POLICY AGAINST VIOLENCE AND HARASSMENT IN THE WORKPLACE OF THE PUBLIC LIMITED COMPANY “ZANAE – BAKERY YEASTS NIKOGLΟU S.A.”

(According to Law 4808/2021 and Ministerial Decision 82063/2021)

CONTENTS

  1. Introduction Page 1

  2. Chapter A: Prevention and Combat of Violence and Harassment in the Workplace Page 5

  3. Chapter B: Complaint Submission and Investigation Procedure Page 7

  4. Annex – Nationwide External Information Sources Page 10

Ι. INTRODUCTION

1) Integrity and respect for all contribute to our success, are of vital importance, and form an integral part of our corporate environment. We have created a workplace where every employee’s personality is valued, and equal opportunities for growth and development are provided. Our corporate social policy is based on human rights, which set the minimum working standards and complement our corporate values.

ZANAE S.A. (hereinafter: “the Company”) declares that it complies with all measures and obligations regarding the implementation of the provisions of Part II of Law 4808/2021 and the relevant Ministerial Decision 82063/2021 for the prevention and addressing of all forms of violence and harassment. The Company expresses its commitment to combating and eliminating violence and harassment in the workplace, ensuring an environment where human dignity is respected. It is explicitly and categorically stated that all forms of violence and harassment occurring during work, related to it, or arising from it are strictly prohibited.

2) The purpose of this policy is to create and establish a working environment that respects, promotes, and ensures human dignity and the right of every individual to a workplace free from violence and harassment. The Company recognizes and respects the right of every employee to a workplace without violence and harassment and does not tolerate any such behavior of any kind, from any person.

3) This policy is adopted under Articles 9 and 10 of Law 4808/2021 and its implementing regulations and applies to the individuals referred to in paragraph 1 of Article 3 of Law 4808/2021.

4) Scope of Application

This policy applies to all personnel associated with the Company in any capacity, including:

  • Employees under indefinite or fixed-term contracts, full-time or part-time,

  • Contracted workers,

  • Seconded staff from EU member states or third-country nationals,

  • Independent service contractors,

  • Employees under paid mandate contracts,

  • Apprentices,

  • Loaned employees,

  • Workers engaged through third-party service providers,

  • Volunteers,

  • Job applicants,

  • Former employees whose employment relationship with the company has ended.

Definitions

VIOLENCE AND HARASSMENT refer to behaviors, acts, practices, or threats thereof that aim to, lead to, or may lead to physical, psychological, sexual, or economic harm, whether occurring as isolated incidents or repeatedly. Harassment also includes behaviors intended to violate a person’s dignity and create an intimidating, hostile, degrading, humiliating, or offensive environment, regardless of whether they constitute discrimination, including harassment based on gender or other discriminatory factors.

PROHIBITED HARASSMENT includes but is not limited to:

Verbal harassment, such as abusive comments, insults, or accusations.

Physical harassment, such as interfering with an individual’s normal work or movement.

Visual harassment, including posters, cartoons, photos, or drawings that demean individuals based on legally protected characteristics.

Retaliation or intimidation for reporting or threatening to report harassment or for cooperating in the investigation of harassment incidents.

SPECIFIC FORM OF HARASSMENT: Gender-Based Harassment and Sexual Harassment

Gender-based harassment and sexual harassment refer to behaviors linked to a person’s gender that aim to violate their dignity and create an intimidating, hostile, degrading, humiliating, or offensive environment. These behaviors include sexual harassment and actions related to sexual orientation, gender expression, gender identity, or gender characteristics. Sexual harassment is defined as unwanted conduct of a sexual nature, including unwelcome sexual advances, requests for sexual favors, and any other verbal or physical act of a sexual nature. Such behavior can be exhibited by a person of any gender toward a person of any gender. Examples of Sexual Harassment:

  • Offering benefits (e.g., promotions or salary increases) in exchange for sexual favors or fostering an environment that promotes “sexual relations” as a means of career advancement in the workplace.

  • Retaliation or threats of retaliation after rejecting sexual advances.

  • Visual behavior: obscene gestures, the display of sexually offensive electronic or printed materials (e.g., emails, social media comments, files, photos, cartoons, posters, or any material with obscene or sexual implications).

  • Verbal behavior: derogatory remarks, sexual innuendos, the use of sexualized language, or sexually explicit “jokes.”

  • Verbal sexual harassment or propositions.

  • Verbal abuse of a sexual nature: sexual comments about a person’s body, the use of sexually degrading language to describe someone, sexually suggestive or obscene comments in conversations, letters, invitations, notes, or other remarks.

  • Physical contact: pinching, sexually suggestive gestures, hitting, grabbing, pushing, etc.

The above examples are indicative and do not constitute an exhaustive list of prohibited actions. Any employee or third party engaging in such prohibited behavior will be held fully accountable for their actions. Indicative Examples of Violence/Harassment Incidents:

  • Innuendos, mockery, obscene, sexual, or racist jokes or comments.

  • The use of offensive language.

  • Comments about someone’s appearance or character that cause embarrassment or discomfort.

  • Stalking and unwanted verbal or physical attention toward someone.

  • Sending sexually explicit messages via SMS, email, or social media.

  • Offensive and persistent questions about someone’s age, marital status, personal life, sexual interests or preferences, as well as similar questions regarding their race, ethnicity, cultural identity, or religion.

  • Sexual gestures or persistent dating proposals.

  • Implying that sexual favors can advance someone’s career or that refusing a sexual relationship could negatively impact their professional growth.

  • Rude gestures, any form of unwanted physical contact.

  • Spreading malicious rumors or insulting someone, particularly based on discrimination related to age, gender, marital status, civil partnerships, pregnancy, motherhood, disabilities, sexual preferences, religion, or beliefs.

  • Verbal or gestural threats.

  • Public or private insults.

  • Undermining or ridiculing a person or their abilities, either privately or in front of others.

  • Outbursts of anger directed at someone.

  • Persistent or unjustified criticism.

  • Cyberbullying, offensive electronic messages, and phone calls.

II. CHAPTER A:

PREVENTION AND COMBATING OF VIOLENCE AND HARASSMENT IN THE WORKPLACE

  1. Assessment of Risks of Violence and Harassment in the Workplace

Acts of violence and harassment may take place particularly: (a) in any area of the Company, including locations where employees perform work, receive payment, take breaks—especially for rest or meals—in hygiene and care facilities, locker rooms, or accommodations provided by the Company for its staff and visitors; (b) during any type of work-related travel, training, events, and social activities linked to or associated with the Company’s operations; and (c) in communications related to work and Company activities, including those conducted via information and communication technologies.

  1. Measures for the Prevention, Control, Mitigation, and Management of Workplace Violence and Harassment Risks, as well as for the Monitoring of Such Incidents or Behaviors

The Company declares zero tolerance for any form of violence and harassment, including sexual harassment and gender-based violence, occurring in the workplace or in connection with work. This applies to conduct by employees against other employees, supervisors, authorized representatives (acting as employers), clients, visitors, suppliers, or any third party.

The Company takes all appropriate and necessary measures to both prevent and address such incidents and behaviors. All employees and anyone connected with the Company in any capacity are required to comply with this policy.

The Company ensures a safe and supportive work environment where relationships among employees, partners, and management are characterized by mutual respect, politeness, honesty, understanding, trust, and dignity.

Within its capabilities, the Company takes all reasonable measures and adapts working conditions as necessary to protect employment and support employees. The Company also undertakes all necessary steps to inform and raise awareness among its staff by utilizing appropriate means (e.g., printed and electronic materials) to combat violence and harassment. It ensures that all employees are aware of its policy on workplace violence and harassment and know where to turn in case of an incident.

The Company encourages employees and any third parties associated with it to report incidents of workplace violence and harassment they witness. It imposes necessary and appropriate sanctions on any employee, client, visitor, or supervisor found to have engaged in prohibited behavior.

  1. Actions for Staff Awareness and Sensitization

Such actions include sending emails with informative materials, posting this Policy on company bulletin boards, publishing it on the Company’s website, informing employees about their rights, and educating those responsible for implementing and enforcing the Policy.

  1. Information on the Rights and Responsibilities of Employees, Employers, and Individuals Exercising Managerial Authority or Representing the Employer, as well as the Relevant Procedures

Employee rights have already been communicated through consultations between the Company’s Management and the Employee Union, which represents the entire workforce, regarding the draft Policy on Workplace Violence and Harassment. This consultation process resulted in the final version of the Policy.

Further employee awareness is ensured through the posting of this Policy on the Company’s bulletin board and website, as well as through verbal communication by Department Supervisors and Directors on an ongoing basis.

The responsibility for this awareness initiative is shared between the Company’s Management, Department Supervisors and Directors, and the Human Resources (HR) Department. This awareness includes information about the Complaint Reception and Investigation Process, as well as the general obligations of the Company and those exercising managerial authority or representing the employer.

  1. Designation of a Reference Person (“Liaison”) for Employee Guidance and Information on the Prevention and Management of Workplace Violence and Harassment

The reference person responsible for guiding and informing employees regarding the prevention and management of workplace violence and harassment is the Head of the Human Resources (HR) Department of the Company (e-mail: hr@zanae.gr).

Additionally, the Company’s legal advisors assist in providing guidance and support.

  1. Protection of Employment and Support for Employees Who Are Victims of Domestic Violence

The Company fully supports its employees who are victims of domestic violence. Employees experiencing domestic violence may inform one of the designated individuals listed in Section III.i. (as indicated below).

III. CHAPTER B: PROCEDURE FOR FILING AND HANDLING INTERNAL COMPLAINTS – REFERENCE PERSON

  1. Filing and Handling Complaints/Reports

Any employee who has experienced an incident of violence or harassment may submit a verbal or written complaint to the Head of the Human Resources (HR) Department, who is designated as the reference person for this policy. Complaints may be submitted in person or via email to hr@zanae.gr. Anonymous complaints are not permitted. The complaint must include the identity of the alleged perpetrator, details of the incident(s), and any supporting evidence. The HR Head will thoroughly investigate each complaint, collecting all necessary information. Complaints and investigations remain strictly confidential to the maximum possible extent, considering the sensitivity of the matter and the privacy of all involved parties.

During the investigation, the HR Head may:

  • Interview the complainant and the accused.

  • Examine witnesses and request documents that could support or refute the allegations.

  • Communicate with department supervisors if the complainant initially reported the incident to them.

Upon completing the investigation, the HR Head submits a written report to the Company’s Management with the findings. The results are also communicated to both the complainant and the accused. The investigation should be completed as soon as possible, and in any case, within one (1) month from the complaint submission date.

Record-Keeping

A written record of all reports and actions taken must be maintained in physical or digital form. The HR Department is responsible for record-keeping.

  1. Investigation and Confidentiality Protection

A secure process is followed for exchanging information between involved employees and stakeholders. Everyone involved in handling complaints must maintain discretion and confidentiality, complying with data protection laws. All personnel involved in complaint handling receive training on:

  • Data protection obligations.

  • The Company’s Data Protection Policy.

  1. Prohibition of Retaliation Against the Complainant

No employee shall face negative consequences for filing a complaint or assisting in an investigation—unless the complaint is proven to be knowingly false and malicious. Employees are protected from retaliation, including:

  • Victimization

  • Adverse treatment

  • Detrimental changes in their employment conditions

If an employee believes they have been retaliated against for reporting or participating in an investigation, they must immediately inform the HR Department, which is responsible for ensuring their protection. The Company expressly commits to a zero-tolerance policy regarding retaliation.

  1. Consequences of Policy Violations

If the investigation confirms an incident of violence, harassment, or retaliation, the Company will take appropriate disciplinary or corrective measures, which may include:

  1. Warnings or reprimands

  2. Disciplinary actions

  3. Changes in job position, schedule, location, or work arrangement

  4. Termination of employment or contract

  5. Legal action

The offender may also face criminal or civil liability as per applicable laws.

  1. Cooperation with Authorities

The Company informs employees that filing a report through internal procedures does not limit their right to file a formal complaint with the relevant authorities. The reference person (liaison) is always available to provide any necessary information to public authorities regarding this policy and its enforcement. The Company fully cooperates with law enforcement, regulatory, or judicial authorities if requested.

This policy is formulated in accordance with Law 4808/2021 and Ministerial Decision 82063/2021, as applicable.

  1. Cases of Domestic Violence

The Company takes all possible measures to protect the employment and support employees who are victims of domestic violence. Employees affected by domestic violence, particularly if it impacts their workplace, may report it verbally or in writing to their supervisor or the HR Head, allowing the Company to take the necessary supportive actions.

  1. Policy Compliance and Exceptions

No exceptions to this policy are permitted. For further information or clarifications, employees may contact the HR Head.

This policy is available on the Company’s official website: www.zanae.gr.

  1. APPENDIX – External Nationwide Support Resources

  1. Contact Information for Authorities (General Cases of Violence and Harassment)

  • SEPE Complaint Hotline: Call 1555 (24/7)

  • Hellenic Police: Call 100 (24/7)

  1. Domestic Violence Cases

  • Call 100 (24/7)

  • If you cannot speak, send an SMS to 100

  • Visit the Hellenic Police’s domestic violence website: http://www.astynomia.gr/index.php?option=ozocontent&perform=view&id=2030&Itemid=421&lang

  • Call 15900 (24/7)

  1. General Secretariat for Demographic and Family Policy and Gender Equality (G.G.I.F.)

  • Call 15900 (24/7)

  • Email: sos15900@isotita.gr

  1. Useful Websites

  • https://isotita.gr
  • http://womensos.gr