INTRODUCTORY NOTE ON THE PREVENTION OF VIOLENCE AND HARASSMENT IN THE WORKPLACE

The following document sets out the Company’s policy on incidents of violence and sexual harassment in any of the premises or work-related circumstances involving TH. DIMITROULAKOS S.A.

As you will see, you may contact the designated representatives listed in this document, one from the Company’s management and one from its administrative staff, in accordance with the requirements of the applicable legislation.

Please be reminded that any incident must be reported through a written complaint, clearly identifying the person or persons responsible for the alleged conduct. The relevant incident reporting form is provided below.

For your information, I would like to point out that, apart from being unacceptable, such behaviour has not been characteristic of the Company throughout its years of operation.

Respect, dignity, understanding and a willingness to cooperate are fundamental values that reflect a person’s level of culture and upbringing, regardless of nationality, religion or gender. These are values that each of us acquires through family education and personal development.

We thank you for the respect you demonstrate towards the workplace, which is also a place of creation and collaboration, and we sincerely hope that this positive working environment will be maintained.

Kind regards,

Sotiris Dimitroulakos

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COMPANY DETAILS

THEODOROS DIMITROULAKOS SOCIÉTÉ ANONYME INDUSTRIAL AND COMMERCIAL COMPANY OF METAL PRODUCTS

Trading name: THEODOROS DIMITROULAKOS S.A.

Registered office: 54 Iera Odos, Athens, Greece

VAT No.: 094450742

Tax Office: F.A.E. Athens

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POLICY ON THE PREVENTION AND COMBATING OF VIOLENCE AND HARASSMENT IN THE WORKPLACE AND ON THE MANAGEMENT OF INTERNAL COMPLAINTS REGARDING INCIDENTS OF VIOLENCE AND HARASSMENT

Article 1 – General Principles and Purpose

The Company operating under the corporate name “THEODOROS DIMITROULAKOS SOCIÉTÉ ANONYME INDUSTRIAL AND COMMERCIAL COMPANY OF METAL PRODUCTS”, with the trade name “THEODOROS DIMITROULAKOS S.A.”, complies with all measures and obligations relating to the implementation of the provisions of Part II of Law 4808/2021 (Government Gazette A’ 101), concerning the prevention and combating of all forms of violence and harassment, including gender-based violence and harassment and sexual harassment.

The purpose of this Policy is to create and establish a working environment that respects, promotes and safeguards human dignity and the right of every individual to a world of work free from violence and harassment.

The Company “THEODOROS DIMITROULAKOS S.A.” declares that it recognises and respects every employee’s right to a working environment free from violence and harassment and that it does not tolerate any such behaviour, in any form, by any person.

This Policy is adopted in accordance with Articles 9 and 10 of Law 4808/2021 and the relevant regulatory provisions implementing them. It applies to the persons referred to in paragraph 1 of Article 3 of Law 4808/2021, in accordance with the scope of application set out in Article 2 herein.

Article 2 – Scope of Application

This Policy applies to and covers all employees and persons working for the Company “THEODOROS DIMITROULAKOS S.A.”, irrespective of their contractual status, including persons employed under contracts for services, independent service agreements or salaried mandate agreements, persons working through third-party service providers, as well as individuals undertaking training, including interns and apprentices, volunteers, employees whose employment relationship has ended, and persons applying for employment.

Forms of violence and harassment against any of the above-mentioned persons may occur, in particular:

a) At the workplace, including public and private spaces and locations where an employee performs work, receives remuneration, takes a rest or meal break, or uses sanitary facilities, personal care facilities or changing rooms.

b) During journeys to and from work, other work-related travel, business trips, training activities, as well as work-related events and social activities.

c) During work-related communications, including communications carried out through information and communication technologies.

Article 3 – Definitions

For the purposes of this Policy, the following definitions shall apply:

a) “Violence and harassment” means forms of behaviour, acts, practices or threats thereof which are intended to cause, result in, or may result in physical, psychological, sexual or economic harm, whether occurring as isolated incidents or repeatedly.

b) “Harassment” means forms of behaviour intended to or resulting in the violation of a person’s dignity and the creation of an intimidating, hostile, degrading, humiliating or offensive environment, irrespective of whether such behaviour constitutes a form of discrimination. This includes gender-based harassment and harassment on other discriminatory grounds.

c) “Gender-based harassment” means forms of behaviour related to a person’s gender which have the purpose or effect of violating that person’s dignity and creating an intimidating, hostile, degrading, humiliating or offensive environment.

Such forms of behaviour also include sexual harassment (as defined below), as well as behaviour related to a person’s sexual orientation, gender expression, gender identity or sex characteristics.

d) “Sexual harassment” means any form of unwanted verbal, psychological or physical conduct of a sexual nature which has the purpose or effect of violating a person’s dignity, particularly by creating an intimidating, hostile, degrading, humiliating or offensive environment around that person.

Article 4 – Prohibition of Violence and Harassment in the Workplace

All forms of violence and harassment occurring in the course of employment, whether connected with or arising from work, are strictly prohibited. This includes violence and harassment based on gender, religion, race or sexual orientation, as well as sexual harassment.

The following are strictly prohibited, among others:

a) Comments containing sexually explicit expressions or other malicious remarks directed at persons who have not expressly indicated their willingness to receive such comments.

b) Comments or persistent questions concerning a person’s physical appearance, gender, religion, race or sexual orientation, which cause embarrassment or discomfort.

c) The distribution and/or display of sexually explicit material or any other material offensive to human personality or dignity (e.g. photographic, digital or printed material).

d) Unwanted comments containing sexual innuendo.

e) Sending messages of a sexual nature.

f) Sexual gestures or acts (e.g. any unwanted physical contact intended to assault, intimidate or pressure someone into engaging in sexual relations).

g) Persistent invitations or proposals for dates.

h) Threats or insinuations that granting sexual favours may advance someone’s career, or that refusing to engage in a sexual relationship may negatively affect their professional career within the Company.

i) The use of obscene, threatening or offensive language, including cyberbullying.

j) Obscene, threatening, violent or offensive gestures.

k) Coercion into sexual contact or physical intimacy.

l) Belittling or ridiculing an individual or their abilities, whether in private or in front of others.

Article 5 – Assessment of Risks of Violence and Harassment in the Workplace

Risks arising from violence and harassment in the workplace may include, indicatively:

a) Violation of human dignity and the infliction of moral harm.

b) Causing anxiety, stress, anger and fear during the performance of work duties.

c) Causing psychosomatic and other symptoms.

The Company itself may also face the following risks, indicatively:

a) Disruption of working relationships and the smooth operation of the Company.

b) Reduced productivity.

c) Legal and financial consequences.

d) Negative publicity.

Article 6 – Measures for the Prevention, Control, Mitigation and Management of Risks of Violence and Harassment in the Workplace and for Monitoring Related Incidents or Forms of Behaviour

The Company “THEODOROS DIMITROULAKOS S.A.” adopts measures and implements administrative practices aimed at preventing, controlling, mitigating and addressing risks of violence and harassment in the workplace, as well as monitoring related incidents or forms of behaviour. Such measures include, indicatively:

a) Providing information and raising awareness among Company personnel regarding violence and harassment, as well as issues concerning vulnerable categories of employees, and training personnel in appropriate and healthy standards of behaviour.

b) Promoting respect for human dignity, cooperation and mutual assistance.

c) Training employees in procedures for managing incidents of violence and harassment.

d) Adopting this Policy on the Management of Internal Complaints Regarding Incidents of Violence and Harassment, so that every complaint or relevant report is received, investigated and resolved confidentially and in a manner that respects human dignity.

e) Appointing a designated contact person (the “Liaison Officer”) for reporting incidents of violence and harassment in the workplace.

f) Providing guidance and support to victims of violence and harassment to facilitate their reintegration into the workplace.

g) Providing assistance to any competent public, administrative or judicial authority investigating incidents of violence or harassment, whenever requested to do so.

Article 7 – Information and Awareness-Raising Activities for Personnel on Issues of Violence and Harassment

The Company “THEODOROS DIMITROULAKOS S.A.” declares its zero-tolerance policy towards incidents of violence and harassment and undertakes the following actions to raise personnel awareness of such incidents:

a) Through this Policy, the Company provides its personnel with information regarding the risks of violence and harassment, the relevant preventive and protective measures, the procedures established at Company level, and the legal options available in the event of such incidents.

b) The Company may organise seminars with mental health professionals or counselling service providers to discuss relevant issues and ensure the timely identification and management of potential risks.

Article 8 – Information on the Rights and Obligations of Employees and the Company “THEODOROS DIMITROULAKOS S.A.” in the Event of an Incident, Report or Complaint, and on the Relevant Procedure

If a person is affected by an incident of violence and harassment when accessing employment, during their employment relationship or cooperation with the Company “THEODOROS DIMITROULAKOS S.A.”, or even after the employment contract or relationship with the Company, in the context of which the incident or behaviour allegedly occurred, has ended, that person shall have the following rights:

a) The right to submit an internal report or complaint to the Company “THEODOROS DIMITROULAKOS S.A.”, in accordance with the complaint-receiving and management procedure provided for herein.

b) The right to appeal to the Labour Inspectorate, submit a complaint and request the initiation of a labour dispute resolution procedure, within the scope of its statutory powers.

c) The right to submit a report to the Greek Ombudsman, within the scope of its statutory powers as the body responsible for promoting and monitoring the principle of equal treatment.

d) The right to seek judicial protection.

Any person covered by this Policy who experiences an incident of violence and harassment against them shall have the right to leave the workplace for a reasonable period of time, without loss of salary or any other adverse consequence, provided that, in their reasonable belief, there is an imminent serious risk to their life, health or safety.

This right shall apply particularly where the perpetrator of such behaviour is a person exercising managerial authority or representing the Company “THEODOROS DIMITROULAKOS S.A.”, or where the Company fails to take the necessary and appropriate measures to restore a peaceful working environment, or where such measures are insufficient to put an end to the violent or harassing behaviour.

In such cases, the affected person is required to notify the Company’s Liaison Officer in writing in advance, describing the incident of violence or harassment and the circumstances justifying their belief that there is an imminent serious risk to their life, health or safety.

If the risk no longer exists or has ceased to exist and the affected person refuses to return to the workplace, the Company “THEODOROS DIMITROULAKOS S.A.” may refer the matter to the Labour Inspectorate, requesting the resolution of the dispute, in accordance with the provisions of Article 18 of Law 4808/2021, as amended and in force from time to time.

Contact Details of the Competent Administrative Authorities to Which Any Affected Person May Refer

a) Labour Inspectorate (SEPE):

The contact details of the Regional Labour Relations Inspectorates are available at the following link:

https://www.sepenet.gr/liferayportal/documents/20181/55607/SEP E+email-phones+catalog+072021.pdf

A telephone complaints service operated by the Labour Inspectorate is also available through the Citizens’ Service Line: 1555.

b) Greek Ombudsman:

17 Chalkokondyli Street, 10432 Athens, Greece.

Email: press@synigoros.gr

Tel.: (+30) 213 1306 600.

c) Immediate psychological support and counselling service for women victims of gender-based violence:

SOS Helpline: 15900.

Article 9 – Appointment of a Designated Contact Person (“Liaison Officer”) and Contact Details

For the purposes of this Policy, SOTIRIOS DIMITROULAKOS is appointed as the designated contact person (the “Liaison Officer”).

Tel.: 22620-59925

Email: sotiris@dimitroulakos.gr

In this capacity, the Liaison Officer is responsible for providing guidance and information to persons covered by this Policy regarding the prevention and management of violence and harassment in the workplace, regardless of whether they approach the Liaison Officer in connection with a specific incident or complaint of violence or harassment.

The decision as to whether Management should be informed shall rest with the Liaison Officer.

Furthermore, the Liaison Officer is required to ensure the protection of Personal Data that may come to their knowledge in the performance of their duties.

Additionally, KATERINA ANGELATOU is appointed as the alternate Liaison Officer.

Tel.: 2262059925

Email: office@dimitroulakos.gr

The alternate Liaison Officer shall replace the appointed Liaison Officer in the event of any impediment, conflict of interest, suspicion of bias or any other reason preventing the appointed Liaison Officer from handling the incident.

Article 10 – Protection of Employment and Support for Employees Who Are Victims of Domestic Violence Through Any Appropriate Means or Reasonable Accommodation

Following a request by an employee who is a victim of domestic violence, the Company “THEODOROS DIMITROULAKOS S.A.” may, on a case-by-case basis and taking into consideration the nature of the employee’s duties and the Company’s organisational capabilities, examine the adoption of appropriate measures aimed at supporting the employee in retaining their job and ensuring their smooth reintegration following such incidents.

This shall apply particularly in cases where the employee has minor children or children with disabilities or serious medical conditions.

Article 11 – Investigation and Examination of Complaints with Impartiality and Protection of Confidentiality and the Personal Data of Victims and Accused Persons

The Company “THEODOROS DIMITROULAKOS S.A.” and the Liaison Officer undertake to receive, and not obstruct the receipt of, investigate and promptly handle every complaint concerning an incident of violence or harassment.

They further undertake to investigate and examine the reported allegations impartially, objectively and with respect for human dignity, as well as to take immediate measures to protect the affected person.

In this context:

a) Persons submitting complaints shall be informed that their complaint has been received and shall be kept regularly updated on the progress of its examination. Upon completion of the investigation, the Company “THEODOROS DIMITROULAKOS S.A.” shall inform the complainant of the investigation’s findings.

b) The Liaison Officer, assisted, where deemed appropriate or necessary, by the Company’s legal adviser and/or other competent executives of “THEODOROS DIMITROULAKOS S.A.”, shall investigate the reported allegations and may use any appropriate means, provided that such means do not contravene the law or accepted standards of conduct.

Furthermore, where deemed appropriate or necessary, the Liaison Officer shall inform the Management of the Company “THEODOROS DIMITROULAKOS S.A.” of the complaint and the results of the relevant investigation.

c) In order to safeguard workplace harmony and the integrity of the investigation, the Company “THEODOROS DIMITROULAKOS S.A.” may, among other measures, transfer the affected person or the person against whom the complaint has been made, or modify their working hours, workplace or working arrangements, on a temporary or permanent basis, until the investigation has been completed.

e) In examining the complaint and establishing the facts alleged, the Liaison Officer may have access to the Company’s records, audiovisual material collected by the Company, where available, and other appropriate means of gathering information and evidence, including, indicatively, communicating with other employees who may be witnesses.

f) Before taking any measure or imposing any sanction, the Liaison Officer shall invite the person against whom the complaint has been made to provide an explanation, unless the Liaison Officer reasonably determines, with appropriate justification, that this is unnecessary, either because it would put the affected person at risk, because conclusive evidence exists regarding whether the act constituting the incident of violence or harassment was committed, or for any other reason.

g) If the incident also constitutes an unlawful act subject to criminal or administrative sanctions, the Liaison Officer shall cooperate with the competent authorities, including, indicatively and without limitation, judicial authorities, prosecutorial authorities, the Labour Inspectorate (SEPE) and the Greek Ombudsman.

h) The Company “THEODOROS DIMITROULAKOS S.A.” and the Liaison Officer undertake to maintain confidentiality and protect all Personal Data collected in the performance of the above duties.

Article 12 – Prohibition of Retaliation Against the Affected Person

The Company “THEODOROS DIMITROULAKOS S.A.” undertakes to comply with the prohibition of retaliation against affected persons, in accordance with Article 13 of Law 4808/2021 and the provisions of labour legislation.

In this context, any adverse treatment of an affected person that constitutes retaliatory behaviour or a countermeasure against that person as a result of submitting a complaint concerning an incident of violence or harassment is strictly prohibited.

Article 13 – Consequences in the Event of a Violation of This Policy

If it is established that an employee or any other person working for the Company “THEODOROS DIMITROULAKOS S.A.”, under any form of employment or working relationship, has violated the prohibition of violence and harassment, the Company “THEODOROS DIMITROULAKOS S.A.”, following a recommendation by the Liaison Officer or the alternate Liaison Officer, shall take the necessary, appropriate and proportionate measures against that person, as the case may be.

Depending on the seriousness of the incident, such measures may include the following, with the aim of preventing similar incidents or behaviour from occurring again:

a) Issuing a formal recommendation or warning requiring compliance.

b) Changing the person’s position, working hours, workplace or working arrangements, on a temporary or permanent basis.

c) Terminating the employment or cooperation relationship, subject to the prohibition against the abusive exercise of rights under Article 281 of the Greek Civil Code.

Article 14 – Cooperation with the Competent Authorities and Provision of Any Relevant Information Upon Request

The Company “THEODOROS DIMITROULAKOS S.A.”, the Liaison Officer and any other person responsible for receiving and managing complaints of violence or harassment shall cooperate with every competent public, administrative or judicial authority which, either acting on its own initiative or following a request submitted by an affected person, seeks information or evidence within the scope of its statutory powers.

They undertake to provide assistance and access to the relevant information and records.

For this purpose, all information and evidence collected, in any form whatsoever, shall be retained in a relevant file, in compliance with the provisions of the legislation on the protection of personal data.

Article 15 – Final Provisions

This Policy shall be communicated to all employees of the Company “THEODOROS DIMITROULAKOS S.A.” by any appropriate means and shall be displayed in the Company’s workplaces and published on the Company’s website.

This Policy may be updated at the discretion of the Company “THEODOROS DIMITROULAKOS S.A.”, including in cases where the contact details of the designated responsible persons change, in order to ensure compliance with the legislation in force from time to time.

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INCIDENT REPORTING FORM – VIOLENCE / SEXUAL HARASSMENT

Download the incident reporting form here.

Download our complete Policy here.