WORTH CONSTRUCTION CONSULTING COMMERCIAL SINGLE-MEMBER LTD, demonstrating zero tolerance towards incidents of violence and harassment in the workplace, adopts this policy in compliance with Articles 9 and 10 of Law 4808/2021, which ratified International Labour Convention No. 190 of 21.06.2021 of the International Labour Organization (ILO) on the elimination of violence and harassment in the world of work, the full text of which is annexed to the Law.

1. Purpose

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 discrimination, violence and harassment. WORTH CONSTRUCTION CONSULTING COMMERCIAL SINGLE-MEMBER LTD declares that it recognises, respects and protects the right of every employee to a working environment free from violence and harassment, and that it does not tolerate any such behaviour, in any form, by any person.

2. Scope – Persons Covered

This policy covers the persons referred to in Article 3(1) of Law 4808/2021. Its scope and protection extend to all employees and persons working for WORTH CONSTRUCTION CONSULTING COMMERCIAL SINGLE-MEMBER LTD of any kind, regardless of their contractual status, including persons employed under a contract for work, independent services or salaried mandate, persons employed through third-party service providers, persons in training, including interns and apprentices, volunteers, persons whose employment relationship has ended, job applicants and any other persons who transact or cooperate with the company.

3. Prohibited Forms of Behaviour – Definitions

Violence and harassment. “Violence and harassment” means forms of behaviour, acts, practices or threats thereof that aim at, result in or are likely to result in physical, psychological, sexual or economic harm, whether they occur as a single occurrence or repeatedly.

Harassment. “Harassment” means forms of behaviour that have the purpose or effect of violating the dignity of a person and creating an intimidating, hostile, degrading, humiliating or offensive environment, regardless of whether they constitute a form of discrimination, and includes harassment on the grounds of sex or on other grounds of discrimination.

Gender-based harassment. “Gender-based harassment” means forms of behaviour related to a person’s sex which have the purpose or effect of violating that person’s dignity and creating an intimidating, hostile, degrading, humiliating or offensive environment, in accordance with Article 2 of Law 3896/2010 (Government Gazette A’ 107) and Article 2(2) of Law 4443/2016 (Government Gazette A’ 232). Such forms of behaviour also include sexual harassment within the meaning of Law 3896/2010, as well as forms of behaviour related to a person’s sexual orientation, gender expression, gender identity or sex characteristics.

Discrimination. “Discrimination” means the different treatment of people arising from prejudice or interests; any act by which people are unjustifiably separated on the basis of the groups, classes or other categories to which they belong or are perceived to belong. Examples include discrimination on the grounds of sex, age, language, nationality, race or ethnic origin, disability, religious beliefs or sexual orientation.

Incidents. The forms of behaviour prohibited by this policy include, by way of example and without limitation: insults based on sex, race, religion, appearance, sexual orientation, disability, age or other personal characteristics and choices; verbal threats or threatening gestures; insults in public or in private; belittling or ridiculing a person or their abilities, either in private or in front of others; threatened or actual physical violence; persistent or unjustified criticism. Abusive, malicious, derogatory, obscene or mocking comments and their dissemination; innuendo; sexist or racist “jokes” and comments; the use of offensive language; verbal sexual harassment or propositions; insinuations that sexual favours may advance a person’s career or that refusing a sexual relationship may adversely affect their career at the Company; offering benefits (e.g. promotion or a pay rise) in exchange for sexual favours, or creating an environment that promotes “sexual contact” as a means of professional advancement in the workplace; retaliation or threats of reprisal after sexual advances have been rejected. Cyberbullying; sending messages with harassing and offensive content by SMS, e-mail, social media, fax or letter; persistent and/or offensive questions, without legitimate reason, about a person’s age, marital status, private life or sexual orientation, as well as similar questions about race or nationality, including cultural identity and religion. Visual forms of harassment are also included, such as posters, cartoons, caricatures, photographs or drawings that are derogatory on the basis of characteristics protected by law. Unwanted physical contact such as touching, pinching, gestures of a sexual nature, hitting, grabbing, pushing, as well as physical violence of any kind. Invasion of privacy; intentional partial or total destruction of personal belongings, vehicles or property; interference with or obstruction of a person’s normal work, movement and physical integrity; physical exclusion or confinement; sexual gestures; physical surveillance; stalking. The above acts are indicative and do not constitute an exhaustive list of prohibited acts.

Legitimate behaviour.

The following behaviours do not constitute incidents of violence and harassment: The direct supervision of employees, including setting performance expectations. Taking measures to correct performance, such as placing an employee on a performance improvement plan. Assigning tasks and giving guidance on how and when they should be carried out. Requesting updates or progress reports on work. Approving or justifiably refusing leave. Requesting documentation of absence for health reasons in accordance with the applicable legislation. Moral and/or financial recognition of an employee’s excellent performance. Providing constructive feedback on work performance.

4. Scope – Definition of the Workplace

4.a. The workplace is understood as a broader spatial framework in which incidents of violence and harassment may occur. The above forms of behaviour may occur at all of the company’s premises throughout Greece where employees provide their services, as well as at places where employees are paid, take a rest or meal break, and in sanitary, washing and changing facilities. This policy also covers all commuting to and from work, other work-related travel, trips, conferences and training, as well as social events and activities related to work or connected with the company’s activities. Finally, it applies to all communications related to the company, including those carried out through information and communication technologies (e.g. e-mails, Zoom or Teams meetings, social media, etc.).

4.b. Domestic violence – All acts of physical, sexual, psychological or economic violence that occur within the family or home, regardless of biological or legal family ties, or between former or current spouses or partners, and regardless of whether the perpetrator shares or has shared the same residence with the victim. Domestic violence carried out in the workplace, for example through physical violence, sexual harassment and stalking by current or former partners, is a serious form of workplace violence. Acts of domestic violence, including stalking/surveillance, may also be committed by people in the same working environment with whom the person has (or had in the past) a close relationship. Domestic violence in any of the above forms also includes violence suffered by an employee while teleworking.

5. Assessment of the Risks of Violence and Harassment at Work

5.a. Assessment and mitigation of risk factors.

WORTH CONSTRUCTION CONSULTING COMMERCIAL SINGLE-MEMBER LTD, in cooperation with all its departments and the competent occupational physician, examines potential risk factors depending on the nature and subject of the work performed, as well as psychosocial risks, including the risks of violence and harassment at work, with the aim of assessing existing working conditions and adapting them so as to minimise, as far as possible, the likelihood of an incident of violence and harassment occurring in the workplace.

Examples of risk situations include: high stress in the workplace, isolated or enclosed workspaces, the layout of workstations, security of premises and their monitoring, lack of appropriate training, persons with a history of violent behaviour, delivery of goods or services, working alone or in an isolated area, working late at night or in the early morning hours, and domestic or personal issues spilling over into the workplace.

5.b. Organisation of seminars, publication of information material and regular staff training on violence and harassment.

All employees must understand the behaviours that constitute violence and harassment, which are unacceptable and condemned. The designated contact person for matters of violence and harassment will ensure that staff receive appropriate awareness on violence and harassment issues and will make this policy known both inside and outside the company.

6. Measures to Prevent Incidents of Violence and Harassment

6.a. Information on the rights of affected persons.

WORTH CONSTRUCTION CONSULTING COMMERCIAL SINGLE-MEMBER LTD declares that, where a person is affected by an incident of violence and harassment when accessing employment, during the employment relationship, or even after the contract or employment relationship in the context of which the incident or behaviour allegedly occurred has ended, that person has the right to:

a) judicial protection,
b) lodge an appeal, file a complaint and request the examination of a labour dispute with the Labour Inspectorate, within the scope of its legal competence,
c) submit a report to the Greek Ombudsman, within the scope of its legal competence, and
d) file a complaint within the company in accordance with the complaints management policy.

The individual procedures for submitting, handling and internally investigating reports set out the detailed steps that any complainant must take, as well as the responsibilities of the bodies of WORTH CONSTRUCTION CONSULTING COMMERCIAL SINGLE-MEMBER LTD and the actions they must take to ensure the effective handling of related incidents. In any case, where a report or complaint of such behaviour is made within the company, the affected person retains every right to apply to any competent authority. Any employee who is subjected to domestic violence that extends into the workplace may report this, orally or in writing, to their supervisor so that the company is informed and can take the appropriate and necessary measures.

6.b. Staff information, awareness and support actions.

WORTH CONSTRUCTION CONSULTING COMMERCIAL SINGLE-MEMBER LTD hereby informs its staff, and keeps displayed in a visible place, the contact details of the competent administrative authorities to which any affected person has the right to apply (Labour Inspectorate, Greek Ombudsman). In particular, it provides information on the Labour Inspectorate (SEPE) complaints line (15512), as well as the citizens’ service line 1555 and https://1555.gov.gr/, and on the immediate psychological support and counselling service for women victims of gender-based violence, who can contact the SOS Line 15900 (General Secretariat for Demography, Family Policy and Gender Equality).

WORTH CONSTRUCTION CONSULTING COMMERCIAL SINGLE-MEMBER LTD, within the limits of its capabilities, takes every appropriate measure and makes every reasonable adjustment to working conditions in order to protect the employment of, and support, employees who are victims of domestic violence. It also takes all necessary measures to inform and raise staff awareness, using the appropriate means referred to above to combat violence and harassment, ensuring that everyone is aware of the company’s policy and procedures regarding incidents of violence and harassment, knows where to turn in the event of violence or harassment, and is aware of the options available to them under the law.

WORTH CONSTRUCTION CONSULTING COMMERCIAL SINGLE-MEMBER LTD trains its managers by every appropriate means so that they can recognise discrimination, violence and harassment at work and provide the necessary support to its staff and associates. It also encourages members of management to participate in training programmes and seminars on identifying and managing potential risks of violence and harassment, and may also hold seminars with mental health professionals or providers of counselling services.

7. Procedure for Submitting and Handling Internal Complaints – Contact Person

Any employee who has been subjected to any incident of violence and harassment may submit an oral or written complaint to Ms Elena Moschou (the company’s Social Accountability Manager), who is also designated as the “contact person” for this policy. The complaint may be submitted in person or by e-mail to emoschou@worth-constructions.gr. Complaints may also be made anonymously. The complaint should state the details of the person complained against, i.e. the person who displayed a form of prohibited behaviour, as well as the specific incident(s) that constitute it.

The contact person thoroughly investigates each complaint and gathers any information necessary in relation to it. Complaints and investigations remain strictly confidential to the greatest extent possible, taking into account the sensitivity of the matter and the privacy of everyone involved.

In particular, the contact person may speak with the complainant and the person complained against, examine witnesses, request the production of any documents that may exist and that prove whether or not an incident of violence and harassment took place, and communicate with the heads of each department, if the complainant has addressed them.

Once the investigation is completed, the contact person submits a written report to the company’s Management setting out the outcome of the investigation. The results of the investigation are also communicated to both the complainant and the person complained against, so that they are informed of them. The investigation must be completed and the contact person’s findings submitted and communicated as soon as possible and in any case no later than 3 weeks from the date on which the complaint was submitted.

If an incident of discriminatory treatment, violence, harassment or retaliation is indeed substantiated, the company’s Management takes, as appropriate in each case, all necessary, suitable and proportionate measures against the person complained against.

These measures may include, by way of example:

a) a recommendation to comply,
b) a change of their position, working hours, place and manner of work,
c) termination of their employment or cooperation contract with the company, subject to the prohibition of abuse of rights under Article 281 of the Greek Civil Code.

Complaints that are shown to be manifestly malicious will be considered unacceptable and will be further investigated at the company’s discretion, both as to their motives and as to the persons involved, in order to restore order by every lawful means.

8. Rights of Affected Persons

In accordance with the applicable legislation, any person subjected to an incident of violence and harassment has the right to leave the workplace for a reasonable period of time, without loss of pay or other adverse consequences, if they reasonably believe that there is an imminent and serious danger to their life, health or safety, in particular where the employer is the perpetrator of such behaviour, or does not take the necessary appropriate measures to restore peace in the workplace, or where such measures are not capable of stopping the violent and harassing behaviour.

In this case, the person leaving must first inform the contact person in writing, describing the incident of violence and harassment and the circumstances that justify their belief that there is an imminent and serious danger to their life, health or safety.

Employees who face incidents of violence and harassment at work have the right to apply to the competent authorities, as provided by law (a. the right to judicial protection, b. the right to appeal, file a complaint and request the examination of a labour dispute with the Labour Inspectorate, within the scope of its legal competence, c. the right to submit a report to the Greek Ombudsman, within the scope of its legal competence).

9. Duty of Impartiality and Confidentiality

The contact person must act objectively and impartially throughout the complaint investigation procedure. In addition, they must treat all parties involved with respect and act in a confidential and discreet manner. The publication or disclosure to non-involved parties of any information concerning a complaint under examination is strictly prohibited. The above obligations also apply to the company’s Management at the final stage of taking measures and decisions.

10. Prohibition of Retaliation – Victimisation of the Complainant

Retaliation against and victimisation of a complainant who, as an affected person, has asserted their rights and submitted a written complaint regarding an incident of violence and harassment are prohibited. Retaliation against and victimisation of the complainant constitute a serious breach of this policy and entail consequences for the person acting in this way. If any employee or third party connected in any way with the company considers that they have been subjected to retaliatory behaviour because they submitted a complaint or assisted in the investigation of incidents of discrimination, violence and/or harassment, they must follow the above procedure to report that incident of retaliation.

11. Cooperation with Administrative and Judicial Authorities

WORTH CONSTRUCTION CONSULTING COMMERCIAL SINGLE-MEMBER LTD, as well as any person or department responsible for receiving and handling such complaints at company level, cooperate with any competent public, administrative or judicial authority which, either on its own initiative or following a request by an affected person, within the scope of its competence, requests the provision of data or information, and undertake to provide assistance and access to such data. To this end, any data they collect, in any form, is kept in a relevant file in compliance with the provisions of Law 4624/2019 (Government Gazette A’ 137) “Hellenic Data Protection Authority, measures implementing Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data”.

For more information about this policy, any interested person may contact Ms Elena Moschou (the company’s Social Accountability Manager).

On behalf of the Management
29/06/2026