POLICY AGAINST VIOLENCE AND HARASSMENT IN THE WORKPLACE

European Dynamics Group of Companies ( “the Company”) complies with all measures and obligations related to the prevention and combating of all forms of violence and harassment, including violence based on gender and sexual harassment.

1. PURPOSE

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 person to work without violence and harassment. The Company recognizes and respects the right of every employee to a healthy working environment without violence and harassment and prohibits any such behavior during or associated with working at the Company, including violence and harassment due to gender and sexual harassment. The Company firmly applies zero tolerance to such behaviors of any kind by any person associated with the Company.

2. SCOPE

This policy includes the members of the Board of Directors, employees and associates, regardless of their contractual or employment status, including those who have an active employment contract, a work contract, a contract for the provision of independent services, those who have been assigned with a paid mandate, those who are employed on a temporary basis, those who are employed through third party service providers, trainees and apprentices, employees whose employment with the Company has ceased, volunteers, candidates for recruitment and other people working in the informal economy.

This policy applies to behavior which constitutes violence and harassment against individuals, in particular:

• In the workplace, including public and private spaces and areas where the employee works, takes a break or rests, in areas of personal hygiene and care.
• During travel to and from work, business travel, training, work-related events and social activities.
• During communications related to working at the Company, including those carried out via corporate e-mails, telephone and video-conference.

3. PROHIBITED FORMS OF BEHAVIOR – RISK ASSESSMENT

Violence and harassment shall be construed as unacceptable behaviors, practices and threats, whether manifested once or repeatedly, which may to lead to, or result in, physical, psychological, sexual or financial harm. Indicatively and not exclusively, the Company considers that violence and harassment includes:

• Verbal abuse, such as misnomers, derogatory or disparaging remarks or comments, jokes or insults, undesirable sexual approaches, verbal bullying,
• Visual harassment, such as gestures, derogatory or disparaging posters, cartoons, drawings, emails, text messages, electronic images, sending obscene or inappropriate letters, emails or notes;
• Physical harassment, such as caressing, pinching, touching, standing in the way and other similar actions at work,
• Threats to cause professional damage if sexual approach is repulsed, promise of benefit in exchange for sexual gratification (sexual harassment),
• Continued expression of sexual interest or inappropriate approach when such interest or approach was rejected,
• Violence and harassment directed at individuals because of their gender or sexual orientation or identity or gender characteristics or other form of discrimination.

The Company assesses the risks of violence and harassment at work, especially taking into account factors such as the proportion of employee population, gender, age, but also special categories of employees, such as newly hired employees.

4. MEASURES FOR THE PREVENTION, CONTROL, RESTRICTION AND TREATMENT OF THESE RISKS

The Company takes all appropriate and necessary measures in order to prevent, deal with and manage forms of violent behavior and harassment, contributing to the creation of a work environment that respects the dignity of the employee. More specifically, the Company:

• Encourages employees to maintain and pursue a work environment where respect for human dignity, cooperation and mutual assistance are fundamental values.
• Encourages direct supervisors and directors to monitor their employees’ work environment and to be in open communication and in honest dialogue with them.
• Ensures that employees have the necessary training, especially when they are going to perform their duties in jobs that are more at risk of violence and harassment, and that they receive the necessary training in the management of such incidents.
• Takes technical measures regarding surveillance in areas where there is a greater risk of violence and harassment, such as the improvement of lighting and cameras, in accordance with the regulatory provisions, to enhance the sense of safety of employees.
• Takes care of the protection of employment and the support of victims of domestic violence, by any appropriate means or reasonable adjustment
• Organizes and participates in actions / workshops / production of material to inform and raise awareness of employees about their rights and obligations and the direct supervisors and directors of the Company’s departments in cases of violence and harassment, regarding the procedures for reporting such behaviors at company level and about the possibilities provided by law in these cases
• Evaluates on a regular basis the effectiveness of the implemented preventive measures and measures to deal with incidents of violence and harassment and reviews and redefines the risks and measures.

5. RIGHTS AND OBLIGATIONS OF EMPLOYEES – DIRECTORS / HEADS OF DEPARTMENTS

Every employee has the right to:

• be treated with respect and kindness
• not be subject to acts of violence and harassment, including sexual harassment, discrimination and intimidation, and be informed and guided for such issues by the Reference Person (as defined below)
• consult the occupational physician
• report any incident of prohibited violence and harassment in the workplace as described below, without being subject to victimization or suffering any other adverse consequences or retaliation
• seek protection by the provisions of par. 3 of no. 12 of Law 4808/2021
• seek judicial protection and the right to appeal before any competent authority, according to the provision of par. 1 of no. 12 of Law 4808/2021.

Every employee is obliged to:

• comply with this policy and all applicable measures in force for the purpose of personal protection and protection of other employees
• report immediately any incident of violence and harassment to his or her supervisor or Reference Person (as defined below)
• cooperate in case of investigation of a complaint, which has been reported in accordance with the procedure described in point 6.
• participate in actions and training programs of the Company on prevention of violence and harassment.

The Directors and heads of Company’s departments are obliged to:

• comply with the present policy and all applicable measures in force and ensure their implementation in their area of responsibility
• refrain from engaging themselves in the manifestation of unwanted and prohibited acts of violence and harassment during the exercise of their duties
• address and investigate any complaints or incidents of violence and harassment that they become aware of and work with the Reference Person
• act promptly when they become aware of the occurrence of acts of violence and harassment, cooperate with public, judicial or administrative authorities, and not obstruct the investigation and management of complaints;

6. APPOINTMENT OF REFERENCE PERSON (“Liaison”)

The Human Resources Manager of the Company (a person appointed as such each time) is appointed as Reference Person (“Liaison”), responsible for guiding and informing the employees of the Company regarding the prevention and combat of violence and harassment in the workplace. The task of the Reference Person is to guide and inform employees regardless of whether they address the Reference Person about an incident or complaint of violence and harassment or not.

Employees of the Company may address in person questions regarding the prevention and treatment of violence and harassment at work to the Reference Person (“Liaison”), by phone or by e-mail at hr_dpt@eurodyn.com

The Reference Person shall keep confidential and protect any personal data that may come to his/her knowledge during the exercise of his/her role.

7. INTERNAL PROCEDURE FOR MANAGEMENT OF COMPLAINTS

Any employee who was exposed to an incident of violence or harassment may file a complaint before the legal department of the Company, which is designated as the competent department for receiving, examining and managing complaints for behaviors of violence and harassment.

The complaint may be submitted in person or via email to the email address legal@eurodyn.com. The complaint must state the details of the complainant, the perpetrator (the person who carried out the behavior prohibited by this policy) and a description of the incident having the nature of the prohibited behavior.

Any complaint, oral or written, must be forwarded to the legal department of the Company. The legal department of the Company examines the complaint directly and impartially, with respect for human dignity.

Upon receipt of the complaint and during its investigation, the legal department handles the complaint in a highly confidential manner. Personal data collected during the investigation of the complaint as evidence of the validity or invalidity of the facts of the complaint, are the absolutely necessary for carrying out the complaint management process. The Company undertakes that throughout the procedure the provisions of the applicable legislation for the protection of personal data will be observed, in particular that the Personal Data of the persons involved will be processed by the legal department of the Company only for the purposes of investigating the complaint and will be communicated only to those who need to know about the reported incidents as well as to the competent authorities, if required by them.

The legal department of the Company is in conversations with the complainant and the respondent, records any staff testimonies and requests the submission of documents or any material that would assist in the determination of the validity or invalidity of the complaint. The completion of the research and the disclosure of the outcome cannot exceed 3 weeks, unless there are special and important reasons. If sufficient information is not provided to reach a safe conclusion or in the event that there are indications that the complaint was made in bad faith, the legal department of the Company may decide to take no further action on the complaint.

If the investigation reveals that the incident of violence and harassment against the complainant actually took place, the legal department of the Company shall submit a written report to the Company’s Management and notify the complainant and the respondent of the outcome of the investigation of the complaint. The Company is obliged to take the necessary, appropriate and proportionate measures on a case-by-case basis against the respondent, following the general disciplinary procedure of the Work Regulation, such as:

• reprimand and recommend compliance
• any disciplinary penalty provided by the disciplinary procedure of the Work Regulation
• change of position, working hours, place and way of providing services
• termination of the employment or any other kind of relationship with the Company. The Company explicitly declares its zero tolerance for any retaliation and further victimization of the complainant. The above also applies to anyone who assists, files or participates in the process of managing internal complaints.

The Company undertakes to cooperate and to provide any relevant information to the competent authorities, upon request. The Company, as well as the legal department of the Company, cooperate with any competent public, administrative or judicial authority, which, either of its own motion or at the request of the complainant, within the scope of its competence, requests the provision of data and information, and undertakes to provide assistance and access to this data.

Employees who need more information or contact information of the competent authorities or have questions about the present policy, can contact their Supervisor or the Reference Person (“Liaison”) of the Company.