Purpose and Commitment

ErgoProlipsis L.T.D. (the “Company” or “ErgoProlipsis”) is committed to fostering a workplace free from violence, harassment, intimidation, and any form of unwanted behavior that undermines the dignity or integrity of individuals. Respect, fairness, and safe working conditions are fundamental to our corporate values and obligations under EU and national law. The Policy is designed to ensure that every person operating within the Company’s sphere of influence is protected from violence and harassment in any work-related context.

The Company adopts a zero-tolerance approach to any form of violence, harassment, bullying, discrimination, intimidation, or retaliation in connection with work.

This Policy forms part of the Company’s governance framework and reflects its commitment to:

Protect fundamental human rights
Promote psychological and physical safety
Ensure fair, respectful, and equal treatment
Maintain ethical and responsible business conduct
Provide accessible information, training, and preventive measures to all workers

The Company recognises that workplace violence and harassment are not only compliance matters, but also governance, risk-management, and sustainability issues. During the development of this Policy, the views and expectations of key stakeholders, including employees and management representatives, were taken into account.

The Company further commits to supporting workers affected by domestic violence, to the extent that is reasonably possible, through appropriate measures or reasonable adjustments.

This Policy is adopted in accordance with:

Applicable European Union legislation concerning equality, non-discrimination, and occupational health and safety
Applicable national legislation governing workplace violence and harassment, including (where applicable) Law 4808/2021 and any subsequent amendments
The ILO Violence and Harassment Convention, 2019 (No. 190) and its accompanying Recommendation (No. 206)
The UN Universal Declaration of Human Rights

Scope of Application

This Policy applies broadly to all individuals engaged in or connected to the activities of the Company.

This Policy applies to:

All employees and non-employees, irrespective of employment status, including permanent, fixed-term, part-time, and self-employed
Contractors, sub-contractors, and external collaborators
Members of management and governing bodies
Interns, trainees, and apprentices
Agency workers and individuals employed through Temporary Employment Agencies (TEAs), including those placed under the direction of the Company as the indirect employer
Workers assigned to the Company under arrangements of legitimate employee lending (secondment), for as long as managerial authority is exercised by the Company
Workers in the informal economy who perform work within the Company’s operational control
Clients, suppliers, business partners, and any third parties interacting with the Company.

The Company expects all covered individuals to comply with this Policy and uphold its principles of dignity and respect.

This Policy applies to conduct occurring in any work-related setting, including but not limited to:

On Company premises and facilities
At client premises or any third-party location where work-related activities are performed
At shared or temporary workplaces, project sites, or external operational locations
During business travel, assignments, or work-related commuting where applicable
At work-related meetings, conferences, training sessions, or social events
In digital environments, including emails, messaging platforms, video conferences, remote work systems, and any other electronic communication platforms
In any environment where the Company exercises managerial authority over the performance of work, regardless of contractual employer
In any situation linked to professional duties, including off-site or informal interactions connected to work activities.

For the purposes of this Policy, the concept of “work-related context” shall be interpreted broadly to ensure effective protection against violence and harassment across the full scope of the Company’s professional activities.

Definitions

Violence

Any act or threat of physical force or power that results in, or may result in, physical, psychological, sexual, or economic harm.

Harassment

“Harassment” means any form of unwanted conduct that has the purpose or effect of violating a person’s dignity and creating an intimidating, hostile, degrading, humiliating, or offensive environment, regardless of whether it constitutes discrimination under applicable law.

Harassment may be linked to legally protected characteristics, including but not limited to gender, age, race, ethnicity, religion, disability, sexual orientation, or other protected grounds.

Sexual Harassment

Any unwanted conduct of a sexual nature, whether verbal, non-verbal, or physical, including:

Sexual advances
Requests for sexual favours
Sexually suggestive comments
Display of inappropriate material

Bullying / Psychological Harassment

Repeated inappropriate behaviour that:

Intimidates
Undermines professional standing
Excludes or isolates
Causes emotional or psychological harm

Violence and Harassment (combined definition)

“Violence and Harassment” refers to a range of unacceptable behaviours and 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 as repeated behaviour, consistent with ILO Convention 190 and national legislation.

Affected Person

Any person covered under Article 3 of Law 4808/2021 who experiences or reports an incident of violence or harassment, including former workers and individuals seeking employment.

Respondent

The person whose conduct is alleged to constitute violence or harassment. Where no investigation has yet been completed, the term “alleged Respondent” may be used.

Reporting Person

Any individual who submits a concern or complaint in good faith under this Policy, irrespective of whether they are the directly affected person.

Prohibited Conduct

The Company strictly prohibits any form of violence or harassment within the workplace or in any work-related context. Prohibited conduct includes both single incidents and repeated behaviours, and includes, but is not limited to:

Physical assault or threats of violence
Intimidation or coercion
Derogatory or discriminatory remarks
Offensive jokes or gestures
Unwelcome physical contact
Repeated humiliating or hostile treatment
Digital harassment or cyberbullying
Abuse of authority or position of power
Any form of retaliation against individuals who report concerns in good faith or participate in an investigation

This list is indicative and not exhaustive. Any behaviour that undermines dignity, safety, or professional integrity is strictly prohibited.

Governance and Responsibilities

Preventing and addressing violence and harassment is a shared responsibility across the organisation. The Company establishes clear accountability at all levels to ensure the effective implementation of this Policy.

The Company

The Company is responsible for establishing and maintaining an effective framework for the prevention, reporting, and resolution of incidents of violence and harassment. In particular, the Company shall:

Establish and periodically review preventive measures and internal procedures
Provide safe, confidential, and accessible reporting channels
Safeguard individuals from retaliation or adverse treatment
Ensure prompt, impartial, and thorough investigations of reported incidents
Ensure that information regarding this Policy and reporting procedures is made accessible and publicly available within the workplace, in accordance with applicable legal requirements
Cooperate with competent authorities where required under applicable law
Implement proportionate corrective and disciplinary measures where violations are confirmed
Monitor and assess the effectiveness of this Policy and related procedures
Promote awareness and provide appropriate training across the organization
Appoint a designated Reference Person responsible for providing guidance, information, and support to employees on matters related to violence and harassment, ensuring easy and direct access for all workers
Ensure the proper functioning of the Reporting Committee, which is responsible for receiving, reviewing, and managing internal complaints in an impartial and confidential manner

Management

Managers and supervisors play a critical role in fostering a respectful workplace culture. They are expected to lead by example and demonstrate behaviour consistent with this Policy.

In particular, managers are responsible for:

Promoting a culture of dignity, inclusion, and mutual respect
Acting promptly and appropriately upon becoming aware of potential misconduct
Ensuring that concerns are reported through the appropriate channels and not obstructed in any manner
Supporting fair, objective, and confidential investigation processes
Taking appropriate interim or corrective measures where required
Preventing and addressing any form of retaliation within their teams
Cooperating with the Reference Person and the responsible person when required

Employees

All employees are expected to contribute to a safe and respectful work environment.

All employees are required to:

Treat colleagues, clients, and third parties with professionalism and respect
Refrain from engaging in any conduct prohibited under this Policy
Cooperate fully and honestly in investigations when requested
Report incidents or concerns in good faith through established channels
Refrain from obstructing reporting or investigation processes
Avoid any form of retaliation against individuals who raise concerns
Make use of the information and support provided by the Reference Person where needed

Failure to comply with these responsibilities may result in disciplinary action in accordance with applicable procedures.

The above examples are indicative and not exhaustive. Any conduct that undermines a person’s dignity, safety, or professional integrity may constitute a violation of this Policy.

Reporting Mechanisms

The Company encourages the prompt reporting of any incident, concern, or suspicion of violence or harassment. Early reporting enables timely intervention, supports affected individuals, and helps prevent further harm.

Reports may be submitted through the Company’s established internal reporting system, in accordance with the Company’s Whistleblowing Policy.

The Company maintains a formal whistleblowing mechanism, accessible through its official website (https://www.ergoprolipsis.gr), which is available to employees and all external stakeholders. The system allows for the submission of reports, including anonymous reports, and contains a dedicated section outlining the applicable reporting procedures and safeguards.

The responsibility for the receipt and handling of reports lies with designated responsible person within the Company, who ensures that all reports are reviewed, assessed, and addressed in accordance with the Company’s procedures.

In addition, a designated Reference Person-“Contact Point” (General Manager of the company), who is available to provide guidance, clarification, and support to any individual seeking information on how to report or navigate the process. The Reference Person does not investigate complaints but ensures that employees have direct and easy access to information and assistance.

The Company ensures that all reporting channels are secure, accessible, and designed to protect confidentiality and safeguard individuals from retaliation.

Information about reporting procedures and the contact details of competent authorities shall be displayed prominently in the workplace in accessible formats, in accordance with legal requirements.

Procedure for Receiving and Examining Complaints

Any person covered under Article 3 of Law 4808/2021 who experiences an incident of violence or harassment, even if the employment or contractual relationship within which the conduct allegedly occurred has ended, has the right, in addition to judicial protection, to:

Submit a complaint before the Labour Inspectorate (Hellenic Labour Inspectorate – hli.gov.gr, Citizen Service Line: 1555)
Address the Greek Ombudsman, as the competent authority for the promotion and supervision of equal treatment (press@synigoros.gr, +30 213 1306 600)
Seek support through the SOS 15900 helpline for victims of gender-based violence
Submit an internal complaint in accordance with the Company’s Whistleblowing Policy

Contact details of the above authorities are made accessible within the workplace and through the Company’s official communication channels.

Internal Reporting Procedure

The Company has established secure and accessible communication channels for the submission and management of complaints, as further described in the Company’s Whistleblowing Policy (www.ergoprolipsis.gr), which sets out the framework governing reporting procedures, confidentiality safeguards, and protection against retaliation. Complaints may be submitted:

In person;
In writing;
By electronic communication to the designated reporting address
Through the Company’s Reference Person (“Contact Point”) for guidance and support

Anonymous complaints may be submitted where permitted by applicable law. However, the effectiveness of the investigation may depend on the availability of sufficient information. The Company encourages identified reporting to ensure proper examination and protection of the reporting person.

The person designated to receive and examine complaints is τhe ESG and Sustainability Director – Tampakoulaki Varvara (v.tampakoulaki@ergoprolipsis.gr, +306907525509)

The Reference Person may support the complainant but shall not participate in the examination or investigation of the case.

Conflict of Interest Safeguard

Where the alleged Respondent is one of the designated responsible persons, or where a conflict of interest may reasonably arise, the complaint may be submitted directly to the other designated officer.

In such cases, the investigation shall be conducted by an alternative authorised person or, if deemed appropriate, by an external advisor to ensure impartiality and objectivity. No individual shall examine a complaint in which they are directly or indirectly implicated.

Content of the Complaint

To enable proper investigation, the complaint should include:

The identity of the complainant (unless anonymous reporting is permitted)
The identity of the alleged respondent
A description of the incident(s), including date, location, and circumstances
Any available supporting evidence or witness information.

Investigation Process

Upon receipt of a complaint, the designated responsible person shall:

Acknowledge receipt
Initiate a prompt, impartial, and confidential review
Hear both parties where appropriate
Collect and examine relevant evidence lawfully available
Ensure respect for dignity, confidentiality, and data protection obligations

The investigation shall be conducted with discretion, integrity, and in compliance with applicable data protection legislation and this Policy.

Upon completion of the review, a written report shall be prepared and submitted to the competent decision-making body of the Company for appropriate action.

Cooperation with Authorities

The Company and all responsible persons shall cooperate with any competent public, administrative, or judicial authority that lawfully requests information or documentation in relation to an incident of violence or harassment.

All documentation collected during the process shall be retained in a dedicated file, in compliance with applicable data protection legislation.

All collected information shall be stored in a dedicated file in compliance with applicable data protection legislation, including Law 4624/2019.

Investigation Procedure

Upon receipt of a complaint or report, the Company will initiate a structured review process aimed at establishing the facts in a fair, objective, and timely manner. Investigations shall be conducted by authorised personnel who are appropriately trained and free from conflicts of interest.

Throughout the process, the Company will ensure confidentiality to the greatest extent possible and respect the dignity and rights of all parties involved. Investigators shall act with discretion and shall access only the personal data strictly necessary for the purposes of the investigation, in accordance with applicable data protection legislation. Findings will be documented, and appropriate measures will be taken based on the outcome of the investigation. Relevant parties will be informed of conclusions and actions taken, subject to legal and data protection constraints.

All investigations shall be conducted in accordance with principles of due process, proportionality, and impartiality. All documentation collected throughout the investigation shall be securely stored in a dedicated file, in compliance with applicable data protection requirements.

Protection Against Retaliation

The Company strictly prohibits any form of retaliation against individuals who raise concerns or participate in processes under this Policy. Protection applies to any person who reports a concern in good faith, participates in an investigation, provides information, or supports an affected individual.

Retaliatory actions — whether direct or indirect — constitute a serious violation of this Policy and will be treated as an independent disciplinary offence. The Company is committed to ensuring that individuals can speak up without fear of adverse consequences to their employment, professional standing, or working conditions.

Measures and Consequences

Where, following the investigation process, an employee or any other person covered under Article 3 of Law 4808/2021 is found to have violated the prohibition of violence and harassment, the Company shall take appropriate, necessary, and proportionate measures against the respondent to prevent recurrence of similar conduct.

Such measures may include, depending on the severity and circumstances of the case:

A formal warning or recommendation for compliance
Modification of role, duties, reporting line, working hours, or workplace location
Reassignment or adjustment of working conditions
Termination of the employment relationship or contractual cooperation, in accordance with applicable law

All measures shall be implemented in line with the principle of proportionality and with due regard to the prohibition of abuse of rights under the labour legislation. The protection and well-being of the affected person shall remain a primary consideration.

Where relevant, the Company may also provide reasonable adjustments or support measures in cases involving victims of domestic violence, in accordance with applicable legislation.

Cases Involving Third Parties

Where the individual engaging in violent or harassing conduct is not an employee of the Company but a third party (such as a client, contractor, or cooperating entity), the Company shall support appropriate actions for the notification of the misconduct to the competent authorities and/or to the employer of the respondent, where applicable.

With the consent of the affected person, the Company shall also take all necessary measures to remove or mitigate exposure to the conditions under which the misconduct occurred. Such measures may include adjustments to working hours, reassignment to a different team, or other appropriate organisational arrangements.

Right to Temporary Withdrawal from the Workplace

Any affected person who reasonably believes that they are exposed to an imminent and serious risk to their life, health, or safety as a result of violence or harassment shall have the right to withdraw from the workplace for a reasonable period, without loss of salary or other adverse consequences.

This right applies particularly where:

The employer is the perpetrator of the conduct
The Company has failed to take appropriate and necessary measures to restore workplace safety
The measures taken are insufficient to effectively stop the violent or harassing behaviour

The withdrawing individual shall inform the Company in writing in advance, specifying the incident and the circumstances supporting the belief that a serious and imminent risk exists.

If the risk no longer exists and the individual refuses to return to work without justified grounds, the Company may refer the matter to the competent labour Inspectorate for resolution.

Prohibition of Retaliatory Dismissal or Adverse Treatment

Any termination of employment or contractual relationship, or any other adverse treatment of a person covered under Article 3 of Law 4808/2021, shall be null and void if it constitutes retaliation or countermeasure in response to a complaint or incident of violence and harassment.

The Company strictly prohibits any form of retaliatory conduct and shall ensure full compliance with applicable anti-retaliation provisions under national legislation.

Confidentiality and Data Protection

All information relating to reports, complaints, and investigations shall be handled with the utmost discretion and sensitivity. The Company processes such information confidentially and in accordance with applicable data protection legislation, including the General Data Protection Regulation (GDPR) and relevant national and European laws.

Access to information will be restricted to authorised individuals who have a legitimate need to know for the purposes of assessment, investigation, or resolution. Investigators and authorised personnel shall access only the personal data strictly necessary for the fulfilment of their duties.

The Company will ensure that data is retained and processed in line with legal requirements and internal data governance policies. All documentation related to reports and investigations shall be stored in a dedicated, secure file in accordance with applicable data protection regulations.

Risk Assessment of Violence and Harassment

The Company integrates the assessment of risks related to violence and harassment into its overall Occupational Risk Assessment framework. This process aims to identify, evaluate, and address potential situations, behaviours, or structural conditions that could create or contribute to risks of violence or harassment in the workplace.

The assessment is conducted periodically and whenever significant organisational, operational, or environmental changes occur. It considers factors such as the nature of work activities, interaction with clients or third parties, isolated or remote work conditions, work schedules, hierarchical structures, and any circumstances that may create heightened vulnerability for specific groups of workers.

Findings from the risk assessment are used to inform preventive measures, awareness initiatives, and any necessary adjustments to workplace policies or practices. The Company ensures that all identified risks are appropriately managed through proportionate and reasonable organisational, technical, or procedural controls.

The risk assessment process is documented and reviewed regularly to ensure continued relevance and compliance with applicable legal requirements.

Prevention, Training, and Monitoring

Prevention is a central pillar of this Policy. The Company is committed to fostering a workplace culture in which dignity, respect, and inclusion are actively promoted and embedded in daily operations.

To support this commitment, the Company shall implement periodic awareness and training programmes, integrate respectful workplace principles into onboarding processes, and regularly assess organisational culture and risk factors related to violence and harassment.

Training and information shall be provided in accessible forms, and special attention shall be given to positions with elevated risk of exposure to violence or harassment, in accordance with applicable legislation.

Where appropriate, the Company may monitor indicators such as the number of reported cases, resolution timelines, and training participation rates, with the objective of evaluating effectiveness and continuously improving preventive measures.

Policy Review and Approval

This Policy shall be reviewed periodically to ensure its ongoing effectiveness, relevance, and compliance with applicable legal and regulatory requirements. Revisions may be made to reflect legislative developments, organisational changes, or identified areas for improvement.

The Policy is approved by the Company’s Top Management and forms an integral part of the Company’s corporate governance framework.

It shall be made available to all employees and posted in a visible location within the workplace, as required by applicable legislation.

Workplace Violence and Harassment Policy