1. The companies of the Life Check Group comply with all measures and obligations relating to the implementation of the provisions of Part II of Law 4808/2021 on the prevention and combating 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 every person’s right to a world of work free from violence and harassment. The companies of the Life Check Group declare that they recognize and respect every employee’s right to a work environment free from violence and harassment and that they do 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 regulatory legislation implementing them and applies to 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) Within the operating premises of the Life Check Group companies and in the context of their operation, workplaces have been created in which the personality of all employees is valued and equal opportunities for advancement and development are provided. Respect and dignity for each employee individually constitute an immediate priority of the company.

b) Each of the companies of the Life Check Group declares zero tolerance toward any incident of violence and harassment, in whatever form it may occur, including sexual harassment and gender-based violence, taking place at work or in connection with work, whether committed by an employee against another employee, by a supervisor, by an authorized person acting as the employer, by a client, visitor, supplier, or any third party.

c) The companies of the Life Check Group provide their employees with information regarding the handling and management of incidents of violence and harassment, as well as their responsibilities and rights.

d) Every employee has the right:

• to be treated with respect and courtesy,
• not to be subjected to violent behavior, harassment, including sexual and gender-based violence, adverse discrimination, and bullying,
• to report any incident of prohibited behavior in the workplace (in accordance with this policy, as analyzed below), without being victimized or suffering any adverse consequence or retaliation.

Every employee is obliged:

• to comply with this policy and all applicable and valid procedures, for both their personal protection and the protection of other persons employed by the company,
• to immediately report any incident of violence and harassment to their supervisor,
• to cooperate in the event of an investigation of any complaint submitted in accordance with the procedure set out below,
• to participate in company actions and training programs relating to incidents of violence and harassment.

In particular, company Directors and Supervisors are additionally obliged:

• to ensure the implementation of this policy within their area of responsibility,
• to establish appropriate standards of conduct within their area of responsibility,
• not to engage themselves in unwanted and prohibited behaviors in the course of performing their duties,
• to act immediately upon becoming aware of any occurrence of prohibited behavior,
• to encourage employees to report any incidents of violence and harassment that they themselves have experienced or that have come to their attention,
• to immediately inform Company Management of any incidents of violence and harassment that occurred within their area of responsibility.

e) The “reference person” for the purposes of this policy for all companies of the Life Check Group is Ms. Christianna Efthymiou, daughter of Konstantinos, with contact email address: [email protected], who provides guidance and information to employees regarding the prevention and handling of violence and harassment at work.

f) The companies of the Life Check Group take, to the extent possible and permissible, measures to protect employment and support employees who are victims of domestic violence. Any employee who has suffered domestic violence that extends into the workplace may report this fact verbally or in writing to their supervisor or to the Human Resources Director, so that the employer company is informed and, where permitted and required by the nature of the case, appropriate and necessary measures may be taken.

B. Procedure for receiving and examining complaints

a) Any employee against whom an incident of violence or harassment has occurred may submit a verbal or written complaint to the above-designated “reference person,” Ms. Christianna Efthymiou, at the following contact address: [email protected].

b) The “reference person” is obliged to act during the complaint investigation process in an objective and impartial manner. Furthermore, they must behave with respect toward all parties involved and in a confidential and discreet manner. The disclosure or communication to non-involved parties of information relating to any complaint under examination is strictly prohibited.

c) Retaliation and victimization of the complainant, who as the affected person asserted their rights and submitted a written complaint regarding an incident of violence and harassment, are strictly prohibited. Retaliation and victimization constitute a serious violation of this policy and entail consequences for the person engaging in such conduct.

d) If an incident of violence and harassment is substantiated, the Management of the competent Life Check Group company shall, on a case-by-case basis, take all necessary, appropriate, and proportionate measures against the accused person. Such measures may indicatively include:

1. Verbal or written warning.
2. Reprimand.
3. Fine of up to 25% of the daily wage or 1/25 of the employee’s monthly salary.
4. Mandatory suspension from work (leave of absence) for up to ten (10) days per calendar year, provided that the employee repeatedly commits a serious disciplinary offense.

e) In the event that the affected person has filed a complaint regarding the incident of violence and harassment with any administrative or judicial authority, the companies of the Life Check Group undertake to provide any necessary assistance and support, as well as any information they may possess, to the competent authorities.