The Company adheres to all measures and obligations regarding the application of the provisions of Part II of Law 4808/2021 for the prevention and combating of all forms of violence and harassment, including gender-based violence and harassment and sexual harassment.
The purpose of this policy is to create and consolidate a work environment that respects, promotes, and ensures human dignity and the right of every individual to a world of work free from violence and harassment. The Company declares that it recognizes and respects the right of every employee to a work environment free from violence and harassment and that it does not tolerate any such behavior, in any form, from any person.
This policy is adopted in accordance with Articles 9 and 10 of Law 4808/2021 and the regulatory legislation implementing them, and covers the persons of paragraph one of Article 3 of Law 4808/2021.

Article 1. Scope of Application

This policy applies to: a) The Management and shareholders of the Company, b) The employees of the business, regardless of their contractual employment status (fixed-term – indefinite term, part-time – full-time), c) Those employed in the business under a project contract, independent services agreement, and salaried mandate, d) Those employed through third-party service providers, e) Trainees and apprentices, f) Volunteers, g) Employees whose employment relationship with the business has ended, h) Job applicants, i) Other individuals transacting or cooperating with the Company.

Article 2. Definitions

2.1 “Violence and Harassment” refers to forms of conduct, 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 a single incident or repeatedly.

2.2 “Harassment” refers to forms of conduct that have the purpose or effect of violating the dignity of a person and of creating an intimidating, hostile, degrading, humiliating, or offensive environment, regardless of whether they constitute a form of discrimination, and includes gender-based harassment or harassment based on other grounds of discrimination.

2.3 “Gender-based Harassment” refers to forms of conduct linked to the gender of a person, which have the purpose or effect of violating the dignity of that person and of creating an intimidating, hostile, degrading, humiliating, or offensive environment. These forms of conduct include sexual harassment, as well as conduct linked to sexual orientation, expression, identity, or sex characteristics of the person.

2.4 Forms of violence and harassment conduct may occur, in particular: a) in the workplace, including public and private spaces and spaces where the employee provides work, receives payment, takes a break notably for rest or meals, in sanitary, washing and changing facilities or accommodation provided by the employer, b) during commuting to and from work, other movements, trips, training, as well as events and social activities related to work, and c) during work-related communications, including those enabled by information and communication technologies.

Article 3. Prevention and Combating

a) Assessment of Violence and Harassment Risks at Work. For the purpose of combating violence and harassment, the Company conducts an occupational risk assessment, which includes psychosocial risks, pursuant to Article 43 par. 1a of Law 3850/2010. Furthermore, the Company may conduct anonymous confidential surveys via questionnaires regarding the work climate and the assessment of violence and harassment risks at work.
b) Measures for the prevention, control, limitation, and addressing of violence and harassment risks at work.

  1. This Policy is communicated to employees and all persons falling within its scope, and the Company takes necessary measures in cases of non-compliance.
  2. Our Company’s human resources are the driving force of the business. In the Company, employment relations are governed by a spirit of teamwork and solidarity based on mutual trust, sincerity, and respect. In this context, staff conduct must be characterized by ethos, transparency, responsibility, and integrity, while any form of violent, intimidating, or offensive behavior is impermissible and intolerable, regardless of position or rank in the Company hierarchy.
  3. The Company supports respect for diversity and the avoidance of discrimination. National origin, social background, political, ideological or religious beliefs, gender, family, age, sexual preferences, and physical abilities do not constitute criteria for discrimination but offer opportunities for new ideas.
  4. The Company ensures a work environment that is accessible, safe, and friendly, where relations between employees, partners, Management, and shareholders are characterized by mutual respect, respect for human dignity, mutual assistance, courtesy, sincerity, understanding, trust, cooperation, and support.
  5. The Company ensures that employees receive the necessary training and information for the performance of their duties, particularly in jobs with higher risk for the manifestation of violence and harassment incidents.
  6. The Company takes technical measures, such as installing emergency alerts, improving lighting, etc., according to the occupational risk assessment conducted.
  7. The Company trains its staff, and particularly the executives and department heads, to recognize violence and harassment at work and to provide the required support to the rest of the staff and partners.
  8. The Company guides and supports victims of violence and harassment or victims of domestic violence regarding their reintegration into the workplace.
  9. The Company is committed to receiving, investigating, and managing every complaint or relevant report, demonstrating zero tolerance for violence and harassment, with confidentiality and respect for human dignity. It also commits not to obstruct the receipt, investigation, and management of such complaints or reports.
  10. The Company commits to providing assistance and access, during the investigation of every incident of violence and harassment, to any competent public, administrative, or judicial authority requesting data or information. To this end, any data collected, in any form, is maintained in a relevant file in compliance with the provisions of Law 4624/2019.
  11. The Company evaluates the effectiveness of the applied preventive and remedial measures on a regular basis and revises/updates the risk assessment and measures.

c) Information and awareness-raising actions for staff.

  1. The Company expresses its commitment to addressing and eliminating violence and harassment in the workplace aimed at creating a work environment where respect for human dignity prevails. To this end, it is expressly and categorically stated that all forms of violence and harassment occurring during work, whether linked to it or arising from it, including gender-based violence and harassment as well as sexual harassment, are strictly prohibited.

Indicatively and not exhaustively, the Company declares that the following are strictly prohibited:

  • Innuendos, mockery, obscene, sexual, or racist jokes or comments.
  • Use of offensive language when describing persons with disabilities.
  • Comments on someone’s physical appearance or character that cause shame or embarrassment.
  • Stalking, pursuit, and unwanted verbal or physical attention towards a person.
  • Sending messages with sexually explicit content via SMS, email, social media, fax, or letter.
  • Offensive and persistent questions about someone’s age, marital status, personal life, sexual interests or preferences, as well as similar questions about their race or nationality, including their cultural identity and religion.
  • Sexual gestures or persistent proposals for dates or threats.
  • Innuendos that someone’s sexual favors can advance their career or that refusal to establish a sexual relationship may negatively affect their professional course in the company.
  • Rude gestures, touching, and any kind of unwanted physical contact.
  • Spreading malicious comments or insulting someone mainly due to discrimination regarding age, gender, type of marriage, civil partnership, pregnancy and maternity, any disability, sexual preferences, religion, or beliefs.
  • Threats, verbal or with gestures, insults publicly or privately.
  • Belittling or ridiculing a person or their abilities, either privately or before third parties.
  • Outbursts of anger against someone.
  • Exercise of persistent or unjustified criticism.
  • Exclusion from social events, workgroup meetings, discussions, and collective decisions or planning.
  • Cyberbullying.
  • Offensive emails, letters, and phone calls.

2. The Company informs employees about the risks of violence and harassment, including sexual harassment, as well as ways to prevent it.

d) Information on the rights and obligations of employees and the employer.

  1. The Company informs its employees that in case a person is affected by an incident of violence and harassment, beyond the right to recourse to the internal complaint procedure, they maintain at any time: a) The right to judicial protection. b) The right to recourse, submission of a complaint, and application for a labor dispute to the Labour Inspectorate. c) The right to report to the Greek Ombudsman.
  2. The Company has posted in a conspicuous place the details of the competent administrative authorities (Labour Inspectorate, Ombudsman) and informs about the SEPE complaint telephone line via the citizens’ service line 1555, as well as the immediate psychological support and counseling service for women victims of gender-based violence via the SOS Line 15900.
  3. In case of violation of obligations arising from this Policy, the Company is obliged to take necessary appropriate and proportionate measures against the respondent to prevent the recurrence of a similar incident. These measures may include compliance recommendation, change of position, schedule, place or mode of work, or termination of the employment contract.
  4. Any person suffering an incident of violence and harassment has the right to leave the workplace for a reasonable time, without loss of salary or other adverse consequence, provided that in their reasonable belief there is an imminent serious danger to their life, health, or safety.
  5. The Company encourages its employees to report incidents of violence and harassment in accordance with the internal reporting procedure provided herein.
  6. Any person reporting an incident is protected from any kind of retaliation and unequal or adverse treatment, provided the report was made in good faith.

e) Designation of a reference person (“Liaison”). The Company designates Ms. Maria Marinea (Tel: 210 8258996, email: mmarinea@am-architects.com) as the competent person for informing and guiding staff on issues regarding the prevention and addressing of violence and harassment.

f) Employment protection and support for employee victims of domestic violence. The Company protects employment and supports employee victims of domestic violence in maintaining their job and smooth reintegration, particularly where there are minor children or children with disabilities, providing the possibility for special leave or flexible working arrangements upon request.

Article 4. Complaint Receipt and Examination Procedure

  1. The Company establishes clear procedures for submitting complaints and reports related to these phenomena ensuring immediate and effective resolution.
  2. The internal resolution procedure can be either informal or formal.
  3. The procedure aims exclusively to inform all persons of the ways such incidents are reported.
  4. Any violation hereof will result in fair disciplinary measures.
  5. For every complaint, all necessary measures will be taken to maintain the confidentiality of the reporting person’s identity and Personal Data.
  6. Exceptionally, the identity of the complainant may be disclosed when: a) the complainant consents in writing, b) disclosure is required by law, c) the complaint clearly involves malice, d) disclosure is necessary for safety reasons.
  7. The complainant is protected from any retaliation or adverse treatment (dismissal, suspension, change of duties, etc.) pursuant to Article 13 of Law 4808/2021.
  8. Complaints must be made in good faith. False or malicious accusations may be subject to disciplinary or penal sanctions.
  9. Complaints should be based on reasonable suspicion; full proof by the complainant is not expected as this is the subject of the investigation.
  10. The affected person retains the right to judicial protection and recourse to administrative authorities regardless of the internal procedure.
  11. The Company commits to cooperating with competent authorities during investigations.
  12. In case of violation, the Company takes appropriate measures (compliance recommendation, transfer, or dismissal).

1. Internal Informal Complaint Procedure:

1.1 The complainant may address the “Complaint Policy Officer,” Ms. Maria Marinea (contact details as above), orally or in writing. This does not substitute the formal procedure. 1.2 The Officer records the history and investigates the possibility of mediation. 1.3 The complainant declares in writing their desire for direct communication with the alleged perpetrator or mediation. 1.4-1.6 The Officer may request more info, proceeds to mediation only upon written request, maintains confidentiality, and informs the complainant of the outcome. 1.7 The complainant is protected from retaliation provided the complaint was made in good faith.

2. Formal Complaint Submission and Examination Procedure.

2.1 To initiate the formal procedure, the complainant must submit a written complaint to the Board of Directors via email at reportharassment@am-architects.com. 2.2 The Board of Directors must investigate every complaint within ten (10) working days from receipt, with impartiality and confidentiality. 2.3 If violence and harassment conduct is established, the Board of Directors may decide to terminate the employment contract of the perpetrator, subject to the prohibition of abuse of right (Art. 281 of the Civil Code).