Policy against Incidents of Violence and Harassment in the Workplace

1. Purpose

In the context of adhering to and implementing the commitments and core values of the Adecco Group, to which ADECCO HR SOCIETE ANONYME TEMPORARY WORK belongs, as reflected in the Code of Conduct, ADECCO HR SOCIETE ANONYME TEMPORARY WORK (hereinafter referred to as “Adecco”) is bound to maintain a place of work without discrimination, intimidation and harassment. This Policy describes Adecco’s policy of creating and maintaining a harmonious working environment with zero tolerance to any behaviour of violence, harassment, intimidation or any form of behaviour that may result in the creation of an intimidating, hostile, humiliating, degrading or aggressive environment.

In this context, Adecco has adopted all the measures and obligations relating to the implementation of the provisions of Part II of Law 4808/2021 on the prevention and management of all forms of violence and harassment, including violence and gender-based harassment and sexual harassment and through this Policy, in conjunction with other relevant Group Policies, applies the policies of Articles 9 and 10 of Law 4808/2021.

2. Scope

This Policy applies to all employees of Adecco, as well as to those who cooperate with Adecco regardless of their contractual status, such as

  • independent partners who undertake the execution of projects or the provision of services;

  • lawyers on retainer;

  • persons employed through third party service providers – suppliers;

  • persons attending training, including trainees and apprentices;

  • volunteers;

  • employees whose employment relationship has ended;

  • candidates for employment at Adecco.

The employees of Adecco who are recruited by Adecco in order to be placed at any of its clients (“Indirect Employer”) and to be temporarily employed under the supervision and management of the Indirect Employer in accordance with the provisions of Law 4052/2012, as amended and currently in force, of PD 80/2022 or any other law in force in the future for temporary employment (hereinafter referred to as “Temporary Employees”), shall be informed by the Indirect Employer of the respective policies and procedures in force in its company.

3. Definitions and examples

For the purposes of this Policy, the following definitions shall apply:

  • Violence and harassment: means any behaviour, act or practice, or threats thereof, that aim at, result in, or are likely to result in physical, psychological, sexual or economic harm, whether a single occurrence or repeated.

  • Harassment: means forms of behaviour that aim at, or result in violating the dignity of the person and the creation of an intimidating, hostile, humiliating, degrading or aggressive environment, whether or not they constitute a form of discrimination, including gender-based harassment or other forms of discrimination.

  • Gender-based harassment: means forms of behaviour related to the gender of a person which have the purpose or effect of violating that person’s dignity and creating an intimidating, hostile, humiliating, degrading or aggressive environment under Article 2 of Law 3896/2010 (GG Series I, No 107) and par. 2 of Article 2 of Law 4443/2016 (GG Series I, No 232). These forms of behaviour also include the sexual harassment of Law 3896/2010, as well as forms of behaviour related to sexual orientation, expression, identity or gender characteristics of the person, as described each time in the applicable legislation.

For the purposes of implementing this Policy, forms of violence and harassment include incidents or behaviours that occur in particular:

  • In the workplace, including public and private spaces where they are a place of work, in places where the worker is paid, takes a rest or a meal, and uses sanitary, washing and changing facilities, or in employer-provided accommodation;

  • When commuting to and from work, during work-related trips, training, events or social activities; and

  • Through work-related communications, including those enabled by information and communication technologies.

Indicative examples of such behaviours are the following:

Sexual harassment:

Any form of unwanted physical, verbal or non-verbal behaviour such as:

  • comments, adjectives, or defamatory expressions with sexual suggestions;

  • “teasing” or “jokes” of a sexual content;

  • obscene gestures, or obscene expressions;

  • images or drawings with obscene or sexual suggestions;

  • showing sexually offensive graphic materials that are not necessary for the work;

  • physical contact, such as ‘light tapping’, pinching, or touching.

Harassment on any basis occurs whenever the following occur:

  • submission to harassing behaviour, which is an explicit or implicit term or condition for employment;

  • submission to or rejection of behaviour is used as the basis for a real or tacit decision on employment, including loss of work, demotion or change of responsibilities or benefits;

  • the behaviour has an unreasonably intrusive purpose or effect on a person’s work performance or creates an intimidating, hostile or offensive work environment;

  • racist or derogatory comments based on ethnicity;

  • receiving, posting, displaying, publishing, photographing, printing, distributing pornographic, obscene, offensive or inappropriate material or material of a sexual, national, religious or racist nature;

  • use of offensive humour, including racist, religious, sexist or jokes based on ethnicity;

  • derogatory comments concerning gender, race, ethnicity, national origin, age, disability, religion, sexual orientation, gender identity or expression or any other legally protected characteristic of another person;

  • any communication or act that is harassing or discriminatory.

4. Prevention and management of violence and harassment

According to the values and commitments of the Adecco Group, such as those included in the Code of Conduct of the Group and other relevant Policies and Procedures applied by the Group each time, Adecco attaches special importance to the cultivation and maintenance of a safe and healthy working environment and harmonious relations between its employees and other persons dealing with Adecco and the employees, legal representatives, executives and in general the associates of Adecco. In this context, Adecco takes care to continuously improve and address the relevant problems by any appropriate means.

In particular, Adecco undertakes actions such as:

Ø     Cultivating a climate of open communication and encouraging all employees to report openly and without fear any prohibited practices or behaviours or incidents that come to their attention.

Ø     An assessment of the psychosocial risks, including the risks of violence and harassment, which is one of the obligations that Adecco has undertaken under the law to ensure the health and safety of its employees, as well as third parties employed on its premises. For this reason, Adecco has incorporated the relevant parameters into the Occupational Risk Assessment Study, as well as the responsibilities of the Occupational Physician in order to limit psychosocial risks and provide an additional channel of communication to the employees through regular meetings of the Occupational Physician, as they result from the corresponding framework (Law 3850/2010).

Ø     Training and information of all and in particular the Adecco executives, the heads of the individual departments and teams, in order to be able to recognise and deal with unacceptable behaviours in accordance with this Policy.

Ø     Management of complaints and reports with full confidentiality and impartiality, in order to avoid any data leakage or any form of retaliation against the parties involved.

Ø     The designation of a reference person (“Link”) to which employees, external partners, apprentices and in general all persons falling within the scope of this Policy, may be addressed, in order to be informed of measures for the prevention and management of violence and harassment in the workplace.

Ø     Measures to protect the employment and support of employees who are victims of domestic violence, by any appropriate means or reasonable adjustment. To this end, employees facing such problems may contact the Human Resources Department.

5. Reference Person (“Link”) on issues of violence and harassment

Employees and Adecco partners in general, as defined in Article 2 of this Policy, may address the person appointed by Adecco as a Reference Person (“Link”) for issues of violence and harassment as appropriate. The Reference Person is informed by Adecco of this Policy and applicable law, and of any development or updating of internal procedures, of the assessment of the relevant risks and of the good practices that Adecco applies each time to combat violence and harassment.

Any communication with the Reference Person shall remain completely confidential. In any case, the role of the Reference Person is strictly limited to informing the interested parties about the current Policy and the possibilities provided by the Policy and the current procedure for issues of violence and harassment and does not extend to the management of complaints, grievances or reports, for which the Procedure referred to in Article 6 hereof shall apply.

6. Procedure for submission of reports and complaints – Examination of reports of incidents

6.1. Complaints, Reports and Submission of Complaints

6.1.1.    Complaints, reports and submission of complaints concerning acts of harassment or retaliation which constitute a breach of this Policy shall be submitted in accordance with the Code of Conduct of the Company and the procedure described in the relevant Policy in force. Anonymous reports will also be taken seriously and investigated.

6.1.2.    The submission of such reports or complaints must be done in person or by e-mail or in writing or by telephone:

Ø     To the direct supervisor of the complainant; or

Ø     To the Human Resources department of the Company, or the Regulatory Compliance officer or the legal department or

Ø     To any member of the Board of Directors.

The person submitting the report may freely use any of the above methods of reporting and its recipients.

Any report or complaint must include an accurate and true description of specific incidents documenting unacceptable behaviour in accordance with this Policy, as well as any material documenting the reported behaviour.

6.2. Investigations

6.2.1.    Investigation and examination of complaints with impartiality and protecting the confidentiality and personal data of victims and complainants

Adecco executives who receive complaints and reports in accordance with the procedure referred to in Article 6.1 have been informed of the importance of the implementation of this Policy and must comply with the applicable legislation to combat violence and harassment, discrimination and other unacceptable behaviour in the workplace, as well as the legislation on the protection of personal data. In the context of managing such reports, Adecco may request the assistance of specialised external consultants.

In any case, complaints and reports are taken seriously and treated with impartiality and strict confidentiality.

Adecco executives must show discretion and ensure the protection of the affected persons from further victimisation or other adverse effects in the workplace.

6.2.2.    Consequences where violations are found

Adecco is committed to treating all its employees with dignity and respect.

Adecco shall investigate the complaints it receives and shall act accordingly, applying where appropriate the disciplinary penalty system as defined in the Work Regulation that Adecco may apply in accordance with labour law. In cases where disciplinary action is required, and always within the framework of applicable labour legislation, Adecco undertakes that the disciplinary procedure in force is applied consistently and fairly to all staff, while personal characteristics such as gender, national origin, religion, etc. do not affect the results of the investigation of a possible misconduct or the severity of a possible penalty.

In any case, apart from the relevant internal procedures, the consequences provided for by the applicable legislation shall apply.

6.2.3.    Cooperation and provision of any relevant information to the competent authorities, if requested.

Adecco will cooperate with the competent authorities and, where necessary, will provide the relevant authorities with any information or evidence requested regarding the investigation of incidents in accordance with this Policy. In this context, Adecco is committed to maintaining confidentiality and respect for the privacy and personal data of the parties involved.

7. Obligations and responsibilities

All Adecco executives and legal representatives are responsible for ensuring compliance with the Policy.

All those who fall within the scope of this Policy pursuant to Article 2 (employees, executives, external partners, suppliers, etc.) are responsible for supporting and implementing this Policy against harassment.

8. Rights of affected persons

Each affected person has the right to report a complaint in accordance with the Procedure of Article 6 of this Policy, while retaining any right to

Ø     Judicial protection;

Ø     Appeal before the Labour Inspectorate, the Greek Ombudsman, within the framework of their statutory powers.

Any person who is subjected to an incident of violence or harassment against him/her, if in his/her reasonable belief there is an imminent danger to his/her life, health or safety, has the right to leave the workplace, or to stop his/her work if this behaviour is linked to the provision of remote work, without salary deprivation or other adverse consequences, as defined in Article 12 of Law 4808/2021, after having previously informed Adecco in writing of the incident or incidents justifying this belief that there is a serious risk to his/her health, safety or life.

9. Prohibition of retaliation

Adecco shall not tolerate any vindictive behaviour or retaliation against any person who shall report in good faith and in accordance with the prescribed procedure, incidents of violence and harassment. Adecco encourages anyone who feels that they have received retaliatory or generally retaliatory behaviour because of such a report, to report the incident immediately following the Procedure of Article 6 of this Policy.

10. Consequences of breaches of this Policy

Any actions or behaviours that are in breach of this Policy may result in disciplinary action, to the extent that this is provided for or permitted under applicable legislation, or to take any appropriate action against the complainant in order not to repeat a similar incident in the future, including but not limited to, the recommendation for compliance, change of position or work schedule, place or manner of employment or even termination of the employment contract.

11. Confidentiality and protection of personal data

Adecco, its executives, external consultants or other partners to whom part or all of the incident investigation procedure related to the implementation of this Policy may be assigned, shall manage the various evidence and data that come to their knowledge with full confidentiality, with impartiality and with full respect for the privacy of the parties involved. Especially to the extent that the investigation of incidents includes the processing of personal data of the persons involved, the Adecco Personal Data Protection Policy is applied, as it is currently in force and is available on the official website of the Company and in the employment contracts concluded with its employees.

12. Communication with competent bodies and authorities

Adecco’s reference person on issues of violence and harassment

TITLE: The Director of the Human Resources Department (currently Ms Anastasia Stavropoulou)

CONTACT PHONE: T +30 2106930490

EMAIL ADDRESS: AdeccoGreece.HR@adecco.com

Telephone Line of the Ministry of Labour – 1555. Specifically for SEPE issues, the relevant complaints are forwarded to the Labour Inspectors, who will examine and manage them.

Labour Inspectorate (SEPE)

Complaints to the Labour Inspectorate are also made electronically through the Authority’s website. Instructions for the submission of a complaint are available at https://www.sepe.gov.gr/

Greek Ombudsman

The Greek Ombudsman https://www.synigoros.gr/, is the competent body for promoting the principle of equal treatment.