Labor Policy

Policy of the “KONSERVOPOIIA VOREIOU AIGAIOU A.E.V.E.” (NORTH AEGEAN CANNING COMPANY S.A.) For preventing and combating violence and harassment at work and for the management of internal complaints for incidents of violence and harassment

1. The Limited Liability Company with the name “KONSERVOPOIIA VOREIOU AIGAIOU A.E.V.E.” (hereinafter “KONVA”) adheres to all measures and obligations regarding the implementation of the provisions in Part II of L. 4808/2021 for preventing and combating any form of violence and harassment including violence and harassment because of gender and sexual harassment.

KONVA has created a workplace, in which the personality of all employees is respected and to whom equal opportunities for advancement and development are provided.

The respect and dignity of each individual employee constitutes the immediate priority of KONVA. KONVA’S corporate social policy is based on human rights. These define the minimum labour standards and function as a supplement to our corporate values.

KONVA, demonstrating zero tolerance for incidents of violence and harassment in the workplace adopts this policy in compliance with Articles 9 and 10 of Greek Law No. 4808/2021, which upholds the Convention 190/21.06.2021 of the International Labour Organisation (ILO) with regard to the elimination of violence and harassment in the world of work, whose text was annexed unaltered to the text of the law.

2. The objective of this policy is to create and establish a working environment which respects, promotes and safeguards human dignity and the right of each person to a world of work without violence and harassment. KONVA declares that it recognises and respects the right of each employee to a working environment without violence and harassment and that it does not tolerate any such behaviour, in any form and by anyone.

3. This policy is adopted in accordance with Articles 9 and 10 of L. 4808/2021 in implementation of the regulatory legislation and covers the persons in Article 3(1) of L. 4808/2021.

Specifically, integrated in the scope of implementing this policy are all personnel associated with KONVA:

• with a dependent employment contract (indefinite or fixed term, full or part time employment),
• with a project based contract, seconded personnel from a Member State of the EU, or personnel from third countries,
• with an independent employment contract,
• with a salaried assignment basis,
• with an apprenticeship contract,
• with a loan contract, employed through third party service provision,
• volunteers,
• persons who apply for employment, persons whose working relationship with the company has expired.

4. KONVA expresses its commitment to combating and eliminating discrimination, violence and harassment in the workplace, with the aim of securing a working environment where respect for human dignity prevails and discrimination on the basis of personal characteristics and choices will not be allowed.

It declares explicitly and categorically and in the most direct way that any form of discrimination, violence and harassment that is displayed during work, either associated with or arising from it, is strictly prohibited.

KONVA declares indicatively: that sexual gestures or insistent proposals for a date or threats, insinuations that one’s sexual favours can be advantageous to the advancement of their career or refusal to engage in a sexual relationship can affect or constitute a negative factor in their professional career path at KONVA, rude gestures, touching and any kind of unwanted bodily contact, ridiculing, indecent, sexual or racist comments, teasing or jokes, insinuations, use of offensive language, comments on one’s external appearance or character that provoke awkwardness, embarrassment or inhibition, messages with a sexual content sent via SMS, email, social networks, fax or letter, offensive and insistent questions about age, one’s family status, personal life, sexual interests and preferences, as well as similar questions about their nationality, including their cultural identity and religion, spreading malevolent comments or offending someone mainly due to discrimination of age, gender, any type of handicap, sexual preferences, religion or beliefs, verbal threats or gestures, use of obscene language publicly or privately, belittling or ridiculing a person or their skills either publicly or privately, angry outbursts against someone, engaging in insistent or unjustified criticism, cyberbullying, offensive electronic messages, letters and telephone calls, etc., are prohibited.

KONVA also prohibits any employee or third party in any way associated with the company, to engage in actions of retaliation against another employee or third party who objects to violence or any form of harassment, submits a complaint, testifies, assists or participates in any investigative procedure of an incident.

It is understood, however, that the direct supervision of employees including the definition of their expected performance, measures taken to correct their performance such as placing an employing in an performance improvement plan, the assignment of tasks and guidance as to how and when they need to be done, approval or rejection of license, the request for validation of sick leave according the provisions in effect, moral and financial rewards for employee performance excellence and provision of constructive comments on job performance do not constitute an incident of violence and harassment.

5. KONVA declares that it will receive, investigate and manage every relative complaint, declaring at the outset that it will not show the slightest tolerance for discrimination, incidents of violence and harassment, with confidentiality and respect to human dignity. It also declares and commits to not interfere in the receipt, investigation and the management of these complaints.

6. At the same time, KONVA declares that it is willing to provide support and access to every responsible public, administrative or judicial authority that may investigate possible incidents of violence and harassment associated with its work.

7. For the persons that violate the terms defined in this policy, the necessary and appropriate measures will be taken accordingly, on a case-by-case basis, in order for similar incidents or behaviour to be prevented and not to reoccur in the future.

8. For combating each form of discrimination, violence, and harassment within the context of and on account of work, KONVA has designed an integrated reporting mechanism for submission, management, processing and investigation, with the establishment of specific reporting submission channels, which support not only the prevention but also the resolution of issues of violence and harassment in the workplace. Each separate Submission, Management, and Internal Reporting Investigation Procedure includes detailed steps which every complainant must follow, as well as the power of the institutions of KONVA and the actions that must be taken to ensure the effective management of the related incidents.

More specifically, KONVA:

• Assesses the risks of violence and harassment in the workplace, utilising digital tools for professional risk assessment.
• Provides information as well as the appropriate training to its employees about dealing with incidents of violence and harassment, managing them, their responsibilities and rights and ensures that all employees are aware of the internal policies and procedures and know who to address in case of violence or harassment.
• Trains its senior management to recognise discrimination, violence and harassment at work and to provide the necessary support to personnel and their colleagues.
• Supervises the implementation of this policy and takes measures for those employees who do not comply with it.
• Ensures a safe and fair working environment.
• Applies the necessary and appropriate penalties in case it realises a display of prohibited form of behaviour by any employee, customer, visitor, supervisor.
• Encourages its employees and all third parties associated with the company in any way to report incidents of discrimination, violence and harassment in the workplace, which they may be witness to.

• Prohibits retaliation and further victimisation of the affected person.
• Adopts submission and complaint examination procedures, and also appoints someone as a person of reference (“liaison”) in the company, responsible for guiding and informing employees on preventing and combating violence and harassment.
• Applies disciplinary penalties, which the person of reference will decide on after examination, to whomever is proven to have engaged in any form of harassment or act of violence as well as to whomever assisted in such actions or was aware of and intentionally did not mention them.

9. Each employee, which to their detriment any incident of violence or harassment was displayed, may submit a verbal or written complaint before the Human Resources Manager who is also designated as the “person of reference” for this policy. The complaint may be submitted in person or through electronic mail and specifically at the email address [email protected]. The complaint cannot be made anonymously.

The details of the accused must be written in the complaint, i.e. those of the person who engaged in the display of a form of prohibited behaviour, as well as the specific incident/s that substantiate it.

The Human Resources Manager will investigate each complaint extensively and collect any information is necessary with regard to it. The complaints and investigations remain strictly confidential to a maximum possible degree, taking into account the sensitivity of the case and the confidentiality of all parties involved.

Specifically, they may communicate with the complainant and the accused, request the presentation of documentation which possibly exists and from which proves that any incident of violence and harassment did or did not take place, and communicate to the supervisors of each unit in case the complainant had addressed them.

Once the investigation of the Human Resources Manager is completed, they will submit a written report to the Directors of the company, which will indicate the results of the investigation. At the same time, the results of the investigation will be disclosed to the complainant and the accused in order to inform them. The completion of the investigation, submission and notification of the findings by the Human Resources Manager must take place as soon as possible and in each case no later than a 3 week period from the date the complaint was submitted on behalf of the complainant.

If the results of the inquiry show that an incident of discrimination, violence or harassment or retaliation took place, KONVA will set in motion the appropriate corrective, disciplinary and/or other actions against the violator.

These actions may include (indicatively and not limited to): (a) disciplinary penalties, (b) a change in position, working hours, location or type of work provided, (c) termination of the employment contract or collaboration contract, (d) judicial actions.

In each case, the violator may also incur liability of a penal or civil nature in accordance with the legislation in force.

10. Complaints that are proven to be evidently malevolent are considered unacceptable and will be further investigated as per the judgement of KONVA, both to the motives as well as to the parties involved in order to restore order with every legal method and means.

 

11. Any employee, following any incident of violence or harassment has taken place to their detriment, has the capacity to communicate with the person of reference, in order for KONVA to assist in obtaining counselling and/or psychological support if they so desire.

 

KONVA declares once again, that it has zero tolerance for incidents of harassment or violence in the workplace and explicitly commits to assist in any way in the elimination and the prevention of such incidents.

 

It is also committed to be responsible for updating this policy, if this is imposed from the expansion of its activities.