Policy for the Prevention and Combating of Violence and Harassment at Work

I hereby certify that:

1. ATHENS VISION S.A. observes all measures and obligations relating to the implementation of the provisions of Part II of Law 4808/2021 on the prevention and handling of all forms of violence and harassment, including gender-based violence and harassment and sexual harassment.
2. 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 person to a world of work free from violence and harassment. ATHENS VISION S.A. declares that it recognizes and respects the right of every employee to a working environment free from violence and harassment, and that it does not tolerate any such behavior, in any form, by any person.
3. This policy is adopted in accordance with Articles 9 and 10 of Law 4808/2021 and the implementing regulations, and covers the persons referred to in paragraph 1 of Article 3 of Law 4808/2021.

A. Prevention and combating of violence and harassment at work

(a) Assessment of the risks of violence and harassment at work.

The risk is assessed as minimal, owing to long-standing employment relationships, the layout of the premises, the nature of the medical procedures, and the number of people who share each space.

(b) Measures for the prevention, control, limitation and handling of these risks, and for monitoring such incidents or forms of behavior.

Informing shareholders, external collaborators and employees; a procedure for handling any complaints; updating the risk assessment and the measures.

(c) Information and awareness-raising actions for staff.

Sending Law 4808/2021 and this policy to everyone by email, posting the policy on the company’s notice board, and publishing it on our website.

(d) Information on the rights and obligations of employees and the employer, as well as of persons who exercise managerial authority or represent the employer, to the extent and degree of their own responsibility, in the event of the occurrence, reporting or complaint of such incidents, and on the relevant procedure.

The employer and those exercising managerial authority are informed of their rights and obligations, and of those of employees. Subsequently, everyone is informed by the company’s General Manager.

(e) Designation of a reference person (“liaison”) to guide and inform employees on the prevention and handling of violence and harassment at work.

• Ms. Argyro Karkoulia, the longest-serving member of the company’s staff, is designated as the “liaison” for employees.
• The company’s General Manager is designated as the “liaison” for shareholders and external collaborators.

(f) Protection of employment and support for employees who are victims of domestic violence, as far as possible, by every appropriate means or reasonable adjustment.

The company provides flexible working arrangements, at the request of an employee who is a victim of domestic violence, to support them in keeping their job and in their smooth reintegration after such incidents, provided that the staffing of their department and the operational needs of the company permit.

B. Procedure for receiving and examining complaints

(a) Communication channels – responsible persons

• The “liaison” for employees.
• The “liaison” for shareholders and external collaborators.
• The company’s Chief Executive Officer.
• The Board of Directors.

Complaints are received by the respective “liaisons,” in writing or electronically, marked “CONFIDENTIAL.” The same persons examine the complaints and collect any evidence. They forward this material, together with their reasoned opinion, marked “CONFIDENTIAL”:

• to the General Manager, for employees, and
• to the Chief Executive Officer, for shareholders and external collaborators.

(b) Investigation and examination of complaints with impartiality, and protection of the confidentiality and personal data of victims and of the persons complained against.

The company has a Privacy Policy and clauses and procedures for compliance with the General Data Protection Regulation (GDPR), and has designated its senior executives as liaisons.

(c) Prohibition of retaliation against the affected person.

The company undertakes not to take any form of retaliation against the affected person who made the complaint, such as dismissal or termination of the employment relationship in any manner, or any other adverse treatment of that person, where it constitutes vindictive behavior or a counter-measure within the meaning of Article 14 of Law 3896/2010 (Government Gazette A’ 207), in relation to an incident of violence and harassment under Article 4.

(d) Description of the consequences when violations are established.

If the General Manager (for complaints by employees) or the Chief Executive Officer (for complaints by shareholders and external collaborators) is persuaded of the merits of a complaint, they recommend to the Board of Directors that measures be taken. The Board of Directors decides whether to impose a sanction, and its severity. For employees who are the subject of a complaint, it decides within the framework of existing labor legislation. For shareholders and external collaborators who are the subject of a complaint, it decides in accordance with the existing Articles of Association or the company’s contractual obligations. Indicative sanctions include a recommendation to comply, a change of position, working hours, place or manner of work, or termination of the employment or collaboration relationship.

(e) Cooperation and provision of any relevant information to the competent authorities, if requested.

The company undertakes to cooperate and to provide any relevant information to the competent authorities that are permitted, under existing personal data legislation, to receive data of this nature and that take up the relevant cases, either ex officio or at the request of an affected person. For this purpose, the company undertakes to keep, in a dedicated file, all data it collects, in any form.