Policy to Prevent & Combat Violence & Harassment
Purpose
Crowe Greece complies with all measures and obligations regarding the implementation of the provisions of Part II of l. 4808/2021 in order to prevent and combat any form of violence and harassment, including gender-based violence and harassment and sexual harassment.
This policy aims to create and establish a working environment that respects, promotes and safeguards human dignity and every person's right to a working environment free from violence and harassment. The company is dedicated to providing a working environment free from discrimination, intimidation and unlawful harassment, supports human rights and explicitly and irrevocably declares zero tolerance to such behaviour. With this policy, it intends to protect all its employees from any form of violence or harassment in the workplace, by informing them of their rights and obligations, creating a safety net for the person affected, but also establishing a specific framework for sanctions for the offender.
It also aims to establish a culture of respect for human rights, initially in the workplace, but also more broadly, so that there is zero tolerance to such violations, while promoting the principle of respect by each member for the other and the fundamental principles and rights at work.
This policy is adopted in accordance with articles 9 and 10 of l. 4808/2021 and the regulatory legislation pursuant thereto and covers the persons referred to in par. 1 of article 3 of l. 4808/2021.
The company, already having a people-centred character, complies with the provisions of the law and strengthens its existing culture of healthy interpersonal relationships in the workplace.
Scope
Law 4808/2021, in addition to all the company's employees, also covers other categories of persons with another contractual relationship, cooperation or even contact with the company. These categories include freelancers, employees under employment contract, independent services, paid on salary basis, trainees and apprentices, volunteers, employees whose employment relationship has ended, even those seeking employment at Crowe Greece.
At the same time, this policy aims to prevent any form of violence or harassment in the workplace, in areas where the employee takes a break, during transport to and from work, including on company trips, during training and at work-related events and social activities, as well as in work-related communication, whether physical, technological or IT-related.
Violence and Harassment Risk Assessment
According to Law 4808/2021 (article 4) “All forms of violence and harassment which occur at work, whether associated with it or arising from it, including gender-based violence and harassment and sexual harassment, are prohibited.” Violence and harassment includes harassment, gender-based harassment and sexual harassment.
The term “violence and harassment” refers to those forms of behaviour, acts, practices or threats thereof, which are intended to cause, result in or are likely to result in physical, psychological, sexual or economic harm, whether a single occurrence or repeated.
“Harassment” refers to those forms of behaviour that aim at or result in the violation of the dignity of the person and the creation of an intimidating, hostile, degrading, humiliating or offensive environment, whether or not it constitutes a form of discrimination, and includes harassment directed at persons because of their sex or on other grounds.
The term “gender-based harassment” means those forms of behaviour associated with the gender of a person, that aim at or result in the violation of the dignity of that person and the creation of an intimidating, hostile, degrading, humiliating or offensive environment according to article 2 of l. 3896/2010 (A' 107) and par. 2 of article 2 of l. 4443/2016 (Α’ 232). These forms of behaviour include the sexual harassment under l. 3896/2010, as well as the forms of behaviour related to sexual orientation, expression, identity or sex characteristics of the person.
“Sexual harassment” means any form of unwanted verbal, psychological or physical behaviour of a sexual nature resulting in the infringement of personality rights, in particular by creating an intimidating, hostile, degrading, humiliating or offensive environment around that person.
Crowe Greece, in collaboration with all its departments and the competent occupational physician, studies the potential risk factors depending on the nature and scope of the work provided, the psychosocial risks and, among others, the violence and harassment risks in the workplace. In this way, it assesses the existing working conditions and ensures that they are adjusted in order to limit, as much as possible, the likelihood of violence and/or harassment occurring in the workplace.
Indicatively, we state certain cases of risk such as:
high work-related stress
isolated or closed workplaces
distribution of jobs
safety and inspection of installations
lack of appropriate training in the subject of the policy
people with a history of violent behaviour
work individually or in an isolated place
work late at night or during the morning
domestic or private life issues that spill over into the workplace
In this frame, the company ensures the awareness of its people on violence and harassment matters, by planning actions such as organising seminars, issuing information leaflets and regular training of personnel on relevant issues in order for all employees to understand those behaviours that constitute violence and harassment, which is intolerable and unacceptable.
Manifestation of Violent and Harassing Behaviours
Such behaviours can manifest themselves in various forms such as physical, verbal, non-verbal, direct, indirect, covert or implied, or manifest in cyberspace, regardless of whether corporate or non-corporate equipment and accounts are used.
Examples of such behaviours may include, but are not limited to, any of the following:
Harassment on any basis exists, whenever it occurs:
Submission used as the basis for an actual or implicit employment decision employment, including loss of job, demotion or change of responsibilities or benefits
Behaviour that intends or interferes with an individual's work performance or creates an intimidating, hostile and/or offensive workplace
The relevant law recognizes the right of all employees to live together in a workplace free from violence and harassment, which constitute a violation of human rights, and affect mental and physical health, dignity, economic and social environment, while at the same time posing a threat to the working environment itself.
Risk Prevention, Reduction and Response Measures
The company, seeking equality and creating a safe environment for all its employees and those associated with it, is required to deal with any incident within a confidentiality and prompt management framework. Violence and harassment risk assessment, awareness-raising actions for the personnel, prevention and management, as well as guidance and support to victims of violence and harassment or victims of domestic violence for their reintegration into the workplace are some of the employer's obligations.
The company fully complies with this policy, as well as its employees. In case of complaint or report, all employees of:
Crowe Greece may contact the Human Resources Director, Mrs. Christina Chatzoglou (tel.: 0030 2108691544, e-mail: cchatzoglou@solcrowe.gr), who is responsible for handling such matters,
while
Crowe Greece Advisory S.A. may contact either the General Manager of the company Mr. Ioannis Giannopoulos (tel.: 0030 2107256904, e-mail: i.giannopoulos@solcrowe.gr), or the HR Administrator Mrs. Nora Svetsa (tel.: 0030 2107256964, e-mail: n.svetsa@solcrowe.gr), who are responsible for handling such matters.
Alternatively, all employees of Crowe Greece can communicate any issue related to this policy that concerns them through the Whistle2Sol. The Whistle2Sol link, as well as the Reports – Complaints Policy can be found on the firm's official website (https://solcrowe.gr/complaints/). In this case, any complaints or reports can be made by name or anonymous. Any report or complaint will be examined immediately with absolute confidentiality, impartiality and protection of personal data based on the Reports – Complaints Policy.
More specifically, the Director’s obligation is to receive, investigate and handle any complaint or relevant report, demonstrating zero tolerance to violence and harassment and with respect for human dignity. Also, it does not prevent the receipt, investigation and handling of complaints or reports and should provide assistance and access to any competent department. Lastly, he/she must provide all necessary information on any possible violence and harassment risks and measures for the prevention and protection of employees.
Upon receipt of any complaint, the competent person shall be responsible for:
providing information on the rights and obligations of the affected persons,
prohibiting any retaliation,
cooperating and providing any relevant information to the competent authorities, and
describing the consequences when any breach is identified, such as a change of position or even termination of the contract by the employer.
Complaints and investigations shall strictly confidential to the maximum extent possible, taking into account the sensitivity of each incident and the confidentiality of all parties involved.
The competent person, and by extension the firm, is required to take all necessary measures to avoid similar incidents or behaviours. Furthermore, the competent person shall provide guidance and inform employees on how to prevent and deal with violence and harassment at work, regardless of whether they address him/her on occasion of such an incident or a complaint about such an incident or not. The competent person shall in any case be obliged to protect Personal Data which may come to his/her knowledge in the course of his/her duties.
Lastly, if a report or complaint is made to the competent person regarding a behaviour that affects the employee in any way, based on the above descriptions, a personal and adapted action plan will be formed, always in consultation with the employee (e.g. flexible working hours, teleworking, etc.) and there will be guidance and information as to where the employee can turn, either for legal or counselling and/or psychological support.
With regard to the reported acts, the firm, through its competent bodies, cooperates with any competent public, administrative or judicial authority, which, either on its own initiative or following a request by an affected person, within the scope of its competence, requests the provision of data or information and undertakes to provide assistance and access to the data (art. 5 par. 1 of l. 4808/2021). For this purpose, any information gathered, in whatever form, is kept in a relevant file in compliance with the provisions of l. 4624/2019 (Α’ 137).
According to par. 2 of article 12 of l. 4808/2021, when established that an employee or a person employed in another relationship breaches the prohibition of violence and harassment under article 4 of the same law, the company shall take the necessary appropriate and adequate measures on a case-by-case basis against the complainant, in order to prevent and avoid a similar incident or behaviour from being repeated. Such measures may include recommendation for compliance, changing the position, working hours, work place or method, or termination of the employment or cooperation relationship, without prejudice to the prohibition of abuse of right in article 281 of the Civil Code.
Especially for victims of domestic violence, Crowe Greece takes every measure and makes every reasonable adjustment of working conditions to support employees - victims of domestic violence and protect their employment. Such measures may include, but are not limited to, employment, by agreement with the employee, in a different object, place or hours, as well as guidance and information of the employee on where to turn for legal or counselling and/or psychological support.
According to existing legislation, every person who suffers an incident of violence and harassment against him/her has the right to leave the workplace for a reasonable time, without deprivation of salary or any other negative consequence, if in his/her reasonable belief there is an imminent serious danger to his/her life, health or safety, in particular, when the employer is the perpetrator of such behaviour or when he/she does not take the necessary appropriate measures, to restore industrial peace, or when such measures are not sufficient to stop the behaviour of violence and harassment.
In this case, the person leaving is obliged to previously inform the competent person (reference person) in writing, stating the incident of violence and harassment and the incidents justifying his/her belief that a serious risk to his/her life, health or safety is imminent.
In addition, employees who face incidents of violence and harassment at work have the right, in addition to filing a complaint within the firm in accordance with the present, to resort to the competent authorities, as defined in article 12 of L. 4808/2021 (a. right to judicial protection, b. right of appeal before the Labour Inspectorate, within the frame of its legal powers, c. right of appeal before The Greek Ombudsman, within the frame of his/her legal powers).
In any case, the firm notifies through this policy but also in person, to each employee who contacts it, through the competent person it has designated, the contact details of the administrative authorities of the State (Hellenic Labour Inspectorate and The Greek Ombudsman). In particular, any affected person may contact with SEPE’s line through the 1555 citizen telephone line, as well as make use of the direct psychological support and counselling service for women victims of gender-based violence through the SOS 15900 line.
Hellenic Labour Inspectorate, 37, 28th October Street, Athens. (Complaints Tel.: 1555, e-mail: helpdesk@sepenet.gr) and on the website https://www.sepenet.gr by subscribing to the service, in accordance with the instructions provided on the website.
The Greek Ombudsman, 17, Chalkokondyli Street, Athens. (Tel.: 2131306600, e-mail: press@synigoros.gr) and on the website https://www.synigoros.gr.
Direct psychological support and counselling service for women victims of gender-based violence, SOS line 15900
Encouraging the maintenance of a working climate where respect for human dignity, cooperation and mutual assistance are core values along with open communication with the employer, the executives who represent him, his direct supervisors and colleagues are an absolute priority for the firm.
The firm's goal is to ensure that employees have the necessary training/information to perform their duties, especially in jobs that are at higher risk of violence and harassment.
Approval and Update of the Policy to Combat Violence and Harassment in the Workplace
This Policy has been approved by the Board of Directors of Crowe Greece, while during its preparation all the provided for information and consultation procedures were followed in accordance with the provisions of article 11 of L. 4808/2021.
The firm aims to evaluate the effectiveness of the implemented prevention and mitigation measures and review/update the assessment of risks and measures on a regular basis.
Any amendment to the text of the Policy to Combat Violence and Harassment in the Workplace shall be made only with the approval of the firm's Management and automatically entails codification of its text.
The Human Resources Department is responsible for preparing and proposing revisions to the policy, acting on its own initiative or following a relevant proposal by the firm's Managing Director.
This policy will be sent to the e-mails of all employees-members of Crowe Greece and will be posted on the firm's internal network (extranet) as well as on its official website.
Lastly, information material will be sent and briefing meetings-teleconferences will be held in order to communicate the policy by the firm’s executives and experts on these issues.