POLICY STATEMENT

In compliance with the provisions of Law 4808/2021 and International Employment Contract No.190, the Company ensures to its employees and to any third party associated with any legal relationship with the Company a safe working environment within the bounds of respect, dignity and courtesy, condemning all acts of harassment, intimidation, violence or discrimination.

The Company declares that it recognizes and respects the right of every employee in a work environment free of violence and harassment and that it does not tolerate any such behavior, of any kind by any person

WHO DOES THIS POLICY APPLY TO?

The present policy applies to all groups of our employees, including, apart from permanent staff, any temporary employees, independent services providers, as well as persons under training status, volunteers, persons whose employment relationship has ended, as well as job applicants and job seekers.

Everyone must comply with this policy and the provisions of Law 4808/2021 and International Labor Convention No. 190, and in addition, managers must be vigilant and to prevent any form of harassment and intimidation.

WHAT IS VIOLENCE, HARASSMENT, OR INTIMIDATION

Violence, harassment, or intimidation is any unwanted behavior that undermines the dignity of employees in the workplace and creates an intimidating, hostile, degrading, sexual orientation, marital status, age, disability, or religion and may include offensive or demeaning remarks, abuse of power, inappropriate touching, unwelcome sexual advances, and any other unwanted conduct.

Intent to cause offense is not necessary for your conduct to be considered intimidating or harassing. The key question is whether the recipient wants you to behave in that way or not.

Some examples of such unwanted behavior are physical or verbal abuse and coercion, violence, making offensive or sexually explicit insults, displaying and distributing offensive material or material of a sexually explicit nature, unwelcome sexual advances or requests for sexual favors, threating of dismissal and/or loss of promotion etc for refusal of sexual favors, misusing personal information, creating a hostile or intimidating work environment, isolating or not cooperating with a colleague, or spreading malicious or insulting rumors.

Harassment or bullying may be conducted face to face, in writing, electronically or by telephone in the workplace, as well as in other places, such as during commuting to and from work, during breaks, at social events. etc.

The Company encourages every victim of such behavior to file a complaint in order appropriate measures to be taken, which in serious cases can lead to dismissal.

The procedure to be followed is recorded below.

PROCEDURE

Any person who has suffered or considers that has suffered an act of violence or harassment in accordance with the above, has the right and must file a report to the competent three-member committee, which has been set up specifically for this purpose in accordance with the provisions of law 4808/21, as well as to the competent authorities.

There are no time limitations for reporting and taking action, although the Company encourages that reports are made as soon as knowledge, or suspicion, of an act of harassment, exploitation or abuse occurs.

All incidents, including the date, time, nature of the incident, names of those involved and the names of any witnesses should be recorded in the relevant report.

The complaint will be kept as confidential as possible, although in many cases an investigation will need to be carried out which may involve others. The investigation will be carried out with the utmost discretion and the reporter will be informed about the procedure throughout the investigation and will have the right to intervene.

The reporter/complainant will continue to work as normal during the investigation of the complaint unless there are indications that his safety is threatened. In any case the issue will be discussed with the complainant.

The Company will take every measure to protect the complainants and the witnesses from retaliation and from any intimidation or harassment.

HOW AN INCIDENT IS REPORTED – WHAT HAPPENS NEXT

The complaint can be submitted confidentially via email to w.policy@naftomar.gr or to the  personal emails of the Committee’s Members. The Committee will investigate the allegations with impartiality, confidentiality, and protection of the personal data of those involved. The Company’s Management and the complainant will be informed by the Committee at all stages of the investigation as well as for how long is estimated that the investigation will last. The duration of the investigation depends on the facts of each case, however every effort will be made to investigate each complaint as soon as possible.

At the end of the procedure, the complainant will be informed in writing about its result and the measures that may be taken against the harasser or bully. The Committee decision will be fully reasoned. If the complaint proves to be true and the harasser continues to work for the Company, the possibility of changing his workplace will always be considered. If this is not possible for any reason, other options will be discussed with the complainant.

Indicative    actions   decided   by   the    Three    Member    Committee    based   on   their severity/repetition are:

Category 1 (Lesser severity and one -off)

• Written warning
• Supplemental training/coaching

Category 2 (higher severity or repeat offenders of category 1)

• Exclude from annual merit increase/bonus/promotion process
• Other financial sanction
• Reduction of role scope
• Work subject to additional oversight (increased scrutiny)
• Change of workplace and/or working hours and/or position

Category 3 (higher severity or repeat offenders of either category 1 or 2)

• Removal of signing rights
• Termination of employment due to an “important cause”, without payment of compensation,
• Other legal

The outcome of the complaint will be notified in writing to the reporter.