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.