Policy for the Prevention and Combating of Violence and Harassment at Work Based on the Law 4808/21

COMPLAINT MANAGEMENT

1. Policy Statement

Violence and harassment at work is a matter of high importance, the effective treatment of which is a necessary condition, not only for the smooth and productive operation of the company, but also for the promotion of wider social goals, such as the fight against all forms of discrimination, the respect for diversity and ensuring the dignity of individuals in our business.

Violence and harassment at work is not only a violation and abuse of human rights, but also a threat to equal opportunities and is unacceptable and incompatible with decent work. All workers have the right to a safe workplace free of harassment and violence.

It is important for the company to have a system in place that will allow both victims to know their rights and ways to react, and the rest to know what the appropriate way is to handle such situations.

Violence and harassment: Means forms of behavior, acts, practices, or threats, which are intended, lead to, or may lead to physical, psychological, sexual, or financial harm. They occur either singly or repeatedly.

Harassment: Means the forms of behavior, which have the purpose or effect of insulting the dignity of the person and creating an intimidating, hostile, humiliating, or aggressive environment, regardless of whether they constitute a form of discrimination and include harassment due to gender or for other reasons distinction.

Harassment due to gender: Means the forms of behaviour referred to in the concept of harassment, with the difference that they are casually linked to gender, which have as a purpose or result the violation of the dignity of that person and the creation of an intimidating, hostile, humiliating, or aggressive environment according to article 2 of law 3896/2010 (A' 107) and par. 2 of article 2 of Law 4443/2016 (A' 232). These forms of behavior include sexual harassment, Law 3896/2010 as well as forms of behavior linked to the person's sexual orientation, expression, identity, or gender characteristics.

Sexual harassment: It means any form of unwanted verbal, psychological or physical behavior of a sexual nature, with the result of insulting the personality of a person, by creating an intimidating, hostile, humiliating, or aggressive environment around him.

The term violence and harassment cover a wide range of unacceptable behaviors and practices. It can manifest itself through life in various forms (physical, verbal, non-verbal, direct, indirect, or implied) or manifest online.

Examples Physical: Unwanted touching, unwanted physical contact, unwanted kissing, unwanted hugging, physical assault, physical abuse, murder.

Verbal (written or spoken): Bullying, threats, hostile behavior, indiscriminate, offensive questions about the person's personal life.

Non-verbal violence: Obscene gestures, display of inappropriate visual material of sexual content.

Online or cyber-harassment through technology and the Internet: Threats, insults, abusive comments, cyberbullying, cyberstalking, trolling, hate, sending obscene images.

With digital evolution, technologies and social media, new channels have been created through which violence and harassment can be perpetrated. Channels which, despite any institutional framework, are objectively very difficult to monitor, with the most important being the difficulty in determining, and by extension in proving, the limits of the "consensual act". It is a dimension that, when invoked by abusers, puts victims in an even more disadvantageous position.

Sexual violence and harassment: Unwanted touching and kissing, unwanted sexual and immoral advances, sexually offensive comments, jokes, sexual gestures, comments about a colleague's clothing, stalking, threats due to non-response to sexual activity, intrusive questions, persistent appointment invitations.

Bullying and mobbing: Repeated unwarranted behavior towards an employee or group of employees that poses risks to their health and safety, repeated negative comments, criticisms, isolating employees, withholding information, assigning tasks that do not match capabilities, giving impossible goals and deadlines, excessive surveillance, or excessive monitoring, forcing workers to work pointlessly, escalating process of marginalization and gradual dismissal from work.

Disagreements and any conflicts that usually exist in a workplace do not constitute harassment, as well as any justified and reasonable action of the company and/or its executives, which is connected to the exercise of the employee's duties, in the context.

Indicative:

• Assignment of tasks and guidance on how and when they should be done.
• Supervise employees, regarding setting performance expectations.
• The moral or financial reward of excellent employee performance.

According to the World Health Organization, different opinions, competition and even confrontations are useful elements in a workplace, while mobbing is characterized by unfavorable actions against someone and is counterproductive for everyone.

At the same time, a conflict is not bullying if the incident is an isolated event or if the two members arguing have equal "power".

MAVRIKOS IMPORTS S.A. (hereinafter "the Company") is committed to providing a safe environment for all its employees, free from any form of violence and harassment at work, including gender-based or sexual harassment, and observes all measures and obligations concerning the implementation of the provisions of Part II of Law 4808/2021. The company will have a zero-tolerance policy for any form of violence or harassment in the workplace, will take all incidents seriously and will investigate complaints promptly. Any act of violence or harassment at work is strictly prohibited.

The term "violence and harassment" in the workplace refers to unacceptable acts, forms of behavior and practices or threats thereof, whether manifested individually or repeatedly, which are intended to, lead to, or are likely to lead to physical, psychological, sexual, or financial harm and includes gender-based violence and harassment. And the term "gender-based violence and harassment" means violence and harassment that targets people because of their gender or disproportionately affects people of a particular gender and includes sexual harassment.

This policy is adopted in accordance with articles 9 and 10 of Law 4808/2021 and the applicable regulatory legislation and covers the persons of paragraph 1 of Article 3 of Law 4808/2021.

2. Preventing and combating violence and harassment at work

a) assessment of the risks of violence and harassment at work, which may be caused by colleagues, superiors, external partners, volunteers:

• Risk of assault leading to physical, sexual, or psychological harm.
• Attempted injury, resulting in bodily harm.
• Harassment or intimidation involving the abuse of physical and psychological force.
• Unwanted behavior – verbal, non-verbal, visual, psychological, or physical based on age, disability, health status, gender, sexual orientation, race, color, language, religion, or other status that adversely affects the dignity of men and women at work.
• Sexual harassment - unwanted behavior that could be perceived by the victim as humiliation, threat, or offense.
• Psychological harassment (bullying) consisting of malicious, cruel, or vindictive attempts to humiliate or undermine the individual.

b) Employees have the right and obligation to report any action or situation that violates this policy. Department heads must take all appropriate measures to prevent, control, limit and address the risks of violence and harassment at work, as well as monitor such incidents or forms of behavior.

c) Anyone, including company employees, casual workers, contractors or visitors who harass someone else, will be screened in accordance with this internal policy.

d) Any act or behaviour of an employee that violates this Policy by an employee of the company is considered a disciplinary Offense, punishable according to its severity.

e) The company undertakes at regular intervals to inform and sensitize employees about the content of this policy, the complaint management process, as well as about their resulting rights and obligations. This will be achieved by regularly organizing informational meetings at department level, or workshops with the participation of all staff.

f) The company must ensure the protection of employment and the support of working victims of domestic violence. For this purpose, appropriate measures will be taken and facilities will be provided to employees.

3. Reference person definition

The company must appoint and announce to employees each time a specific reference person ("Link"), responsible for guiding and informing employees about the prevention and treatment of violence and harassment at work. To this person, employees will be able to address any issue concerning the implementation of this policy. Evanthia Patsaki, accounting department, is specifically designated as the reference person for the first application of this application (email: accdept@mavrikosimports.gr).

4. Procedure for submitting and examining complaints about incidents of violence and harassment at work

According to the law, the rights of employees who may be subjected to violence or harassment are: a) the right to judicial protection, b) submitting an application for a labor dispute procedure to the Labor Inspection, within the framework of its statutory powers, c) reporting to the Ombudsman, within the framework of his statutory powers, as well as d) a complaint within the company in accordance with what follows.

a. All reports of violence or harassment will be taken seriously and treated with respect and trust. No one will be disadvantaged by filing such a complaint, and any form of retaliation against the complainant is prohibited. All those involved in the complaint review process should maintain absolute confidentiality and ensure the personal data of victims and complainants.

b. Whoever experiences an act or behavior of violence or harassment should submit a report alternatively and at his choice to the "Association" or to the head of his department.

Reports may be submitted confidentially, in writing or by e-mail: accdept@mavrikosimports.gr

All reports receive a protocol number and are marked as highly confidential and treated with respect, confidentiality and without fear of retaliation to anyone who reports an incident of harassment or such conduct.

The company takes all the necessary measures to respect the confidentiality and protection of the person's personal data and the information he/she has submitted, disclosing their identity only where required by applicable law or when disclosure is unavoidable to carry out an effective investigation and taking appropriate action. In addition, the company undertakes to provide cooperation and relevant information to any competent public, administrative or judicial authority, if requested, during the investigation of an incident of violence and harassment.

c. All reports will be investigated in a timely, thorough, impartial manner and persons who have submitted reports will be informed of the receipt of the report and the progress of their review.

With the submission of each report and in all cases where there are incidents of violence or harassment, depending on the nature and importance of the case, the recipient of the report collects further information and as the case maybe, discusses the facts with the person involved to clarify the status. Then, in collaboration with the Human Resources Department and the assistance of the Legal Service, it is assessed whether it is essential as well as the possibility of influence on the company's activity.

In any case, the Company ensures that the final decision is based on transparent and unbiased evidence.

d. The company reserves the right to move employees or modify their working hours, pending the outcome of the investigation, as defined in the relevant legislation. During this period, partial or total access to buildings and/or facilities may not be permitted. If the incident of discriminatory treatment of violence, harassment or retaliation is confirmed, after the investigation, the Company will take appropriate corrective, disciplinary or other actions against the offender. Such as indicative and not limiting: (a) disciplinary sanctions, (b) change of position, time, place or method of providing the work, (c) termination of employment contract or partnership agreement, (d) legal actions. In any case, the offender may also be subject to criminal or civil liability, according to the current legislation.

This Policy applies in parallel with the applicable general legislation for the protection of the employee's personality and does not affect his legal rights at the level of civil and criminal legislation. Furthermore, they do not have the right, apart from judicial protection to appeal to the Labor Inspectorate and the Ombudsman as a body promoting and supervising the principle of equal treatment.

The Policy for the Prevention and Combating of Harassment at Work is regularly monitored and revised as required.