Policy for the Prevention and Combating of Violence and Harassment in the Workplace
&
Policy for the Management of Internal Complaints Regarding Incidents of Violence and Harassment
of the company under the name
ΙΝΚ LTD

In the context of INK LTD compliance with the provisions of Part II of Law 4808/2021 for the prevention and treatment of all forms of violence and harassment, including gender-based violence and sexual harassment, and specifically Articles 9 and 10 of Law 4808/2021, the Company establishes and adheres to the following policy:

1. PURPOSE

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 world of work free from violence and harassment.
INK LTD declares that it recognizes and respects the right of every employee to a workplace free from violence and harassment and adopts a zero-tolerance stance toward such behaviors, regardless of their form or the identity of the perpetrator.

Therefore, this policy aims to:

a. Prevent, address, and eliminate all forms of violence and harassment, including gender-based and sexual harassment that occur during work, are related to work, or arise from it.

b. Enable the immediate recognition of harassment or oppression cases by investigating incidents through effective complaint-reporting methods.

c. Inform all executives, employees, external partners, clients, and third parties in contact with the company that any form of violence or harassment is unacceptable.



2. SCOPE OF APPLICATION

This policy applies to the individuals described in paragraph 1 of Article 3 of Law 4808/2021 and, in particular, to all members of the Company’s Management, employees and personnel regardless of their contractual/employment status, including those under an employment contract, project contract, independent services, and temporary employment; those employed through third-party service providers; interns and trainees; employees whose employment relationship with the Company has ended; as well as job applicants and other individuals who interact or cooperate with the Company.

3. RISK ASSESSMENT OF VIOLENCE AND HARASSMENT AT WORK – DEFINITIONS


a) “Violence and harassment” means any behaviors, acts, practices, or threats thereof that are intended, lead to, or may lead to physical, psychological, sexual, or economic harm, whether they occur as isolated incidents or repeatedly.

b) “Harassment” refers to forms of behavior that are intended or result in violating a person’s dignity and creating an intimidating, hostile, degrading, humiliating, or offensive environment, regardless of whether they constitute discrimination. This also includes harassment based on gender or other discriminatory reasons.

c) “Gender-based harassment” refers to behaviors linked to a person’s gender that aim to or result in violating that person’s dignity and creating an intimidating, hostile, degrading, humiliating, or offensive environment, as defined in Article 2 of Law 3896/2010 and paragraph 2 of Article 2 of Law 4443/2016. These behaviors include sexual harassment under Law 3896/2010, as well as actions related to sexual orientation, gender expression, identity, or characteristics.

Prohibited forms of violence and harassment under this policy include, but are not limited to:

  • Insults, especially but not exclusively based on gender, race, religion, appearance, sexual orientation, disability, age, or other personal traits and choices; threats; verbal or gestural abuse; insults made publicly or privately; demeaning or ridiculing a person or their abilities, either privately or in front of others; angry outbursts; persistent or unjustified criticism.
  • Offensive, malicious, derogatory, obscene, or mocking comments and their dissemination; innuendos; sexist or racist jokes and remarks; the use of insulting language; verbal sexual harassment or proposals; suggestions that sexual favors can lead to career advancement or that refusal can harm one’s professional path within the Company; offering benefits (e.g., promotion or pay raise) in exchange for sexual favors; fostering an environment where sexual interaction is promoted as a career development tool; retaliation or threats of retaliation after rejecting sexual advances.
  • Cyberbullying, sending harassing or offensive messages via SMS, email, social media, fax, or letter; intrusive or persistent questions about age, marital status, personal life, sexual orientation, race, ethnicity, cultural identity, or religion. This includes visual harassment such as posters, cartoons, caricatures, photographs, or illustrations that demean protected characteristics under the law.
  • Unwanted physical contact such as touching, pinching, sexual gestures, hitting, grabbing, pushing, or any type of physical violence; invasion of privacy; deliberate partial or total destruction of personal belongings, vehicles, or property; obstructing normal work, movement, or physical integrity; physical confinement or isolation; sexual gestures; physical stalking or pursuit.

It is explicitly stated that retaliation, acts of vengeance, or intimidation against any employee or third party who opposes violence or harassment, submits a complaint, testifies, assists, or participates in any investigation procedure — and any further victimization of the complainant — are considered forms of violence and harassment and are strictly prohibited.


4. MEASURES FOR THE PREVENTION, CONTROL, MITIGATION, AND MANAGEMENT OF SUCH RISKS, AS WELL AS FOR MONITORING SUCH INCIDENTS OR FORMS

As part of its overall policy on preventing and addressing incidents of violence and harassment in the workplace, the company takes the following actions:

  • Informs and trains its staff using the most suitable means in each case to ensure that all personnel are aware of this policy, the procedures outlined herein, and their legal rights in the event of incidents of violence or harassment in their work environment.

These actions include, among other things, informing employees by posting information in visible places or sending it via email to their professional email addresses. This includes details of the competent administrative authorities to which affected individuals can appeal (e.g., Labour Inspection), especially the complaint hotline (15512), the Citizen Service Line (1555), the government website https://1555.gov.gr, and the SOS Line 15900 for immediate psychological support and counseling for women victims of gender-based violence.

  • Trains and informs managers in every appropriate way to help them recognize and identify phenomena of discrimination, violence, and harassment in the workplace, so they can provide the necessary support to employees and partners.
  • Encourages participation of employee representatives and management staff in training programs and seminars regarding the identification and management of potential risks of violence and harassment, as well as in sessions led by mental health professionals or counseling service providers.
  • Establishes a procedure for receiving and examining complaints related to the above phenomena, by appointing a specific individual as the company’s designated contact person (“liaison”), responsible for guiding and informing employees about the prevention and management of violence and harassment, as well as handling complaints. This process also includes provisions for imposing disciplinary measures against anyone proven to have committed or assisted in harassment or violence or anyone who was aware of such acts and deliberately concealed them.
  • Explicitly prohibits retaliation against the complainant and further victimization of the affected individual.

The company is committed to handling all harassment-related complaints and procedures confidentially and examining them impartially.

5. COMPLAINT RECEPTION AND EXAMINATION PROCEDURE

Any employee of the Company or third party connected in any way with it who believes they have been subjected to discriminatory treatment, violence, or any form of harassment, or has witnessed such behavior occurring in the work environment, may report/complain according to the procedures outlined below.

The designated point of contact for managing incidents of workplace violence and harassment under this policy is the current Corporate Social Responsibility Officer and Human Resources Manager of the company.

All inquiries regarding the implementation or interpretation of this policy should be addressed to the designated contact person, who is also responsible for managing all matters related to staff information and guidance, and for issues concerning the prevention and response to violence and harassment in working conditions. This is also the person to whom complaints or grievances are submitted by affected individuals, which are managed as described below.

Complaints regarding violations of this policy are accepted in writing, either anonymously or under a real name, via the dedicated email address: safeworkplace@ink.gr, which is accessible only by the designated contact person.

Complaints are investigated by the contact person promptly and thoroughly, with impartiality and in compliance with confidentiality principles and personal data protection of both alleged victims and alleged perpetrators.

Specifically, the contact person collects and evaluates the complaint, records and categorizes it. If the complaint is made with the complainant’s name, the contact person will contact them to inform them of the options available for managing the incident and ask how they wish the procedure to proceed.

Complainants have the right to be informed of the receipt and progress of their complaint’s investigation.

To prevent any deterioration of the complainant’s position and to ensure the integrity of the investigation, the contact person must recommend that the company’s management take all necessary measures (e.g., employee reassignment, modification of work hours, or telework arrangements) until the investigation concludes.

The following processes may be followed after a complaint is received:

  • Mediation by the contact person and achievement of a resolution through discussion, after inviting and hearing both parties. If the conditions leading to the complaint are resolved and the incident is deemed closed — with the process not exceeding 10 working days — the contact person drafts a report on the incident and its outcome and informs the company’s management.
  • If the complainant does not wish to proceed with mediation, if mediation is unsuccessful, or in the case of an anonymous complaint, the contact person prepares a report with the findings of their investigation, including the characterization and severity of the behavior (if found to be harassment or violence). This report is submitted within 10 working days from receipt of the complaint to the company’s management, which decides on the imposition of sanctions.

If the company confirms that an incident of violence, harassment, or discriminatory treatment did occur, it will decide on appropriate corrective actions and disciplinary sanctions against the accused person, depending on the severity of the incident. These may include, but are not limited to:

a. Oral or written reprimand or compliance notice
b. Change of position, working hours, location, or working arrangements
c. Termination of the employment or collaboration contract

Complaints found to be clearly unfounded or malicious will be archived as inadmissible. If deemed necessary by management, they may be further investigated to restore order and prevent misuse of the procedures outlined in this policy.

This policy and the above procedure apply in parallel and complementarily to existing general legislation on the protection of employee personality and do not affect any legal rights under civil or criminal law.

Any employee or executive engaging in prohibited behavior bears full and sole responsibility for their actions. If the matter is brought before the courts, the company commits to cooperating with the competent authorities and providing any relevant information if requested.

The company and the designated contact person also commit to cooperating with any competent public, administrative, or judicial authority that, within its jurisdiction and either ex officio or upon request by an affected person, requests information or documentation. Any data collected shall be kept in a dedicated file, in compliance with personal data protection laws.

At the end of each calendar year, the contact person will prepare a report summarizing the types of incidents handled (without naming individuals) and their progress.

The adoption of the policies under Articles 9 & 10 of Law 4808/2021 is finalized by informing employees through posting in the workplace, on the company’s notice board and website, and by informing employees and their representatives via written or electronic communication or any suitable means. In the event of policy amendments, the company has the same obligation for consultation and employee notification as it did upon initial implementation.

For the Company
The Manager