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Policy for the Prevention of Workplace Violence & Harassment

Policy for the Prevention of Workplace Violence & Harassment

POLICY FOR THE PREVENTION AND TREATMENT OF INCIDENTS OF VIOLENCE AND HARASSMENT IN THE WORKPLACE AND MANAGEMENT OF INTERNAL COMPLAINTS

I. Purpose

This policy aims to prevent and deal with incidents of violence and harassment at work, which may occur either during work or as a result of it. Hydroussa Navigation Ltd. makes any effort to provide a safe and free of all forms of harassment, violence, discrimination, and intimidation environment, through which the rights and dignity of all are promoted.

II. Scope

The scope of this policy includes all types of personnel associated with the company under employment contract (indefinite duration or fixed term), work contract, independent services contract, salaried assignment basis (έμμισθης εντολής), apprenticeship, “loan’’ system, volunteering, as well jobseekers and job applicants.

III. Prohibited Behaviors – Risk’s Assessment of Violence and Harassment

The term "violence and harassment" refers to a number of forms of behavior, acts, practices or threats, whether they occur individually or repeatedly, and which intend to, lead or may result in physical, psychological, sexual or financial harm. Specifically, the concept of "violence" includes any action that threatens the safety of employees and associates of the company or causes damage to its assets. Similarly, the term "harassment" includes those forms of behavior that aim to violate the dignity of the individual and to create an intimidating, hostile, humiliating, degrading and / or threatening environment. Such indicative behaviors that may occur are the following:

  • Threatened or actual physical violence
  • Bullying, oppression, persecution
  • Aggressive or threatening behavior, which reasonably causes fear to another person
  • Verbal harassment
  • Overt threats
  • Threats related to the position and working conditions
  • Offensive comments or jokes which concern another person
  • Arrogant, demeaning, and derogatory comments
  • Acts of retaliation
  • Domestic violence transferred to the workplace

A more specific form of "harassment" is "gender-based harassment", i.e. forms of behavior related to a person's gender which have as their purpose or result the violation of that person's dignity and the creation of an intimidating, hostile, degrading or humiliating and threatening environment. These forms of behavior include "sexual harassment", i.e. any unwanted, unpleasant, offensive, humiliating for the recipient behavior of sexual nature, whether expressed in words or deeds. Such behaviors that may occur are indicatively the following:

  • Sexual comments, jokes, gestures
  • Immoral and / or offensive comments about gender or sexual orientation
  • Indiscreet questions about personal or sexual life
  • Sexual innuendos
  • Invitations for dating or sexual intercourse
  • Unwanted touches, whistles, caresses, kisses
  • Persistent or lascivious stares
  • Sending messages of erotic or sexual content (by phone or e-mail)

Incidents of violence and harassment may occur in various places, and in particular:

  • In the workplace, including public and private spaces and areas where the employee provides work, is paid, takes a rest break, areas of personal hygiene and care, locker rooms or accommodation provided by the company.
  • When commuting to and from work, during other travel, work- related trips, education purposes, and work-related events and social activities.
  • Through work-related communications, including those enable by information and communication technologies.

The above-mentioned behaviors, wherever they may occur, are completely unsolicited, reprehensible, disapproved and prohibited by the company.

IV. Company’s obligations

Hydroussa Navigation Ltd. must ensure a safe, dignified, healthy and friendly working environment. In this context, it declares its zero tolerance for any incident of violence and harassment, which takes place at work by or against an employee, client, visitor, associate and any third party. The company takes all appropriate and necessary measures to prevent, deal and manage such incidents and forms of behavior. More specifically, Hydroussa Navigation Ltd.:

  • provides information, but also appropriate training to its employees on incidents of violence and harassment, on the way of addressing and managing them, their responsibilities, rights, etc.
  • oversees the implementation of this policy and takes action on non-compliant employees.
  • ensures that the working environment is pleasant, safe and friendly.
  • imposes the necessary and appropriate penalties on any employer, customer, visitor, associate, etc., who acts in a prohibited way.

V. Employee’s Rights and Obligations

Each employee is entitled to:

  • be treated with respect and courtesy.
  • not accept violent behavior, harassment, discrimination and intimidation.
  • to report any incident of prohibited conduct in the workplace (according to the company's internal procedure, as described below), without being victimized or suffering any other adverse consequence.

Each employee is obliged to:

  • comply with this policy and all applicable and enforced procedures for the purpose of both personal protection and that of the other employees of the company.
  • immediately communicate any incident of violence and harassment to his / her superior. This notice does not replace the complaint procedure as described below.
  • cooperate in case of investigation of a complaint, which has been submitted in accordance with the following procedure.
  • participate in company’s actions and training programs related to incidents of violence and harassment.

VI. Additional obligations of Directors, Managers and supervisors

Specifically, the company’s Directors, Managers and supervisors must also:

  • ensure the implementation of this policy in their area of responsibility.
  • form appropriate behavior patterns in their area of responsibility.
  • not engage in the conduct of prohibited behaviors in the exercise of their duties.
  • act immediately and inform employees, who have already informed them of any incidents of violence and harassment, about the complaints procedure.
  • encourage employees to report incidents of violence and harassment that they themselves have experienced or perceived.
  • immediately inform the company’s Management about any incidents of violence and harassment that took place in their area of responsibility and to which they were present.

VII. Guidelines for the prevention and treatment of incidents of violence and harassment

In order to prevent and deal with 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 can provide assistance and information on these issues.
  • Participate in actions and programs aimed at combating stereotypes, prejudices and discrimination.
  • Correct their behavior when they realize that it is bothering or offending a colleague or co-worker.
  • Set their personal boundaries to those around them.
  • Do not ignore incidents of violence and harassment.
  • Do not feel uncomfortable, ashamed or blame themselves for the perpetrator's behavior.
  • Not justify the behavior of the perpetrator.
  • Reject or deal calmly and decisively with violent or harassing behavior.
  • Keep a diary with details of incidents of violence and harassment.
  • Inform their supervisor or the company.
  • Submit a written complaint.

VIII. Procedure for the submission and Management of Internal Complaints

Any employee against whom any incident of violence or harassment has occurred may submit a written complaint before the Responsible for Human Resources. The complaint can be submitted in person or via e-mail and specifically to the e-mail address This email address is being protected from spambots. You need JavaScript enabled to view it.. It is not possible to file a complaint orally or by telephone. The complaint should indicate the personal details of the accused, i.e. the person exhibiting prohibited behavior, as well as a specific incident / s, which evidence it.

The Responsible for Human Resources thoroughly investigates each complaint and collects any necessary information. In particular, he/she may talk to the complainant and the respondent, examine witnesses, request the presentation of documents that may exist and from which it is proved that any incident of violence and harassment took place or not, etc. When the Responsible for Human Resources completes his/her investigation, he/she submits a written report to the company’s Management, stating the result of the investigation. The results of the investigation are communicated at the same time to both the complainant and the accused, in order for them to become aware of it. The completion of the investigation and the submission and communication of the Responsible for Human Resources findings should take place as soon as possible.

If an incident of violence and harassment actually occurs, the company’s Management proceeds, on a case-by-case basis, to take all the necessary, competent and appropriate measures against the accused. These measures may include, for example, the recommendation of compliance, the change of the position, the working hours, the place and type of employment, the termination of the employment contract or cooperation with the company, etc.

IX. Obligation of impartiality and confidentiality

The Responsible for Human Resources is obliged to act during the process of investigating complaints in an objective and impartial manner. In addition, he/she must behave with respect towards all parties involved and in a confidential and discreet manner. It is strictly forbidden to disclose or publicize to non-involved parties information relating to the complaint under consideration. The above obligations are also borne by the company’s Management during the final stage of taking measures and decisions.

X. Prohibition of Retaliation - Victimization of the complainant

Retaliation and victimization of the complainant, who as a victim claimed his/her rights and submitted a written complaint regarding an incident of violence and harassment, is prohibited. Retaliation and victimization of the complainant constitute a serious breach of this policy and have consequences for the person acting in this way.

XI. Cooperation with administrative and judicial authorities

If the affected person has reported the incident of violence and harassment before any administrative or judicial authority, the company undertakes to provide any necessary assistance, as well as any available information to these competent authorities.

XII. Cases of Domestic Violence

Hydroussa Navigation Ltd. takes, as far as possible, measures to protect employment and support workers victims of domestic violence. Any employee who has suffered domestic violence may report this in writing to his/her supervisor or the Responsible for Human Resources in order to inform the company and take appropriate and necessary action.

XIII. “Reference’’ Person

For any information regarding this policy, you can contact the Responsible for Human Resources.

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Company Data Protection Policy

Company Data Protection Policy

This Data Protection Policy (hereafter “Policy”) accounts for the personal information collected, processed and used by “Hydroussa Navigation Ltd.” (hereafter “Company” or “We”).

[ For more information on our data protection policies and procedures, you can always directly contact us at This email address is being protected from spambots. You need JavaScript enabled to view it. ]

Our Company as a Data Controller

Our Company processes personal data as an employer, prospective employer, as a supplier of services, for marketing related purposes and in the course of its operations, its standard business as a crew and ship management company. It also collects personal information when co-operating with third parties / partners and with respect to the visits of this website.

[ For specific information with regard to the protection of data collected through our website, you can read our Website Use Privacy Policy by follow the link: https://www.hydroussa-navigation.gr/index.php/website-use-privacy-policy. ]

How we collect personal data

The Company collects personal information:

(i) directly from the data subject; or

(ii) indirectly, either from internal sources, including the Departments of the Company; other entities affiliated with the Company, if any; or external third parties, including agents, intermediaries, suppliers, business partners etc.

What kind of data we process

We process personal data that includes but is not limited to:

(a) information referring to a subject’s name, contact details (full address, email address, phone number), birth date and place, gender, bank details, marital and family status, passport, visas and ID numbers, tax and social security numbers, as well as information on previous experience, references and professional certificates, correspondence with or about the data subject, the contract of employment and any amendments to it and all information needed for  the execution of a contract of employment, as is the case with our shore-based employees;

(b) information referring to a subject’s name, contact details (full address, email address, phone number) and emergency contact details, birth date and place, gender, bank details, marital and family status, passport, visas and ID numbers, tax and social security numbers, as well as information on previous sea services and references, qualifications and certificates, the respective contract of employment and any amendments to it, correspondence with or about the data subject, and, where appropriate, disciplinary and complaint records, as is the case with our crewmembers;

(c) information referring to a subject’s name, gender, identity card number or passport number, birth date and place, mailing address, telephone numbers, email address and other contact details, resume, educational qualifications, professional qualifications and certifications and employment references, as well as employment and training history or pictures/photographs maybe included in an application, as is the case with job applicants;

(d) information referring to a subject’s name, contact details (mailing address, email address, phone numbers), tax ID, payment details, job title and role/function; delivery information; scanned version of invoices, billing and similar documents, as is the case with our suppliers and our suppliers’ personnel and representatives, including trainers, technicians, lawyers, accountants, auditors and other service providers;

(e) information referring to a subject’s name, contact details (mailing address, email address, phone numbers), tax ID, payment details, job title and role/function, as is the case with our agents and our agents’ personnel and representatives; etc.

Special categories of data

Where necessary, we may keep information relating to a subject’s health, which could include reasons for absence and /or accident reports and notes, as well as medical records, as is the case with crewmembers joining the vessels managed by us.

This information is used in order to comply with our health and safety and occupational health obligations, including in order to consider how a subject’s health affects the ability to work and fulfil the respective employment obligations, as well as to comply with our statutory obligations and applicable legislation with regard to recruitment, employment, other flag or local legal requirement with respect to occupational medicine and, evidently, to protect a subject’s vital interests as is the case when protecting the safety and integrity of our crews at sea and the visitors or service providers onboard.

All above data and any other data that constitutes special category of data, including references to a subject’s ethnic origin /nationality etc.  are lawfully collected and processed by the Company and, unless this is not authorized or required by law or such information is required to protect the subject in an emergency, we obtain the subject’s explicit consent.

Why we process personal data

Personal data is processed by us as necessary for the performance of a contract to which the data subject is a party (as is the case with our employees, crewmembers and third-party associates), as well as for compliance of the Company with a legal obligation. We also process personal data in order to pursue the legitimate interests of the Company and protect our legal position in the event of legal proceedings or insurance claims.

When we need to process personal data to pursue our legitimate business interests, for example to prevent fraud or potential crimes, for administrative purposes or to protect the Company’s  assets and to improve our efficiency, we try to never process a subject’s data where these interests are overridden by the subject’s own interests and we use only methods and technologies which are necessary, proportionate and implemented in the least intrusive manner, by appropriate means that ensure a balance with the subject’s fundamental rights and freedoms.

How we use and protect personal data

We do not collect more information than we need to fulfil the purposes for which we process personal data.

We hold accurate and up to date data in manners that reasonably ensure appropriate security thereof, protection against unauthorized or unlawful processing, accidental loss, destruction or damage.

We restrict physical access to authorized persons and maintain and use appropriate technical and organizational measures and specified technological solutions and IT systems to protect the integrity, safety, security and availability of the personal data we process.

Monitoring – Ship tracking – CCTV surveillance

While onboard, geolocation of a subject is obviously monitored/tracked. In certain cases, computer and telephone/mobile telephone use are also monitored. The same applies while ashore, when and to the extent installation of a CCTV system is involved in our premises.

All for reasons relating to the subject’s personal safety and integrity and as precautionary/preventive measures against piracy or other possible dangers while at sea; to protect our Company’s assets and resources; and, mostly, to ensure the life, the safety and integrity of our people.

E-mail correspondence

Any personal data (name, address, title/position, contact details) we send and/or receive in our e-mail or other electronic correspondence is processed in compliance with the GDPR and any other applicable law or regulation.

Our Company uses the personal data contained therein and any attachments thereto lawfully, fairly and in a transparent manner; for specified, explicit and legitimate purposes.

Our correspondence recipients are duly informed that they have all rights provided for by respective legislation regarding their personal data.

Who has access to personal data

A subject’s information is disclosed, as the case may be, only to appropriate Company’s personnel, including, evidently, the Master/Officers of the ships managed by us.

We may also disclose personal data to port or other competent authorities if this disclosure is mandatory under applicable law.

Disclosure to tax authorities and to internal and/or external auditors is included.

We also disclose personal data to service providers onboard or ashore,  as well as to our charterers, port and other agents, external consultants, training providers, business associates and professional advisors, including lawyers and accountants, as well as accredited clinics or doctors performing medical exams or prescribing medication to our crews prior to or during their recruitment) and to other third parties, if we are legally obliged to do so (flag requirements included) or where we need to comply with our contractual duties to the data subject, for instance where we may need to pass on certain information to our port agents responsible for the transportation, boarding etc. from and to ports or other destinations or to our insurance or other associates in case of an accident.

In all such cases, we do so where appropriate and only in accordance with local laws and requirements and we try to at all times ensure that such third parties have undertaken appropriate data processing obligations to ensure the security and confidentiality of the subject’s data.

Due to our global activities and the nature of our business as a crew and ship management company, personal information may be transferred outside of the E.E.A. when we need to comply with our legal or contractual requirements. We do so only where an adequate level of protection is ensured or where we have in place safeguards including the use of standard contractual terms, to ensure the security of a subject’s data in case of these transfers.

We might also transfer a subject’s personal data to companies affiliated with the Company, if any, for purposes connected with the management of the Company’s business.

When we assign data processing

Where the Company relies on a third-party data processor, to execute processing on its behalf, we choose one who provides adequate security level and measures and undertake reasonable steps to ensure compliance of the data processor with such measures.

Duration of retaining

Personal data is stored for no more than it is necessary for the purposes for which it is processed for.

For so long as personal data is retained by the Company, we implement and at all times have in force appropriate technical and organizational measures as required by law, in order to safeguard the rights of the data subjects

When we process personal data based on the subject’s consent, this consent remains valid until such time it is withdrawn by the subject, as the case may be.

Future use and update

If in the future we intend to process personal data for a purpose other than that which it has been collected for we make sure to provide the subject with information on that purpose and any other relevant information if such purpose is not compatible with the initial.

The subject’s rights

If and to the extent we process a subject’s personal data based on his/her consent, the subject may withdraw consent and request us to stop using and/or disclosing such personal data for any or all of the purposes for which consent has been granted to the Company. This may be done by submitting a request in writing or via email to our authorized person in charge.

Upon receipt of such written request to withdraw the consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with the subject) for the subject’s request to be processed and for us to notify him/her of the consequences of our acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we seek to process and effect a subject’s respective request within 30 days of receiving it.

A subject is also entitled to request access to his/her personal data, as well as rectification, erasure or restriction of processing, as the case may be, to object to our processing, if and as the case may be, as well as to receive the data in machine-readable format.

Changes to this Policy

We reserve the right to make changes to this Policy from time to time. Regularly reviewing our website ensures that a subject is always aware of the updated version.

If we make material changes to this Policy, we will promptly provide notification via prominent notice on our website.

Contact in case of queries

For more information on our personal data policies and procedures and for guidance on privacy related issues, as well as for requests for access, rectification, erasure, etc. as above, you can contact our data protection officer (This email address is being protected from spambots. You need JavaScript enabled to view it. / 0030-2106152355), who can also answer all your queries on how the Company is processing personal data.

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Shipboard Drug and Alcohol Policy

Shipboard Drug and Alcohol Policy

Company Drug and Alcohol Policy exceeds the principles set forth in the Oil Companies International Marine Forum (OCIMF) "Guidelines for the control of drugs and alcohol aboard ships" and applies to all shore staff and sea going personnel.

The policy of Hydroussa Navigation Ltd. is to prevent the possession and use of illegal drugs and the consumption of alcohol onboard as well as the misuse of legitimate drugs.

 The Company has established a “Zero Tolerance Policy”
with respect to possession and consumption of drugs & alcohol on board the vessels.

Each candidate seafarer must consent to undergo a pre-employment screening for drugs and alcohol.  Satisfactory results are a precondition for employment.

Each Officer or crewmember must consent to undergo unannounced testing for use of drugs and alcohol during his employment.

The possession and use of alcohol, illegal drugs or substances onboard is a serious offence and grounds for employment termination.

The Company (or the Master as its legal representative) reserves the right to conduct unannounced searches for drugs and/or alcohol onboard.

The Company reserves the right to submit anyone onboard, including visitors and contractors, involved in a serious incident or suspected of drugs and alcohol use or impairment, to drug and alcohol screening immediately after such an event.

It is required that the Officers and ratings, returning from shore leave, observe at least a four hour period of abstinence from alcohol prior to assignment of duties onboard.

At no time should the Master or any Officer or crewmember onboard be allowed to perform assigned duty under the effect of alcohol. Alcohol impairment, under this policy, is defined as a Blood Alcohol content of 40 mg/100ml or greater.

 

Chief Executive Officer

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Safety Policy

Safety Policy

It is the Company’s Policy to promote Safety at sea. In order to comply with this Policy, the Company is committed to continuous efforts to identify and eliminate or manage safety risks associated with its activities.

The Company’s goal is to conduct its business in a manner that protects the safety of employees, others involved in its operations, customers, and the public as well as to prevent all accidents, injuries, and occupational illnesses through the active participation of every employee.

The Company goal is to achieve ZERO incidents at sea through continuous improvement.

For achieving these goals, the Company:

  • complies with all applicable laws and regulationsas as well as applicable best industry practices and recommendations, and applies responsible standards where laws and regulations do not exist;
  • designs and maintains facilities, establishes management systems, provides training and conducts operations in a manner that safeguards people and property;
  • responds quickly, effectively and with care to emergencies or accidents resulting from its operations, in co-operation with industry organizations and authorized government agencies;
  • stresses to all employees, contractors, and others working on its behalf their responsibility and accountability for safe performance whilst at work and safe behavior outside of work;
  • works with government agencies and others to develop responsible laws, regulations, and standards based on sound science and consideration of risk;
  • takes into consideration the results of Industry researches and recommendations to extend knowledge about the safety effects of its operations, and as appropriate, communicates them to employees, contractors, and others who might be affected;

 

Chief Executive Officer

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Quality Policy

Quality Policy

The Company ensures that the quality of its operations, the safety and health of its employees and the protection of the environment remain the predominant factors in all aspects of its operations. In this respect, the Company has established and maintains a process based Safety and Quality Management System (SMS) that is designed to continuously improve the quality of the services offered by the Company.

The Company is committed to conduct all activities for which it is responsible in a safe, efficient and environmentally sound manner that consistently meets Customers’ expectations, while ensuring effective and efficient compliance with prevailing statutory and regulatory requirements.

In order to ensure that operations and quality service objectives can be achieved, the SMS addresses the continuous monitoring of all aspects of the Company’s operations so that potential problems can be readily identified and appropriate corrective actions implemented. The nature of services provided by the Company allows its access to industry best practices and where there is a clear benefit these will be adopted within the Company.

The SMS is based on the belief that preventing problems from occurring is in the best interests of our customers, our quality management, and all of us in the Company.

The Company recognizes the importance of customer satisfaction and will work to exceed customer expectations. Open and ongoing dialog will be maintained with all stakeholders to communicate their expectations and to discuss feedback on performance.

The Quality Policy has the full support of Senior Management and applies to all employees of the Company. It is the policy of the Company to provide services which are always in accordance with its own standards and its customers’ requirements, including legal obligations.

It is mandatory that the Company’s SMS procedures are known, understood, adhered to at all times and reviewed often to ensure the maintenance of the Company’s quality standards.

Chief Executive Officer

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