Policy on Violence & Harassment at Work

Policy for the prevention and combat of violence and harassment at work

CHAPTER A: PREVENTION & PROTECTION FRAMEWORK

Article 1: Introduction & Fundamental Principles

• a) The Company under the corporate name “RAM ESTIASI SA”, active in the field of REFRESHMENT STAND SERVICES, with Tax Registration Number (T.I.N.) 801803656 (Internal Revenue Service / D.O.Y. of PAROS), having its registered office at PAROIKIA KRIOS VOUTHIMA CHRYSSI AMMOS, PAROS, P.C. 84400, and legally represented by MOUSTRAS PANAGIOTIS, fully complies with the provisions of Law 4808/2021 (Labor Protection), the International Labour Organization (ILO) Convention 190 on the elimination of violence and harassment in the world of work, as well as the relevant provisions of Law 5239/2025. Through this policy, the management pledges the universal implementation of statutory measures for the prevention and management of any form of improper conduct, with particular emphasis on gender-based and sexual harassment.
• b) The Company applies a policy of zero tolerance towards phenomena of violence, harassment, and discrimination. This document clearly defines the rights and obligations of both employees and the employer, aiming to ensure a healthy working climate.

The Company explicitly recognizes that:

• Every individual is entitled to work in an environment free from discrimination and intimidation.
• Violence and harassment directly violate human rights and undermine equal opportunities.
• Cultivating a culture of mutual respect and dignity constitutes the primary prevention tool.
• Such behaviors severely damage people’s psychological and physical health, degrade productivity, and tarnish the corporate reputation.

Article 2: Purpose

• a) The main objective of this policy is to establish a modern working framework that safeguards human dignity. The Company guarantees that it will not tolerate any behavior that offends the personality of its employees, regardless of whom it originates from.
• b) Through this Policy, the Company:
  • Commits to maintaining a safe environment that promotes equality and respect for diversity.
  • Accurately defines the procedures for preventing and addressing non-compliant and offensive behaviors.
  • Takes care, through every available and appropriate means, to protect and support employees who are victims of domestic violence.

Article 3: Conceptual Definitions & Examples

1. Violence and Harassment

• Definition: Any unacceptable behavior, practice, or threat thereof (whether manifesting as a single occurrence or repeatedly), which aims to lead, or is likely to lead, to physical, psychological, sexual, or economic harm. By definition, it also encompasses gender-based violence.
• Indicative Examples:
  • Threatening, aggressive, or intimidating behavior.
  • Spreading malicious rumors, social isolation, or deliberate exclusion.
  • Derogatory comments regarding gender, race, ethnicity, age, disability, religion, or sexual orientation.
  • Use of offensive, racist, or sexist humor and public ridicule.
  • Distribution, posting, or display of pornographic, obscene, or racist material.
  • Systematic and unjustified suffocating surveillance (bullying/stalking).
  • Destruction or theft of personal items and work tools.
  • Arbitrary and abusive exclusion from leaves, training programs, or promotions.
  • Physical assault and bodily abuse.

1. Gender-Based Violence and Harassment

• Definition: Behaviors related to a person’s gender, which offend their dignity and create a hostile, degrading, humiliating, or intimidating environment. This covers sexual harassment as well as discrimination concerning gender identity, expression, or sex characteristics.
• Indicative Examples:
  • Comments or innuendos that diminish someone’s personality based on their gender or sexual orientation.
  • Hostile treatment or prejudice due to gender identity.

III. Sexual Harassment

• Definition: Any form of unwanted verbal, psychological, or physical conduct of a sexual nature, with the effect of violating a person’s dignity, particularly by creating an intimidating, hostile, degrading, humiliating, or offensive environment around them.
• Indicative Examples:
  • Coercive sexual advances, persistent requests for dates, or demands for sexual favors.
  • Sending messages, images, or emails with sexual/pornographic content.
  • Obscene jokes, innuendos, or comments regarding someone’s romantic or private life.
  • Derogatory remarks about an employee’s physical appearance or attire.
  • Unwanted physical contact (touching, fondling, patting, or close approach without consent).

1. Discrimination (Direct & Indirect)

• Definition:
  1. Direct discrimination: Less favorable treatment of a person compared to another in a similar situation, based on a protected characteristic (gender, age, religion, origin, etc.).
  2. Indirect discrimination: When an apparently neutral provision, criterion, or practice puts a specific group of persons at a disadvantage, unless it is objectively justified by a legitimate and necessary purpose.
• Indicative Examples:

• • Obstructing career advancement due to age, religion, or political beliefs.
  • Exclusion from corporate perks or accommodations due to sexual orientation or origin.

What DOES NOT Constitute Violence or Harassment

The lawful actions of the Management relating to managerial prerogative and the smooth operation of the business do not constitute violations of this policy, such as:

• The exercise of supervision and the setting of performance targets.
• The implementation of Performance Improvement Plans.
• The assignment of duties, guidance, and requests for progress reports (reporting).
• The approval or reasoned rejection of leave requests.
• Requests for the submission of medical certificates for absence, in accordance with the law.
• Providing constructive feedback (positive or negative) and the moral or financial rewarding of excellence.

Article 4: Scope & Beneficiaries

• a) This policy covers horizontally all personnel of the Company, regardless of their contractual employment status (fixed-term/indefinite contracts, project-based contracts, independent services, salaried mandates). It also includes employees through third-party providers, interns, apprentices, volunteers, job applicants, as well as former employees.
• b) Protection extends to incidents taking place:
  • At physical workplaces (including break areas, dining areas, restrooms, or company-provided accommodations).
  • During commutes to and from work, business trips, seminars, and corporate social events.
  • Via digital communication channels (emails, phone calls, chats, video conferencing platforms).

CHAPTER B: COMPLAINT MANAGEMENT PROCEDURE

Article 1: Responsibilities & Roles

• a) The ultimate responsibility for compliance with this Policy lies with the Board of Directors of the Company.
• b) The Director of HR, Nikos Papadopoulos, and the HR Manager, Lia Vrastaminou, are designated as the Reporting Persons (responsible for receiving and managing complaints). They hold the responsibility to guide staff, receive reports, and conduct impartial investigations.
• c) Managers, supervisors, partners, and suppliers are required to actively assist in the implementation of this policy.
• d) Complaints can be submitted by the victim themselves, by any third party who witnessed the incident (colleague, manager), or by the Occupational Physician.
• e) The Company explicitly informs every affected person that they retain the right to concurrently appeal to the competent public authorities (Labor Inspectorate – 1555, The Greek Ombudsman – 2131306600) or to the Justice system.
• f) If an employee becomes aware of a violation of this policy, they must immediately inform their Supervisor, the General Manager, or the Occupational Physician, who in turn will forward the information to the Reporting Person.
• g) Provoking, participating in, or covering up/showing apathy towards incidents of violence and harassment constitutes a serious disciplinary offense.
• h) Right to Separate/Leave: Any employee subjected to violence or harassment has the right to demand that the behavior cease. They are, however, required to inform the Reporting Person in advance and in writing, setting out the reasons for their departure.
• i) The Company guarantees the absolute protection of Personal Data, in full compliance with the General Data Protection Regulation (GDPR – EU 2016/679) and Law 4624/2019.

Article 2: Competences of the Occupational Physician

• a) The Occupational Physician acts in an advisory capacity on matters of work psychology, ergonomics, and workplace design. They support the integration or reintegration of victims of violence, harassment, or domestic violence, proposing reasonable adjustments to their workstations if necessary.
• b) They supervise the implementation of health measures, regularly inspect workstations, investigate the causes of psychosocial risks, and provide emergency medical care in cases of accidents or violent incidents.
• c) They are entitled to submit a report-complaint on behalf of an affected employee if they became aware of the incident during the taking of the medical history, exclusively and only with the explicit consent of the employee.

Article 3: Receipt & Examination of Internal Complaints

Reports are accepted as follows:

• In Writing: Via email to the electronic addresses hrdirector@criosparos.com or hr@criosparos.gr, addressed to the Reporting Person (Director of HR or HR Manager) with an automatic copy sent to the General Manager / Chief Executive Officer (CEO).
• Orally: Via telephone or in-person meeting with the Reporting Person or through the Supervisor/Occupational Physician (with the consent of the affected person).

The Company encourages named (non-anonymous) complaints, as they facilitate the full investigation of the facts, and guarantees that there will be no retaliation, adverse treatment, or stigmatization of the complainant. Anonymous reports will also be examined, depending on their degree of substantiation and the data provided.

Article 4: Investigation Procedure

The Reporting Person is obliged to:

1. Accurately record the facts and dates.
2. Clarify the complainant’s expectations and agree with them on the next steps (formal or informal process).
3. Maintain a confidential file with restricted access.
4. Inform the employee of their rights outside the company (Labor Inspectorate, Ombudsman, etc.).

The investigation is conducted with strict confidentiality. The findings are submitted in writing to the Management and communicated to the parties involved (the complainant and the respondent) within three (3) weeks from the submission of the complaint. The Company is obliged to cooperate fully with public authorities if information is requested.

Article 5: Decision Making & Disciplinary Sanctions

• a) The competent body for imposing penalties is the Special Disciplinary Committee, consisting of the Chief Executive Officer, the General Manager, and the Legal Counsel, after taking into consideration the findings of the Reporting Person.
• b) If a violation is proven, penalties are imposed based on the principle of proportionality:

Penalty Assessment Factors:

• (i) Mitigating Circumstances: Isolated incident, proven lack of awareness/training regarding the Policy, spontaneous reporting of the violation by the perpetrator themselves.
• (ii) Aggravating Circumstances: Repeated or continuous behavior, intent (willful misconduct), gross negligence, recidivism/relapse despite previous recommendations or penalties.

Article 6: Supplementary / Appropriate Measures

For the protection of the victim and the restoration of labor peace, the Company may additionally take the following measures:

• Operational transfer (change of department, shift, hours, or branch office) of the complainant and/or the perpetrator.
• Implementation of a remote work (teleworking) arrangement for any of the involved parties.

CHAPTER C: FINAL PROVISIONS

Article 1: Auditing, Statistics & Review

The Company maintains anonymous statistical data (number of incidents, types of complaints, resolution methods) for the purpose of evaluating this policy. The review and any update of the text takes place on an annual basis.

Article 2: Entry into Force & Publicity

This Policy enters into force immediately. It is posted in prominent and accessible areas at the physical workplaces (notice boards) and uploaded digitally to the Company’s internal network (intranet), ensuring that all personnel have immediate and continuous access.