Policy Against Violence and Harassment

POLICY FOR THE PREVENTION AND COMBATING OF VIOLENCE AND HARASSMENT AT WORK AND HANDLING OF INTERNAL COMPLAINTS ABOUT INCIDENTS OF VIOLENCE AND HARASSMENT OF THE COMPANY “ORA KESSARIS WATCH AND JEWELLERY COMMERCIAL S.A.”

The company “ORA KESSARIS WATCH AND JEWELLERY COMMERCIAL S.A.” demonstrating zero tolerance to incidents of violence and harassment in the workplace, adopts this policy, in compliance with articles 9 and 10 of Law 4808/2021, which ratified the International Labour Convention 190/21.06.2021 of the International Labour Organization (ILO), on the elimination of violence and harassment in the world of work, the text of which was annexed as such to the text of the Law.

1. Purpose

The purpose of this policy is to create and consolidate a working environment that respects, promotes and ensures human dignity and the right of every person to a world of work without discrimination, violence and harassment. “ORA KESSARIS WATCH AND JEWELLERY COMMERCIAL S.A.” declares that it recognizes, respects and protects the right of every employee in a working environment without violence and harassment and that it does not tolerate any such behavior, of any kind, by any person.

2. Scope - Covered Persons

This policy covers the persons of para. 1 of art. 3 of Law 4808/2021 and its scope of application and protection includes all kinds of employees and workers of “ORA KESSARIS WATCH AND JEWELLERY COMMERCIAL S.A.”, irrespective of their contractual status, including contract workers, providers of independent services, contracts of renumerated mandate, third-party service providers, persons in training including trainees and apprentices, volunteers, persons whose employment relationship has ended, persons seeking employment and other persons dealing with or cooperating with it.

3. Prohibited forms of behavior - Definitions

Discrimination. “Discrimination” means the difference in treatment of persons resulting from prejudice or interests, any act which unduly distinguishes individuals on the basis of the groups, classes or other categories to which they belong or are considered to belong. Indicatively, discrimination based on sex, age, language, nationality, race or ethnicity, disability, religious beliefs or sexual orientation.

Violence and harassment. “Violence and harassment” mean the forms of behavior, acts, practices or threats thereof, which aim at, lead to or are likely to lead to physical, psychological, sexual or economic harm, whether manifested individually or repeatedly.

Harassment.  “Harassment” means forms of conduct which have as their purpose or effect the violation of the dignity of the individual and the creation of an intimidating, hostile, degrading, humiliating or aggressive environment, whether or not they constitute a form of discrimination, and include harassment on the grounds of sex or for other grounds of discrimination.

Gender Harassment & Sexual Harassment.  “Gender harassment” means forms of behavior related to the gender of a person, which have as their purpose or effect the violation of the dignity of that person and the creation of an intimidating, hostile, degrading, humiliating or aggressive environment according to article 2 of Law 3896/2010 (A’ 107) and para. 2 of article 2 of Law 4443/2016 (A ' 232). These forms of behavior include the sexual harassment of Law 3896/2010, as well as forms of behaviour linked to the sexual orientation, expression, identity or sex characteristics of the individual.

Incidents.  The forms of conduct prohibited by this policy include but are not limited to: Insults based on discrimination based on sex, race, religion, appearance, sexual orientation, disability, age, or other personal characteristics and choices, threats, verbal or gesture, insults in public or in private, devaluation or ridicule of an individual or their abilities, either in private or in front of third parties, threatened or actual physical violence, persistent or unjustified criticism. Insulting, malicious, derogatory, obscene or mocking comments and their dissemination, innuendos, sexist or racist “jokes” and comments, the use of offensive language, verbal sexual harassment or suggestions, the innuendos that one's sexual graces can advance one's career or that refusing to enter into a sexual relationship may negatively affect one's professional career in the Company,  offering benefits (e.g. promotion or salary increase) in exchange for sexual graces or creating an environment that promotes “sexual intercourse” as a means of professional development in the workplace, retaliation or threat of retaliation after rejection of sexual proposals. Cyberbullying, sending messages with harassing and offensive content via SMS, e-mail, social media, fax or letter, unnecessarily persistent and/or offensive questions about age, marital status, personal life, sexual orientation, as well as similar questions about race or ethnicity, including cultural identity and religion. Also included are visual forms of harassment such as posters, cartoons, caricatures, photographs or drawings that are derogatory based on the characteristics protected by Law. Physical unwanted contact such as touches, pinches, gestures of a sexual nature, strikes, grabs, pushes as well as all kinds of physical violence. The violation of privacy, the intended partial or total destruction of personal belongings, vehicles or property, the interference or obstruction of normal work, movement and physical integrity of the individual, physical exclusion or confinement, sexual gestures, physical surveillance, stalking. The above acts are indicative and do not constitute an exclusive list of prohibited acts.

Legitimate behaviors. The following behaviors do not constitute incidents of violence and harassment:

The direct supervision of employees, including the setting of performance expectations. Taking steps to correct performance, such as placing an employee in a performance improvement plan. The assignment of tasks and guidance on how and when they should be done. The request for updates or task progress reports. The approval or justified refusal of requests for leave. The request for documentation of absence for health reasons based on the applicable legal provisions. The ethical or/and financial reward for excellent employee performance. The provision of constructive feedback on the performance of work.

Retaliation.  It is forbidden for any employee or third party, in any way connected with them, to take retaliatory actions against another employee or a third party, who opposes violence or any form of harassment, submits a complaint, testifies, assists or participates in any incident investigation process.

4. Scope - Identification of the Workplace

(a) A workplace means a wider spatial context in which incidents of violence and harassment can take place. The above forms of behavior may take place in all the company's facilities nationwide, in which employees provide their services, as well as in those places where employees receive their remuneration, take a break for rest or food, in personal hygiene and care areas, changing rooms or accommodation provided by the company to staff. Also, this policy covers all kinds of commuting to and from work, other travels, trips, conferences, education, as well as social events and activities related to work or related to the company's actions. Finally, it also applies to all kinds of communications related to the company, including those made through information and communication technologies (e.g. e-mails, zoom or teams meetings, social media, etc.).

(b) Domestic violence - All acts of physical, sexual, psychological or economic violence that take place 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 offender shares or previously 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 violence in the workplace. Acts of domestic violence, including stalking/surveillance, can also be committed by people who are in the same work environment, with whom they have (or have had in the past) close relationships. Domestic violence, under any of the above forms, that is practiced on the employee during teleworking.

5. Assessment of the risks of violence and harassment at work

(a) Assessment of risk factors and their improvement.

“ORA KESSARIS WATCH AND JEWELLERY COMMERCIAL S.A.” carries out studies in collaboration with all its departments and the competent occupational doctor on possible risk factors depending on the nature and subject matter of the work provided, the psychosocial risks, including the risks of violence and harassment at work, with a view to assessing the existing working conditions and adjusting them in such a way as to reduce as far as possible the chances of an incident of violence and harassment in the workplace.

Indicatively, there are cases of risk such as: high stress in the workplace, workplaces isolated or closed, distribution of jobs, security of facilities and control thereof, lack of appropriate education, people with a history of violent behavior, delivery of goods or services, individual work or in an isolated place, work late at night or during the morning hours, household or personal life issues brought in the workplace.

(b) Organization of seminars, publication of information leaflets and regular training of staff on issues of violence and harassment.

All employees must understand those behaviors that constitute violence and harassment, intolerable and unacceptable. The person responsible for violence and harassment reporting will ensure that staff receive appropriate awareness of violence and harassment and will make this policy known inside and outside the company.

6. Measures to prevent incidents of violence and harassment.

(a) Information on the rights of affected persons

“ORA KESSARIS WATCH AND JEWELLERY COMMERCIAL S.A.” states that in the event that a person is aggrieved by an incident of violence and harassment in access to employment, during the employment relationship or even if the contract or employment relationship in the context of which the incident or conduct is alleged to have occurred has expired, they have:

a) the right to judicial protection;

b) appeal, submission of a complaint and application for a labor dispute to the Labor Inspectorate, within the framework of its legal responsibilities,

c) reporting to the Greek Ombudsman, within the framework of the legal responsibilities of the Ombudsman, as well as

d) a complaint within the company in accordance with the complaints management policy.

The individual procedures for the submission, management and internal investigation of reports include the detailed steps that any complainant must take, as well as the responsibilities of the bodies of “ORA KESSARIS WATCH AND JEWELLERY COMMERCIAL S.A.” and the actions they need to take to ensure the effective management of relevant incidents. In any case, when a report or complaint of such behavior arises within the company, the affected person retains all their right to appeal to any competent authority. Any employee, who suffers domestic violence, which also has repercussions in the workplace, may report this fact orally or in writing to his supervisor in order to inform the company and for it to take appropriate and necessary measures.

(b) Information, awareness and support actions for staff

“ORA KESSARIS WATCH AND JEWELLERY COMMERCIAL S.A.” hereby informs the staff and maintains in a conspicuous place the contact details of the competent administrative authorities, to which any affected person has the right to appeal (Labor Inspectorate, Ombudsman), and in particular informs about the SEPE complaint hotline (15512) and the citizens' service line 1555 and https://1555. gov. gr/, as well as about the service of direct psychological support and counseling of women that are victims of gender-based violence who can communicate with the SOS 15900 Hotline (General Secretariat for Demographic and Family Policy and Gender Equality [G.S.G.E.].

 “ORA KESSARIS WATCH AND JEWELLERY COMMERCIAL S.A.”, declares its zero tolerance to any incident of violence and harassment, in any form it may take, including sexual harassment and gender-based violence, which takes place at work or by its implementation, by an employee against another employee, by a supervisor, by an authorized person, who is understood as an employer, by a customer, a visitor, a supplier and any third party. Furthermore, within the limits of its capabilities, it takes all appropriate measures and makes every reasonable adjustment of working conditions to protect employment and support workers - victims of domestic violence. It also takes all the necessary measures to inform and raise the awareness of the staff, using the above-mentioned appropriate means to combat violence and harassment, ensuring that everyone is aware of the company's policy and procedures towards incidents of violence and harassment and knows where they can turn in case of violence or — harassment, as well as the possibilities given to them by Law.

“ORA KESSARIS WATCH AND JEWELLERY COMMERCIAL S.A.” trains its executives in every appropriate way and means to recognize discrimination, violence and harassment at work and to provide the necessary support to its staff and associates. It also encourages the participation of employee representatives and management executives in training programs and training seminars on the identification and management of potential risks of violence and harassment and it may conduct seminars with mental health specialists or counseling service providers.

7. Rights and Obligations of employees

Every employee is entitled to:

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

Every employee is obliged to:

to comply with this policy and all applicable and existing procedures for the purpose of both their personal protection and that of the other employees of the company, to immediately announce any incident of violence and harassment to their supervisor, to cooperate in the event of an investigation of a complaint, which may have been submitted in accordance with the following procedure, to participate in actions and training programs of the Company regarding incidents of violence and  harassment.

Additional obligations of Directors and supervisors.

In particular, the Directors and heads of the Company must also: ensure the implementation of this policy in their area of responsibility, formulate appropriate standards of behavior in their area of responsibility, do not themselves manifest unwanted and prohibited behaviors, in the exercise of their duties, act immediately when they become aware of any manifestation of a prohibited behavior,  encourage employees to report any incidents of violence and harassment, which they themselves suffered or came to their attention, to immediately inform the Management of the Company of any incidents of violence and harassment that took place in their area of responsibility.

8. Instructions for preventing and addressing incidents of violence and harassment

In order to prevent and address incidents of violence and harassment in the workplace, it is advisable for employees to: seek comprehensive and objective information on legislation on violence and harassment and protection mechanisms. The Company may provide assistance and information on these issues, participate in actions and programs aimed at combating stereotypes, prejudices and discrimination, correct their behavior when they perceive that it is bothering or offending a colleague or associate, to define their individual boundaries to those around them, not to ignore incidents of violence and harassment, not to feel uncomfortable, ashamed or blame themselves for the behavior of the offender, not to justify the behavior of the offender, to repel or deal calmly and decisively with violent or harassing behavior, to keep a diary with details of incidents of violence and harassment, to inform their supervisor or the Company through informal, open and honest dialogue, to submit a written complaint, by e-mail, for further support in case a solution has not been reached, regarding the complaint concerning conduct of violence or harassment at work.

9. Procedure for the Submission and Management of Internal Complaints - Reference Person

Any employee against whom any incident of violence and harassment has occurred may submit an oral or written complaint before Mr.  Nikos Vintsentzatos, who is also defined as a “reference person” for this policy.

The complaint may be submitted in person or by e-mail to the e-mail address [email protected]. The complaint cannot be made anonymously.

The complaint should state the details of the complainant, i.e., the person who committed the manifestation of a form of prohibited behavior, as well as a specific incident(s), which constitute it.

The reference person thoroughly investigates any complaint and collects any information necessary about it. Complaints and investigations shall remain strictly confidential to the maximum extent possible, taking into account the sensitivity of the case and the confidentiality of all parties involved.

In particular, the reference person may talk to the complainant and the complainee, examine witnesses, request the production of documents that may exist and from which it is proved that any incident of violence and harassment has taken place or not, and communicate with the heads of each department, in case the complainant has addressed the matter to them.

After the reference person completes their investigation, they submit a written report to the Management of the Company, in which they state the result of the investigations. The results of the investigation are also communicated to the complainant and the complainee, so that they can be made aware of them. The conclusion of the investigation and the submission and notification of the findings of the reference person must take place as soon as possible and in any event not later than the period of three weeks from the date of submission of the complaint by the complainant.

In the event that the establishment of an incident of discrimination, violence or harassment or retaliation actually arises, the Management of the Company proceeds, on a case-by-case basis, to take all necessary, appropriate and proportionate measures against the complainant.

Such measures may include, but are not limited to:

(a) the recommendation for compliance;

b) the change of the job, the working hours, the workplace and the working methods,

c) the termination of the employment or cooperation contract with the company, without prejudice to the prohibition of abuse of rights under Article 281 CC.

Complaints that are proven to be blatantly malicious will be considered inadmissible and will be further investigated at the discretion of the company, both as to the motives and as to those involved, in order to restore order by any legal means.

10. Rights of affected persons

According to the applicable legislation, any person who suffers an incident of violence and harassment against them has the right to leave the workplace for a reasonable time, without deprivation of salary or other adverse consequences, if in their reasonable belief there is an imminent serious danger to their life, health or safety, and in particular, when the employer is the perpetrator of such behavior or when they do not take the necessary appropriate measures  to restore peace of work, or when such measures are not capable of stopping the behaviour of violence and harassment.

In this case, the departing person is obliged to inform the reference person in writing beforehand, indicating the incident of violence and harassment and the incidents justifying their belief that a serious danger to their life, health or safety is imminent.

Employees who face incidents of violence and harassment at work have the right to appeal to the competent authorities, as provided for in the Law (a. right to judicial protection, b. right to appeal and submit a complaint and application for a labor dispute to the Labor Inspectorate, within the framework of its legal responsibilities, c. petition to the Greek Ombudsman, within the framework of the legal responsibilities of the Ombudsman).

11. Obligation of impartiality and confidentiality

The reference person shall be obliged to act in the process of investigating complaints in an objective and impartial manner. In addition, they must behave with respect to all parties involved and in a confidential and discreet manner. It is completely forbidden to disclose to non-involved parties information concerning the complaint under consideration.

The above obligations are also borne by the Management of the Company during the final stage of taking measures and decisions.

12. Prohibition of Retaliation - Victimization of the complainant

It is forbidden to retaliate and victimize the complainant, who, as an aggrieved person, asserted their rights and filed a written complaint about an incident of violence and harassment. The retaliation and victimization of the complainant constitute a serious breach of this policy and have consequences for the person acting in this way.

If any employee or third party who is in any way connected with the Company considers that they have suffered retaliatory behaviors due to the submission of a complaint or the provision of assistance in the investigation process of incidents of discrimination, violence and/or harassment, they must follow the above procedure to report such incident of retaliation.

13. Cooperation with administrative and judicial authorities

“ORA KESSARIS WATCH AND JEWELLERY COMMERCIAL S.A.”  as well as any person or service responsible for receiving and handling such complaints at company level shall cooperate with any competent public, administrative or judicial authority which, either ex officio or upon request by an affected person, within the framework of its competence, requests the provision of data or information and undertakes to provide assistance and access to the data. To that purpose, any data collected, in any form, is kept in a relevant file in compliance with the provisions of Law 4624/2019 (A' 137) “Personal Data Protection Authority, measures for the implementation of 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 on this policy, any interested person can contact Mr.  Nikos Vintsentzatos to the e-mail address [email protected] .