POLICY FOR THE PREVENTION AND COMBATING OF VIOLENCE AND HARASSMENT AT WORK
The “MEDIMALL PRIVATE POLYCLINIC” MEDICAL SOCIÉTÉ ANONYME declares that incidents of violence and harassment in the workplace are expressly prohibited.
It undertakes to make every possible effort in order to address and eliminate them immediately, so as to ensure a safe working environment for those employed therein (personnel, collaborating physicians, etc.).
Consequently, MEDIMALL shall not tolerate any form of violence, abusive behavior, psychological or physical mistreatment, intimidation, harassment including sexual harassment against any person employed therein.
DEFINITIONS
Violence and harassment:
These are behaviors, acts, practices or threats, which aim at, lead to or may lead to any form of harm to the victim (physical, psychological, or sexual) and are manifested either individually or repeatedly.
Violence in the workplace:
This is any incident of abuse, threat or attack against a person in the workplace during the performance of work duties. It may include physical assault, aggressive behavior, threats, verbal abuse, incidents related to anger, insults, etc. These are behaviors that constitute physical and psychological abuse, which create physical or mental pain, diminish the personality, dignity and integrity of the employee.
Harassment:
These are behaviors that may lead to the violation of the dignity of the person and the creation of a problematic, humiliating and hostile environment for the victim.
Gender-based harassment:
These are behaviors connected with gender and aimed at or violating the dignity of a person and creating a problematic (intimidating, hostile, degrading, humiliating or offensive) environment. These cases also include sexual harassment as well as harassment due to sexual orientation, identity or gender expression.
Sexual harassment:
Any form of unwanted verbal or non-verbal or physical conduct of a sexual nature, which affects sexual dignity and creates an intimidating, hostile, degrading or humiliating environment for the person. These are behaviors with a sexual tone or insinuation manifested through acts or words and which are unpleasant and offensive to a person. It is not required that the behaviors be repeated; even a single incident is sufficient. Examples of sexual harassment include, indicatively: Unwanted physical contact, touching parts of the body, exposure of body parts, sexual comments or insinuations, unwanted proposals aimed at sexual intercourse, unwanted familiarity, sexual or immoral or offensive comments, steering discussions toward sexual topics, description of sexual life in front of other persons, indiscreet questions about personal or sexual life, obscene remarks, annoying flirting and continuous/persistent proposals for social activity outside the workplace while it has been made clear that such proposals are unwanted, display of obscene images or objects, whistling, unnecessary very close physical proximity, messages through mobile phones or other electronic means with offensive content, sexual proposals or amorous remarks, exploitation of a position of authority provided by a hierarchically superior position for one’s own sexual benefit, such as indicatively the case where a supervisor demands sexual favors in exchange for better working conditions, promotions, salary increase, etc., retaliatory or intimidating actions in the event of reporting or threatening to report any harassment behavior.
Persons employed at MEDIMALL should never manifest such behaviors in the workplace.
MEDIMALL shall not tolerate any action that creates an intimidating, offensive, humiliating or hostile climate or causes feelings of fear, concern and discomfort to employees.
Whether an action/behavior is considered violence or harassment is an objective fact and is not affected by the intentions of the perpetrator.
Any person who becomes the recipient or witness of such behaviors may contact MEDIMALL and report the incident in question, and MEDIMALL declares that it shall take all necessary measures and proceed with the necessary actions in order to address this incident immediately and effectively, ensuring confidentiality and protection of the victim from any acts of revenge and retaliation.
MEDIMALL shall receive and investigate all complaints, provide access and disclose to the competent public, administrative or judicial authorities any information requested by them regarding any incidents of violence and harassment in the workplace, assisting their work.
PURPOSE AND SCOPE OF APPLICATION
The purpose of this policy is the creation of a safe working environment with absolute respect for human rights and the protection of the employee from abusive and violent behaviors, as well as the timely prevention, immediate response and effective combating of such behaviors.
This policy applies in MEDIMALL workplaces and in any other place where employees are present within the framework of their work (home visits, seminars, business trips, etc.) as well as in all telephone and electronic communications taking place within the framework of work (email, sms, etc.). In addition to MEDIMALL personnel, this policy must also be complied with by persons employed on its premises under a project contract, independent services agreement, salaried mandate, trainees and apprentices, visitors to MEDIMALL as well as their escorts.
Within this framework MEDIMALL has assigned CHRISTOS PAVLOU and AIKATERINI KASIDIARI the guidance and information of employees on matters of prevention and handling of incidents of violence and harassment.
MEDIMALL’s aim is to raise awareness among employees so that they perceive and recognize in a timely manner behaviors of violence and harassment, to encourage victims to report them and to cultivate the creation and maintenance of a spirit of respect for human rights within the working environment.
MANAGEMENT OF REPORTS / COMPLAINTS
In the event that any employee becomes the recipient of violent or harassing behavior within the workplace or becomes witness to such behavior toward a third employee within the working environment, he/she should immediately proceed with a report/complaint following the procedure described in the Internal Complaints Management Policy and Procedure.
MEDIMALL undertakes to manage every report/complaint demonstrating zero tolerance to violence and harassment, with absolute respect for the rights of the employee and taking all necessary measures to ensure the confidentiality of the entire process and the protection of his/her personal data.
The executives authorized by MEDIMALL for the management of complaints have undertaken towards the company to maintain under a regime of absolute confidentiality and discretion any information and personal data disclosed to them within the framework of management of the submitted report/complaint.
MEDIMALL shall immediately and thoroughly investigate the report/complaint, in a fair and impartial manner, taking into account all evidence to be collected with the aim of reaching reasonable conclusions as to whether an incident of violence or harassment took place within the workplace and to impose the corresponding sanctions, in order to prevent and avert any similar incident in the future.
These sanctions may include: a) recommendation for compliance, b) change of position, schedule, place or method of provision of work, c) termination of the employment contract or cooperation agreement, d) recourse to the competent police authorities e) recourse to the competent judicial authorities.
In any case, the offender may also incur criminal or civil liability, in accordance with the applicable legislation.
In the event that the investigation conducted by the company concludes that the complaint was malicious and that no incident of violence or harassment took place, the motives of the malicious complaint shall be investigated and the corresponding sanctions shall be imposed.
It is expressly noted that retaliatory actions against the complainant are strictly prohibited and the corresponding sanctions shall be imposed.
9/5/2023
The Legal Representative of MEDIMALL
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