informal handling of incidents of workplace violence, bullying, or harassment.
    (a) Any employee, trainer, or trainee who feels subjected to violence or harassment and wishes to address the matter informally can follow the internal/informal procedure:
    • Directly approach, verbally or in writing, the person responsible for the behavior, requesting its cessation and prevention of recurrence.
    • Alternatively, they may informally report the incident to their supervisor or the Company’s Chairperson and CEO, expressing their concern.
    • The person receiving the report (reference person) documents the incident and explores options for communication or mediation. If necessary, the reference person, with the complainant’s written consent, encourages direct communication or undertakes mediation to resolve the issue.
    (b) The reference person ensures confidentiality and resolves the issue within a reasonable timeframe.(c) Informal handling does not preclude the complainant from filing a formal complaint as outlined in Section B.

A.6 Rights of Affected Individuals
Any individual who has experienced violence, bullying, or harassment in the workplace has the right to:
(a) File a complaint or report internally as per Section B of this Policy.
(b) Report the incident to the Labor Inspectorate through the following channels:

  • Website: https://www.sepe.gov.gr/epikoinonia/diadrastikos-chartis
  • Labor Inspectorate Hotline: 15512
    (c) Contact the SOS Helpline 15900 for immediate psychological support and counseling for victims of gender-based violence.
    (d) Submit a report to the Ombudsman:
  • Address: 17 Halkokondyli St., 10432, Athens
  • Email: press@synigoros.gr
  • Phone: (+30) 213 1306 600
    (e) Request measures against the accused or seek protective measures, such as relocation, schedule changes, or remote work, provided these are feasible and do not disrupt the Company’s operations.
    (f) Temporarily leave the workplace without loss of pay or adverse consequences if there is a reasonable belief of imminent danger to life, health, or safety. A written report explaining the incident and the justification for the departure must be submitted.
    (g) Seek legal protection through the courts for compensation or moral damages.
    (h) Request assistance from legal entities or associations under Article 22(2) of Law 3896/2010.

A.7 Burden of Proof
When a victim claims to have experienced violence or harassment, the burden of proof lies with the accused to demonstrate in court or before relevant authorities that no such actions occurred, as stipulated in Article 15 of Law 4808/2021 and Article 24(1) of Law 3896/2010.

A.8 Obligation to Uphold the Policy
No employee, including those in managerial roles, trainers, or trainees, may obstruct others from exercising their rights or fulfilling their obligations under this Policy.

A.9 Reference Person
For any information or clarification regarding this Policy or issues related to preventing and addressing workplace violence and harassment, interested parties may contact the Company’s Vice Chairperson, Ms. Despina Archontidou.

A.10 Support for Victims of Domestic Violence
The Company will support any employee, regardless of their employment relationship, who is a victim of domestic violence. Support may include:
(a) Flexible work arrangements for a specified period, subject to periodic review.
(b) Safety planning at the workplace, such as secure parking and placement in non-isolated areas.
(c) Any other appropriate measures within the Company’s capabilities to provide psychological and social support to the victim.

Part B – Procedure for Handling Internal Complaints about Incidents of Workplace Violence, Bullying, and Harassment

B.1 Submission of Internal Complaint/Report

  1. Any individual who has experienced violence, bullying, or harassment at work in violation of this Policy has the right to submit a written complaint or report about the incident. The same right applies to anyone who witnesses such incidents, even if they are not personally affected. Complaints or reports can be submitted via the following communication channels:
    (a) Sending an email to: archontidou@technopolis-ekp.gr
    (b) Sending a letter to the following postal address: 31 Giannitson St., 54627, Thessaloniki, Attn: Ms. Despina Archontidou.
    (c) Using the telephone line: +30 2314173196
  2. All complaints or reports are handled with absolute confidentiality.
  3. Complaints or reports may be submitted anonymously or under a real name. The anonymity of the individual filing the complaint or report is always protected. However, submitting a complaint or report under a real name is encouraged, as it facilitates the identification and resolution of the issue.

B.2 Temporary Measures in Favor of the Complainant

  1. The reference person, in collaboration with the complainant, may implement immediate and appropriate temporary measures to protect the complainant until the full investigation and resolution of the complaint are completed. These measures may include:
    (a) Changing work shifts, if possible.
    (b) Transferring the complainant to another department within the Company.
    (c) Allowing the complainant to work remotely, considering their duties and the Company’s operational requirements.
    (d) Granting paid leave to the complainant.
  2. The above measures, or others that provide equivalent protective outcomes, may be implemented individually or in combination.

B.3 Investigation of Complaint/Report

  1. The reference person, in collaboration with the members of the Complaint Management Committee, promptly investigates and examines complaints/reports with impartiality, ensuring confidentiality and the protection of personal data for both the complainant and the accused.
  2. During the investigation, full anonymity may not always be feasible, for example, during interviews with the complainant, the accused, or witnesses. Nevertheless, all legal requirements for personal data protection and confidentiality will be strictly observed.
  3. The reference person, in collaboration with the Company’s Board of Directors, has access to all Company records, audiovisual materials, and other relevant means to collect information and evidence related to the complaint.
  4. The investigation process includes:
    (a) Receiving the incident report through the designated communication channels.
    (b) Collecting and processing all submitted complaints or reports.
    (c) Gathering relevant information and conducting a thorough review of the incident.
    (d) Interviewing all involved parties and any witnesses.
    (e) Evaluating all information, preparing a report, and submitting recommendations to the Committee.

B.4 Decision-Making Procedure for Disciplinary Measures

  1. The decision to impose disciplinary measures on the accused is made by the Complaint Management Committee (hereinafter referred to as “the Committee”), whose members are:
    (a) Chairperson: Ms. Despina Archontidou
    (b) Member: Ms. Maria Damianou
    (c) Member: Ms. Kyriaki Amanatidou
  2. The Committee convenes validly when all members are present, and decisions are made by an absolute majority. If a complaint/report is deemed clearly unfounded, the Committee decides to archive it.

B.5 Sanctions/Measures Against the Accused

  1. If the allegations in the complaint/report are partially or fully substantiated, the Committee takes the necessary and appropriate measures against the accused to prevent the recurrence of similar incidents or behaviors.
  2. Such measures may include:
    (a) A formal warning or instruction for compliance.
    (b) Reassignment to another role, schedule, location, or method of work.
    (c) Termination of the employment or collaboration agreement, subject to the prohibition of abusive exercise of rights under Article 281 of the Greek Civil Code.
  3. Additional appropriate measures may be imposed at the Committee’s discretion, including dismissal as a last resort.

B.6 Prohibition of Retaliation Against the Complainant

  1. The Company strictly prohibits any form of retaliation against the complainant for reporting incidents of violence, bullying, or harassment. Specifically, no adverse treatment of the complainant is permitted if it constitutes revenge or countermeasures under Article 14 of Law 3896/2010. Dismissals or terminations of the legal relationship on which employment is based are null and void.
  2. However, this prohibition does not protect individuals who knowingly submit false or malicious complaints. In such cases, following verification by the Committee, the Company may impose sanctions, including the termination of the employment or collaboration agreement.

B.7 Cooperation with Competent Authorities
The Company is committed to cooperating with competent authorities during the investigation and resolution of complaints. All relevant records and evidence are maintained in compliance with the GDPR and Law 4624/2019.

B.8 Third-Party Reports

  1. The Company encourages third parties (non-employees) to report any violations of policies, procedures, or laws related to violence and harassment. Reports may be submitted via:
    (a) Email to: archontidou@technopolis-ekp.gr
    (b) Letter to: 31 Giannitson St., 54627, Thessaloniki, Attn: Ms. Despina Archontidou.
  2. Upon submission, the procedure outlined in Articles B.1 through B.5 will be followed.

B.9 Evaluation and Optimization of the Policy

  1. The Company is committed to regularly evaluating this Policy to ensure compliance with applicable laws and regulations.
  2. The Policy will be disseminated through internal communication channels to all employees and appropriately communicated to trainers and trainees participating in the Company’s activities.