Anti-Violence and Harassment Policy

A. General

1. Spine Action complies with all measures and obligations arising from Part II of Law 4808/2021 for the prevention and management of all forms of violence and harassment, particularly gender-based and sexual harassment.

2. The purpose of our policy is to create and establish a work environment that respects, promotes, and ensures human dignity and the right of every person to a workplace free from violence and harassment. To this end, the company declares that it both recognizes and respects the right of every employee to a workplace free from violence and harassment, and that it does not tolerate any such behavior, in any form, from anyone.

3. This policy is adopted in accordance with Articles 9 and 10 of Law 4808/2021 and its implementing regulations. According to Article 3, paragraph 1 of Law 4808/2021, it applies to all persons employed by or working in the company, regardless of their contractual status, including those working under project contracts, independent services, salaried mandates, those employed through third-party service providers, including interns and trainees, employees whose employment has ended, and those applying for employment.

B. Prevention and Combating of Violence and Harassment in the Workplace

The company, based on its adopted policy for the prevention and management of workplace violence and harassment, declares that its strategic framework includes the following:

1. Any form of violence, sexual harassment, or direct or indirect discrimination based on gender is prohibited and not tolerated by anyone during or in connection with work or under the pretext of work. This applies both within and outside the workplace and working hours, including the employee’s commute to and from work and other related activities (training, breaks, etc.), even those conducted through information and communication technologies.

2. Every report or complaint regarding incidents of violence or harassment is investigated by the company without delay, with impartiality, based on the principles of confidentiality, human dignity, and the personal data of those involved.

3.The company provides cooperation and any relevant information, if requested, to the competent authorities—public, administrative, or judicial—during the investigation of incidents of violence or harassment or similar behavior.

C. Information on the Rights and Obligations of Employees and the Company – Procedure for Submitting and Examining Complaints

1. In the event of an incident of violence or harassment, any affected person informs the designated company liaison, who, in addition to investigating the incident, provides guidance on actions and rights, as well as details of the competent authorities to whom they may appeal (Labor Inspection, Ombudsman). The liaison also informs the affected person about the possibility of filing a complaint with the independent department of the Labor Inspection Body (S.E.P.E.), through the citizen service line 1555, as well as about the immediate psychological support and counseling service for women victims of gender-based violence, who can contact the General Secretariat for Family Policy and Gender Equality’s SOS Line 15900.

2. If an incident of violence or harassment is confirmed, the company, in accordance with the law, takes appropriate measures against the accused to prevent and avoid a recurrence of a similar incident. Depending on the severity of the misconduct, these measures may include, among others, compliance orders, changes in position, working hours, location or method of work, or even termination of the employment or cooperation relationship due to the accused’s fault.

3. Every employee in the company, including those working under project contracts, independent services, salaried mandates, those employed through third-party service providers, as well as interns and trainees, who experience an incident of violence or harassment against them, has the rights outlined in Article 12, paragraph 3 of Law 4808/2021.

4. This regulation, which is posted on the company’s Notice Board, has been drafted following consultation with employees. It forms an integral part of all types of contracts that have been or will be concluded with those working in the company, who have been informed of their rights and obligations, as well as those of individuals exercising managerial authority or representing the company, to the extent and within the scope of their own responsibilities, in the event of such incidents or complaints, as well as the related procedure to be followed in such cases.

5. The company’s legal representatives and Ms. Sofia Koukourli are designated as the reference personnel (“liaison”) for the guidance and information of employees regarding the prevention and management of workplace violence and harassment. The relevant complaint can also be submitted electronically by the affected person at hr@spineaction.gr.