ATRON HEALTH WORKER VIOLENCE AND HARASSMENT PREVENTION AND COMBAT POLICY

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TABLE OF CONTENTS

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1. Introduction

2. Definitions

3. Scope

4. Purpose

5. Preventing and combating violence and harassment at work

6. Procedure for receiving and examining complaints

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1. Introduction

Atron Health based in Galatsi (8 Veikou Avenue and 2 Lesvos Street), with VAT number 800519113 (hereinafter “Company”) complies with all measures and obligations related to the implementation of the provisions of Part II of Law 4808/2021 to prevent and address all forms of violence and harassment, including gender-based violence and harassment and sexual harassment.

2. Definitions

“VIOLENCE AND HARASSMENT”: the forms of behavior, acts, practices or threats thereof, which are intended, lead or may lead to physical, psychological, sexual or financial harm, whether manifested individually or repeatedly.

“Harassment”: the forms of behavior, which have the purpose or effect of violating the dignity of the person and creating an intimidating, hostile, humiliating, humiliating or aggressive environment, regardless of whether they constitute a form of discrimination, and

they also include harassment based on gender or for other reasons of discrimination.

“GENDER HARASSMENT”: forms of behavior linked 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 aggressive environment, including sexual harassment; as well as forms of behavior linked to the person’s sexual orientation, expression, identity or gender characteristics.

3. Scope

This policy is adopted in accordance with art. 9 and 10 of Law 4808/2021 and the applicable regulatory legislation and occupies the persons of art. 3 § 1 of Law 4808/2021, i.e. all those who had, have, wish or are going to provide their services to the Company, regardless of their contractual relationship.

For the purposes of implementing this Policy, forms of violent and harassing behavior may take place in particular:

– in the workplace, including public and private spaces and spaces where the employee provides work, receives remuneration, takes a break in particular, for rest or for food, in areas of personal hygiene and care, changing rooms or accommodation provided by the employer,

– commuting to and from work, other commuting, travel, education, as well as work-related events and social activities and

– during work-related communications, including those carried out through information and communication technologies.

This Policy is applied in conjunction with the Company’s other Policies and instructions to its employees/partners.

4. Purpose

The purpose of this Policy is to create and consolidate a work environment that respects, promotes and ensures human dignity and the right of every person to a work world free of violence and harassment. The Company declares that it recognizes and respects the right of every employee to a work environment free of violence and harassment and that it does not tolerate any such behavior, of any form, by any person.

5. Preventing and combating violence and harassment at work

a) ASSESSMENT OF THE RISKS OF VIOLENCE AND HARASSMENT AT WORK

The Company assesses the risks of violence and harassment at work, taking into account any inherent risks stemming from the nature of the activity, the job position, factors such as gender and age or other characteristics that constitute reasons for discrimination, as well as risks concerning special groups of workers (eg new hires, night workers).

b) MEASURES TO PREVENT, CONTROL, LIMIT AND ADDRESS THESE RISKS, AS WELL AS MONITORING SUCH INCIDENTS OR CONDUCT

The Company demonstrates zero tolerance for violence and harassment, operating with confidentiality and respecting human dignity. In more detail, the Company:

– encourages the maintenance of a working climate, where respect for human dignity, cooperation and mutual assistance are key values,

– observes a report/complaint management procedure,

– carries out actions to raise employees’ awareness of healthy behavior patterns, to support victims of violence and harassment and to reintegrate victims of domestic violence into the workplace,

– takes technical measures in its facilities to prevent risks, such as adequate lighting of the premises,

– trains its staff in violence incident management procedures,

– evaluates and updates relevant preventive and countermeasures.

c) STAFF INFORMATION AND SENSITIZATION ACTIVITIES

The Company carries out actions to inform and raise awareness of the staff regarding the possible risks of violence and harassment in the workplace and the relevant prevention and protection measures for such incidents. As part of staff awareness, targeted meetings are organized to discuss relevant issues and address potential risks in a timely manner. In addition, the participation of management executives and employee representatives in training seminars on the recognition and management of risks of violence and harassment at work is encouraged.

d) INFORMATION ON THE RIGHTS AND OBLIGATIONS OF THE EMPLOYEES AND THE EMPLOYER, AS WELL AS THE PERSONS EXERCISE THE RIGHT OF MANAGEMENT OR REPRESENT THE EMPLOYER, TO THEIR EXTENT AND DEGREE

RESPONSIBILITY, IN CASE OF OCCURRENCE OR REPORTING OR REPORTING OF SUCH INCIDENTS, AS WELL AS FOR THE RELATED PROCEDURE

Any person affected by an incident of violence or harassment during access to employment, during the employment relationship or even if the contract or employment relationship in the context of which the incident or conduct allegedly occurred has ended, has the following rights:

– judicial protection,

– appeal, submission of a complaint and application for a labor dispute to the Labor Inspectorate within the framework of its legal powers,

– reference to the Ombudsman within the scope of his statutory powers and

– complaint within the company, retaining in any case the right of appeal to any competent authority.

CONTACT DETAILS OF THE COMPETENT AUTHORITIES

Ombudsman Line: 213 13 06 600 (e-mail: press@sinigoros.gr), Labor Inspection Line: 1555 (e-mail: helpdesk@sepenet.gr) and SOS Line 15900 for immediate psychological support and counseling of female victims of gender violence.

(Regarding the procedure for reporting or denouncing incidents of violence or harassment, see Chapter 6 of this Policy.)

e) APPOINTMENT OF A REFERENCE PERSON (“LINK”) TO GUIDE AND INFORM EMPLOYEES REGARDING THE PREVENTION AND COMBATATION OF VIOLENCE AND HARASSMENT AT WORK

The Company designates as a reference person (“link”) within the company, competent to guide and inform employees on the prevention and treatment of violence and harassment at work, regardless of whether they contact him on the occasion of an incident or complaint about an incident of violence and of harassment, Mr. Roumeliotis Constantinos, to whom employees can contact for the relevant issues (phone number 6972007486 and e-mail address mobbing@atronhealth.gr). The reference person is bound by a Declaration of Confidentiality and Confidentiality regarding the personal data that may come to his knowledge during the exercise of his said duties.

f) EMPLOYMENT PROTECTION AND SUPPORT FOR WORKING VICTIMS OF DOMESTIC VIOLENCE, TO THE EXTENT POSSIBLE, WITH EVERY OFFER THROUGH REASONABLE ACCOMMODATION

The Company ensures the protection of employment and the support of working victims of domestic violence, whenever possible, by any appropriate means or reasonable adjustment, such as indicatively with flexible work arrangements following the request of an working victim of domestic violence.

6. Procedure for receiving and examining complaints

a) COMMUNICATION CHANNELS – COMPETENT PERSONS

The Company guarantees secure and easily accessible communication channels for receiving and examining complaints and informing complainants and facilitates the relevant procedures. In particular, the competent person who will receive, examine and manage the complaints or complaints of the affected persons for violent or harassing behavior is designated Mr. Roumeliotis Konstantinos. The relevant communication will be made at the e-mail address

mobbing@atronhealth.gr. In any case, the affected person will be informed, at any stage of the procedure followed within the Company, of the possibility of submitting an additional complaint to the competent administrative authorities within their competence (Labour Inspectorate and Ombudsman), as well as to judicial authorities of his choice.

b) INVESTIGATION AND EXAMINATION OF COMPLAINTS WITH IMPARTIALITY AND PROTECTION OF THE CONFIDENTIALITY AND PERSONAL DATA OF VICTIMS AND COMPLAINTS

Complaints are received, investigated and handled promptly and impartially, in a manner that respects human dignity and ensures the protection of confidentiality and personal data of victims and complainants.

c) PROHIBITION OF RETALIATION AT THE WEIGHT OF THE Aggrieved Person

The Company undertakes to comply with the obligation to prohibit retaliation, in accordance with art. 13 of Law 4808/2021 and the provisions of the labor legislation.

d) DESCRIPTION OF THE CONSEQUENCES UPON IDENTIFICATION OF VIOLATIONS

In the event of a violation being established, the Company takes the necessary, appropriate and proportionate measures against the complainant, in order to prevent and prevent a similar incident or behavior from repeating itself. These measures include, indicatively, the recommendation of compliance, the change of position, change of hours, change of place or method of providing work or the termination of the employment or cooperation relationship, subject to the prohibition of the abuse of the right of art. 281 AK.»