PART A: General Provisions

1. Introduction:

The company under the name “REVITUP LTD”, located at 4 Athanasiou Kampeli Street, Postal Code 71304, with Tax Identification Number (TIN): 996975326, legally represented by Mr. Minas Liapakis, complies with all measures and obligations concerning the implementation of the provisions of Part II of Law 4808/2021 for the prevention and combatting of all forms of violence and harassment, including gender-based violence and harassment, as well as sexual harassment.

2. Purpose:

This policy aims to create and maintain a working environment that promotes respect, dignity, and the right of every employee to a workplace free from violence and harassment. Η “REVITUP LTD” expressly declares that it acknowledges and respects the right of every member of its personnel to a safe and healthy work environment and condemns all forms of violence or harassment, regardless of their source or nature. This policy is adopted pursuant to Articles 9 and 10 of Law 4808/2021 and the relevant implementing legislation, and it applies to the persons referred to in paragraph 1 of Article 3 of Law 4808/2021.

3. Scope:

This policy, as stated above based on paragraph 1 of Article 3 of Law 4808/2021, applies to and concerns all employees and workers of “REVITUP LTD”, regardless of their contractual status. This includes individuals employed under a project-based contract, independent services, paid mandates, individuals employed through third-party service providers, as well as trainees, including interns and apprentices, volunteers, former employees whose employment relationship has ended, job applicants, and persons working in the informal economy.

Forms of violent and harassing behavior against any of the above-mentioned individuals may occur in particular:

  • in the workplace, including public and private spaces and premises where the employee performs work, receives payment, takes breaks—especially for rest or meals—as well as hygiene and care facilities provided by “REVITUP LTD”
  • during commuting to and from work, other business-related travel, training, events, and social activities related to work; and
  • during work-related communications, including those carried out through information and communication technologies.

4. Definitions:

For the purposes of this policy, the following definitions apply:

  • “Violence and harassment” means any forms of behavior, acts, practices, or threats thereof that are intended to, result in, or are likely to result in physical, psychological, sexual, or economic harm, whether they occur as isolated incidents or repeatedly.
  • “Harassment” means forms of behavior that have the purpose or effect of violating a person's dignity and creating an intimidating, hostile, degrading, humiliating, or offensive environment, regardless of whether they constitute a form of discrimination. This includes harassment based on gender or other discriminatory grounds.
  • “Gender-based harassment” refers to forms of behavior related to a person's gender that have the purpose or effect of violating their dignity and creating an intimidating, hostile, degrading, humiliating, or offensive environment. These behaviors include sexual harassment, as well as behaviors related to a person’s sexual orientation, gender expression, gender identity, or sex characteristics.
  • “Sexual harassment” means any form of unwelcome verbal, psychological, or physical conduct of a sexual nature that aims at or results in the violation of a person’s dignity, particularly by creating an intimidating, hostile, degrading, humiliating, or offensive environment around them.

5. Prohibition of Violence and Harassment in the Workplace:

Any form of violence and harassment that occurs during work, is related to it, or arises from it is strictly prohibited, including violence and harassment based on gender, religion, race, sexual orientation, and sexual harassment.

Specifically, and without limitation, the following behaviors are strictly forbidden:

  • Comments containing sexually explicit expressions or other malicious remarks directed at individuals who have not explicitly expressed a desire to receive such comments
  • Obscene remarks or persistent questions about a person’s appearance, gender, religion, race, or sexual orientation that cause embarrassment or discomfort
  • Circulation and/or display of sexually explicit material or any content that is offensive to human dignity or personality (e.g., photographic, digital, or printed material)
  • Unwanted comments with sexual innuendo
  • Sending sexually explicit messages
  • Sexual gestures or acts (e.g., any unwanted physical contact aimed at assaulting or pressuring someone into a sexual relationship)
  • Persistent suggestions to go on dates
  • Threats or implications that someone’s career may benefit from offering sexual favors or be negatively impacted by refusing to engage in a sexual relationship
  • Use of obscene, threatening, or offensive language, including cyberbullying
  • Obscene, threatening, violent, or offensive gestures
  • Coercion into sexual encounters or contact
  • Derogatory comments or mockery of a person or their abilities, whether in private or in front of others.

Therefore, any behavior involving violence or harassment—whether physical, verbal, non-verbal, or online—is strictly prohibited.

PART B: PREVENTION AND COMBATING OF VIOLENCE AND HARASSMENT AT WORK

1. Risk Assessment of Violence and Harassment

Risks related to violence and harassment are identified by considering the potential danger arising from the nature of the work, the job position, as well as factors such as gender, age, or other characteristics that may cause discrimination. These risks can have serious consequences both for employees and the company itself. More specifically, for employees, the risks include in particular:

  • Violation of human dignity and causing moral harm,
  • Causing anxiety, stress, anger, and fear during work performance,
  • Causing psychosomatic symptoms (such as headaches, tachycardia, increased blood pressure, sleep disorders, etc.).

At the same time, the company itself faces risks such as:

  • Disruption of working relationships and smooth operation of the company,
  • Reduced productivity,
  • Legal and financial consequences,
  • Negative publicity.

However, the prevention, control, and limitation measures for risks of violence and harassment in the workplace, as well as the procedures for monitoring and managing relevant incidents implemented by “REVITUP E.P.E.”, combined with staff awareness and training actions on these matters, the structure of work, and the nature of its activities, along with strict compliance with applicable health and safety legislation, substantially contribute to strengthening employee protection and effectively managing these risks.

2. Measures for the Prevention, Control, Limitation, and Management of Violence and Harassment Risks at Work and for Monitoring Such Incidents or Behaviors

"REVITUP LTD" ensures an accessible and safe working environment where the relationships between employees, collaborators, management, and company members are characterized by respect for human dignity, cooperation, mutual respect, and courtesy. The company also takes measures and applies administrative practices to prevent, control, limit, and manage risks of violence and harassment at work and to monitor such incidents or behaviors. Indicatively, these measures and practices include the following:

  • Adoption of a Policy for Managing Internal Complaints Regarding Incidents of Violence and Harassment, included in this document (Part C), so that every complaint or related report is received, investigated, and resolved confidentially and in a manner that respects human dignity. The company representative, Mr. Minas Liapakis, may keep a logbook of reported incidents.
  • Appointment of a contact person (“liaison”) to guide and inform employees about the prevention and management of violence and harassment at work.
  • Encouragement to maintain a workplace climate where respect for human dignity, cooperation, and mutual assistance are core values.
  • Technical measures, such as adequate lighting, installation of emergency alert systems, etc.
  • Training employees in the procedures for handling violence incidents and ensuring that employees receive the necessary training/information to perform their duties, especially in positions with a higher risk of violence and harassment incidents.
  • Actions to raise employees’ awareness of healthy behavioral standards, as well as issues concerning vulnerable categories of workers.
  • Open communication with the employer and colleagues, guidance and support for victims of violence and harassment to reintegrate into the workplace.
  • Providing assistance to any competent public, administrative, or judicial authority during the investigation of incidents of violence or harassment, when requested.
  • Regular evaluation of the effectiveness of preventive measures and response measures applied, and revision/updating of risk assessments and measures.
  • Any other appropriate and suitable measure to achieve the purposes of this policy.

3. Actions for informing and raising awareness of staff on issues of violence and harassment

"REVITUP LTD" declares its zero tolerance towards violence and harassment and undertakes the following actions to raise awareness among its personnel on these issues:

  • it provides its staff with information regarding the risks of violence and harassment, as well as related prevention and protection measures, the procedures existing at the company level, and the options available under the law in case of such incidents.
  • It may organize targeted staff meetings to discuss related topics and timely address potential risks.
  • It encourages the participation of employees and management executives in training programs and seminars related to the recognition and management of risks of violence and harassment in the workplace.

4. Information about the rights and obligations of employees and the employer, as well as persons exercising managerial authority or representing the employer, to the extent and degree of their responsibility, in case of occurrence, reporting, or complaint of incidents, as well as the relevant procedure.

Options available to those affected by incidents of violence and harassment:

In the event that a person is affected by an incident of violence or harassment during access to employment, during the employment relationship or collaboration with "REVITUP LTD" or even if the contract or employment relationship within which the incident or behavior allegedly occurred has ended, they have:

  • the right to judicial protection,
  • the right to appeal, file a complaint, and request the conduct of a labor dispute at the Labor Inspectorate within its statutory competencies,
  • the right to submit a report to the Ombudsman within its statutory competencies as a body promoting and supervising the principle of equal treatment, and
  • the right to file a report or complaint within the company according to the policy for receiving and managing complaints.

In any case, when a report or complaint of such behavior arises within the company, the affected person retains all rights to appeal to any competent authority. Furthermore, any person covered by this policy who suffers an incident of violence or harassment against them has the right to leave the workplace for a reasonable time, without loss of salary or other adverse consequences, provided that, in their reasonable belief, there is an imminent serious risk to their life, health, or safety, especially when the perpetrator is a person exercising managerial authority or representing "REVITUP LTD" or when "REVITUP LTD" does not take the necessary and appropriate measures to restore workplace peace, or when such measures are insufficient to stop the behavior of violence and harassment.

However, the prevention, control, and limitation measures of the risks of violence and harassment in the workplace, as well as the monitoring and management procedures applied by "REVITUP LTD", combined with the actions for informing and raising awareness of the staff regarding these issues, the work structure, and the nature of its activity, as well as consistent compliance with applicable health and safety legislation at work, significantly contribute to enhancing employee protection and effectively managing related risks. In the event such an incident arises, the employee who leaves is obliged to notify in advance the responsible reference person in writing, describing the incident of violence or harassment and providing evidence supporting their assessment that there is a serious risk to their life, health, or safety. If the risk no longer exists or has ceased and the affected person refuses to return to the workplace, "REVITUP LTD" reserves the right to refer the matter to the Labor Inspectorate with a relevant request.

5. Contact details of competent administrative authorities to which any affected person has the right to appeal

"REVITUP LTD" maintains in a visible place the contact details of the competent administrative authorities to which any affected person has the right to appeal, namely:

  • Labor Inspection Body (SEPE): SEPE complaint hotline: 15512, as well as the citizen service line: 1555 and https://1555.gov.gr/
  • Ombudsman (Synigoros tou Politi): Chalkokondyli 17, 10432 Athens, E-mail: press@synigoros.gr Tel: (+30) 213 1306 600
  • Immediate psychological support and counseling service for women victims of gender-based violence: SOS line 15900.
  • Additionally, the website https://metoogreece.gr, under the auspices of the General Secretariat for Demographic and Family Policy and Gender Equality (Ministry of Labor and Social Affairs), created to gather all necessary information on sexual harassment and violence, as well as actions for prevention and combating such behaviors. This site includes phone numbers for information and reporting sexual violence and harassment incidents, whether occurring at the workplace or other social settings.

6. Appointment of a contact person ("Liaison") for the guidance and information of employees regarding the prevention and handling of violence and harassment at work

Any employee who experiences any incident of violence or harassment may submit a verbal or written complaint, either in person or by email, to the Company Representative, Mr. Minas Liapakis, appointed as the contact person ("liaison")..

Contact details:

The complaint should include the details of the accused person—that is, the individual who committed the prohibited behavior—and specify the incident that constitutes the complaint.

Within his responsibilities, the contact person is responsible for thoroughly investigating each complaint, collecting all necessary evidence, as well as guiding and informing employees covered by this policy on the prevention and handling of violence and harassment in the workplace, either following a specific complaint or proactively. The decision to inform Management is at the discretion of the Liaison, following the evaluation of each case. Moreover, the contact person is responsible for ensuring the protection of Personal Data that may come to his knowledge while performing his duties.

7. Employment protection and support for employees who are victims of domestic violence by all appropriate means or reasonable accommodation

"REVITUP LTD", as a demonstration of its social responsibility towards the phenomenon of domestic violence, may, upon request of an employee victim of domestic violence, examine on a case-by-case basis, taking into account the nature of the employee’s duties and the company’s organizational capabilities, the adoption of appropriate measures aimed at supporting the employee in maintaining their employment and facilitating their smooth reintegration after such incidents—especially in cases where there are minor children or children with disabilities or serious illnesses (e.g., adoption of flexible work arrangements, etc.).

PART C: PROCEDURE FOR RECEIVING AND EXAMINING COMPLAINTS

1. Communication channels – responsible persons

As detailed above in Part B, subsection 6, the company representative, Mr. Minas Liapakis, is designated as the responsible contact person for receiving, examining, and managing complaints or grievances by affected persons regarding behaviors of violence or harassment.

2. Investigation and examination of complaints with impartiality and protection of confidentiality and personal data of victims and accused

The company and the contact person commit to receiving (and not obstructing the receipt of), investigating, and promptly handling every complaint about an incident of violence or harassment. They will investigate the allegations impartially, objectively, and with respect for human dignity, and will take immediate measures to protect the affected person.

In this context:

  • Complainants will be informed upon receipt of their complaint and regularly updated on the progress of the investigation. Upon completion, "REVITUP LTD" will notify the complainant of the investigation results.
  • If possible, the contact person will attempt to resolve the incident amicably before escalation.
  • To safeguard workplace peace and the integrity of investigations, "REVITUP LTD" may, among other actions, transfer the affected or accused person or modify their work hours, location, or manner of work until the investigation concludes.
  • During the examination of the complaint, the contact person may access company records, audiovisual materials collected by the company, and other relevant means to gather information and evidence.
  • Before any measure is taken or sanction imposed, the contact person summons the accused for a hearing, unless there is a justified reason not to do so (e.g., to avoid endangering the victim, or if there is irrefutable evidence regarding the act constituting the violence or harassment, or other reasons).
  • If the incident constitutes an illegal act subject to criminal or administrative sanctions, the contact person cooperates with the competent authorities (including but not limited to judicial, prosecutorial, Labor Inspectorate, Ombudsman, etc.).
  • "REVITUP LTD" and the contact person commit to maintaining confidentiality and protecting personal data collected during the execution of their duties.

3. Prohibition of retaliation against the affected person

Retaliation and victimization against the complainant, who as an affected person asserted their rights, is strictly prohibited. "REVITUP LTD" commits to this prohibition in accordance with Article 13 of Law 4808/2021 and labor legislation provisions. This includes any adverse treatment constituting retaliatory behavior or countermeasure against the affected person due to the filing of a complaint about violence or harassment.

4. Consequences in case of violation of this policy

If it is found that an employee or another person working under any relationship with "REVITUP LTD" has violated the prohibition against violence and harassment, "REVITUP E.P.E." will take the necessary, appropriate, and proportional measures to prevent recurrence of such incidents or behavior. These measures may include:

  • Issuance of a compliance notice,
  • Imposition of disciplinary penalties, including relevant provisions of the Company’s Work Regulations or Code of Ethics & Conduct, as applicable,
  • Change of position, working hours, workplace, or manner of work, either temporarily or permanently, or
  • Termination of employment or cooperation agreement, without prejudice to the prohibition of abuse of rights under Article 281 of the Civil Code.

Furthermore, if a complaint is deemed maliciously filed, "REVITUP LTD" reserves the right to take any lawful measures against the complainant under the employment or cooperation contract and applicable law.

5. Cooperation and provision of all relevant information to competent authorities, if requested

"REVITUP LTD" καιand any authorized person responsible for receiving and managing complaints of violence or harassment fully cooperate with competent public, administrative, or judicial authorities, whether on their own initiative or upon request by the affected person, in providing information or evidence within their jurisdiction. The company commits to providing the necessary assistance and access to relevant information. For this purpose, all collected information, in any form, is recorded and maintained in a special file in accordance with data protection legislation.

PART D: FINAL PROVISIONS

This policy is communicated to all employees of "REVITUP LTD" by all appropriate means and is posted in the workplaces, in the Shared Electronic Folder accessible to all employees, and on the company’s website. In case of any amendment to this policy, or changes to the contact persons designated for receiving and managing complaints of violence and harassment, or the designated reference person, provision is made for updating this policy accordingly.