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Workplace Harassment and Violence Prevention Policy
What is the Purpose of the Policy?
The present Policy for the Prevention of Violence and Harassment in the Workplace & for the Management of Related Internal Complaints (hereinafter the “Policy”) of Sidapharm I.K.E. (hereinafter “Sidapharm”) declares the company’s zero tolerance for incidents of violence and harassment in the workplace.
Its purpose is to ensure a safe working environment for all individuals working for the Company, through the prevention and handling of incidents of violence and harassment at work, in compliance with Articles 9 and 10 of Law 4808/2021 (ΦΕΚ 101 Α΄/ 19.06.2021), which ratified the International Labour Convention No. 190 (21.06.2021) of the International Labour Organization on the elimination of violence and harassment in the world of work, as codified in Articles 64 and 65 of Presidential Decree 80/2022 (ΦΕΚ 222 Α΄/04.12.2022).
Its purpose is to ensure a safe working environment for all individuals working for the Company, through the prevention and handling of incidents of violence and harassment at work, in compliance with Articles 9 and 10 of Law 4808/2021 (ΦΕΚ 101 Α΄/ 19.06.2021), which ratified the International Labour Convention No. 190 (21.06.2021) of the International Labour Organization on the elimination of violence and harassment in the world of work, as codified in Articles 64 and 65 of Presidential Decree 80/2022 (ΦΕΚ 222 Α΄/04.12.2022).
How Are Incidents of Violence and Harassment in the Workplace Defined?
Violence and Harassment: Means behaviors, acts, practices or threats thereof, which aim at, lead to, or may lead to physical, psychological, sexual or economic harm, whether occurring as isolated incidents or repeatedly.
Physical Violence: Means any attempt at physical assault against another person or group of persons, and/or the infliction of physical harm, and/or damage to objects or property.
Harassment / Psychological Violence: Means forms of behavior that have the purpose or effect of violating a person’s dignity and creating an intimidating, hostile, degrading, humiliating or offensive environment, irrespective of whether they constitute a form of discrimination, and includes gender-based harassment.
Gender-Based Harassment: Means forms of behavior related to a person’s gender, which have the purpose or effect of violating that person’s dignity and creating an intimidating, hostile, degrading, humiliating or offensive environment. Such behaviors also include sexual harassment under Law 3896/2010, as well as behaviors related to a person’s sexual orientation, expression, identity, or gender characteristics.
Sexual Harassment: Means any form of unwanted verbal, non‑verbal or physical conduct of a sexual nature, with the purpose or effect of violating a person’s dignity, particularly by creating an intimidating, hostile, degrading, humiliating or offensive environment.
A single incident of such conduct is sufficient to constitute sexual harassment if it affects the person’s dignity and creates an adverse environment. Such inappropriate behavior may occur not only face‑to‑face but also through social media or online.
Sexual Harassment as unethical conduct : Means sexual harassment where the rejection or non‑acceptance of such conduct by an employee is used as a criterion for a decision affecting the employment of the individual subjected to sexual harassment.
Psychological Harassment at Work: Means social interaction through which one or more individuals aim to place another individual in a position of weakness by using a chain of unethical behaviors which, although seemingly unrelated, are in fact part of a strategy to intimidate the targeted individual.The employee is subjected to psychological harassment or “bullying,” with or without the use of social media, through ongoing criticism and undermining, aggressive or obscene language, social exclusion and isolation, spreading of rumors and humiliation, hostile behavior, stalking, unjustified assignment of adverse tasks, etc.What distinguishes psychological harassment from other stress factors is its systematic, long‑term and “covert” nature, aimed at the psychological and professional exhaustion of the target. Aggression may be expressed both verbally and non‑verbally.
Domestic Violence: Means all acts of physical, sexual, psychological or economic violence occurring within family relationships, regardless of biological or legal family ties, or between former or current spouses or partners, and regardless of whether the perpetrator currently shares or previously shared the same residence as the victim.
Physical Violence: Means any attempt at physical assault against another person or group of persons, and/or the infliction of physical harm, and/or damage to objects or property.
Harassment / Psychological Violence: Means forms of behavior that have the purpose or effect of violating a person’s dignity and creating an intimidating, hostile, degrading, humiliating or offensive environment, irrespective of whether they constitute a form of discrimination, and includes gender-based harassment.
Gender-Based Harassment: Means forms of behavior related to a person’s gender, which have the purpose or effect of violating that person’s dignity and creating an intimidating, hostile, degrading, humiliating or offensive environment. Such behaviors also include sexual harassment under Law 3896/2010, as well as behaviors related to a person’s sexual orientation, expression, identity, or gender characteristics.
Sexual Harassment: Means any form of unwanted verbal, non‑verbal or physical conduct of a sexual nature, with the purpose or effect of violating a person’s dignity, particularly by creating an intimidating, hostile, degrading, humiliating or offensive environment.
A single incident of such conduct is sufficient to constitute sexual harassment if it affects the person’s dignity and creates an adverse environment. Such inappropriate behavior may occur not only face‑to‑face but also through social media or online.
Sexual Harassment as unethical conduct : Means sexual harassment where the rejection or non‑acceptance of such conduct by an employee is used as a criterion for a decision affecting the employment of the individual subjected to sexual harassment.
Psychological Harassment at Work: Means social interaction through which one or more individuals aim to place another individual in a position of weakness by using a chain of unethical behaviors which, although seemingly unrelated, are in fact part of a strategy to intimidate the targeted individual.The employee is subjected to psychological harassment or “bullying,” with or without the use of social media, through ongoing criticism and undermining, aggressive or obscene language, social exclusion and isolation, spreading of rumors and humiliation, hostile behavior, stalking, unjustified assignment of adverse tasks, etc.What distinguishes psychological harassment from other stress factors is its systematic, long‑term and “covert” nature, aimed at the psychological and professional exhaustion of the target. Aggression may be expressed both verbally and non‑verbally.
Domestic Violence: Means all acts of physical, sexual, psychological or economic violence occurring within family relationships, regardless of biological or legal family ties, or between former or current spouses or partners, and regardless of whether the perpetrator currently shares or previously shared the same residence as the victim.
How Are Incidents of Violence and Harassment in the Workplace Defined?
1. This Policy applies to all individuals who work for or provide services to the Company, regardless of their contractual status. This includes employees under contracts of dependent employment (permanent, fixed‑term, probationary, etc.), individuals engaged under service contracts, works contracts, independent services agreements, salaried mandate agreements, individuals employed through third‑party service providers, the Company’s suppliers, contractors and subcontractors and the individuals working on their behalf, as well as persons receiving training, including interns and apprentices, volunteers, pro bono collaborators, former employees whose employment relationship has ended, and individuals applying for employment.
2. For the purposes of implementing this Policy, incidents of violence and harassment may be directed against any of the persons referred to in paragraph 1 of this section or may originate from any of the persons referred to in paragraph 1 of this section, as well as from third parties.
Such incidents must occur in the context of the individual’s broader provision of work and participation in work‑related activities, notably in the following circumstances:
At the workplace, including all areas where the individual performs work, receives compensation, takes breaks—particularly for rest or meals—areas for personal hygiene and care, locker rooms, or accommodation facilities provided by the Company.
During commuting to and from work, during other work‑related travel, business trips, training activities, as well as events and social activities related to work.
During work‑related communications, including those conducted through information and communication technologies.
2. For the purposes of implementing this Policy, incidents of violence and harassment may be directed against any of the persons referred to in paragraph 1 of this section or may originate from any of the persons referred to in paragraph 1 of this section, as well as from third parties.
Such incidents must occur in the context of the individual’s broader provision of work and participation in work‑related activities, notably in the following circumstances:
At the workplace, including all areas where the individual performs work, receives compensation, takes breaks—particularly for rest or meals—areas for personal hygiene and care, locker rooms, or accommodation facilities provided by the Company.
During commuting to and from work, during other work‑related travel, business trips, training activities, as well as events and social activities related to work.
During work‑related communications, including those conducted through information and communication technologies.
Assessment of Violence & Harassment Risks
Forms of Workplace Harassment:
– malicious comments targeting employees’ personality, manner, expression, behavior, habits, or opinions
– disclosure of personal information, spreading false rumors, or defaming them,
– ridiculing or showing contempt toward them,
– attacking them with shouting or offensive remarks,
– manipulation tactics directed against them,
– non‑verbal harassing messages targeting them,
– systematically assigning tasks below their qualifications,
– frequent changes of duties without providing adequate time for training or acquiring experience,
– withholding essential information required for the performance of their duties,
– undermining their abilities by continuously and daily highlighting their mistakes and weaknesses,
– inventing rules that apply only to them while the rest of the staff is not required to follow them,
– excessive control or exposing them to adverse conditions (e.g., smoking, loud music),
– isolation tactics,
– systematically ignoring their suggestions as if they are absent,
– prohibiting others from speaking to them,
– excluding them from meetings, seminars, or social events,
– creating fabricated prerequisites for exercising their employment rights, making it discouraging for them to pursue them,
– threatening them with punishment if they submit complaints to Management,
– deliberately altering their performance evaluation to a negative assessment,
– intimidating them through violent actions (e.g., slamming a hand on the table, shutting a door in their face).
The following do not constitute harassment nor unequal treatment they are considered legitimate managerial actions:
– the application of performance criteria set by the Company
– realistic deadlines for the completion of a project
– constructive feedback on the outcome of an employee’s work
– regular performance feedback
– informing an employee of unsatisfactory performance, provided it is a fair assessment and – necessary tools, information, and knowledge have been provided for the proper execution of their duties
– remarks concerning inappropriate or unethical behavior
– changes in duties and responsibilities, provided that the initial and essential terms of the original employment contract are not altered and remain in effect
– direct supervision of employees, including setting performance expectations
– taking measures to correct performance, such as placing an employee on a performance improvement plan (PIP)
– assignment of tasks and guidance on how and when they must be completed
– requests for updates or progress reports on work tasks
– justified approval or denial of leave
– requests for documentation of absence due to health reasons, in accordance with applicable regulations
– moral or financial rewards for excellent employee performance
– the provision of constructive comments regarding job performance
– malicious comments targeting employees’ personality, manner, expression, behavior, habits, or opinions
– disclosure of personal information, spreading false rumors, or defaming them,
– ridiculing or showing contempt toward them,
– attacking them with shouting or offensive remarks,
– manipulation tactics directed against them,
– non‑verbal harassing messages targeting them,
– systematically assigning tasks below their qualifications,
– frequent changes of duties without providing adequate time for training or acquiring experience,
– withholding essential information required for the performance of their duties,
– undermining their abilities by continuously and daily highlighting their mistakes and weaknesses,
– inventing rules that apply only to them while the rest of the staff is not required to follow them,
– excessive control or exposing them to adverse conditions (e.g., smoking, loud music),
– isolation tactics,
– systematically ignoring their suggestions as if they are absent,
– prohibiting others from speaking to them,
– excluding them from meetings, seminars, or social events,
– creating fabricated prerequisites for exercising their employment rights, making it discouraging for them to pursue them,
– threatening them with punishment if they submit complaints to Management,
– deliberately altering their performance evaluation to a negative assessment,
– intimidating them through violent actions (e.g., slamming a hand on the table, shutting a door in their face).
The following do not constitute harassment nor unequal treatment they are considered legitimate managerial actions:
– the application of performance criteria set by the Company
– realistic deadlines for the completion of a project
– constructive feedback on the outcome of an employee’s work
– regular performance feedback
– informing an employee of unsatisfactory performance, provided it is a fair assessment and – necessary tools, information, and knowledge have been provided for the proper execution of their duties
– remarks concerning inappropriate or unethical behavior
– changes in duties and responsibilities, provided that the initial and essential terms of the original employment contract are not altered and remain in effect
– direct supervision of employees, including setting performance expectations
– taking measures to correct performance, such as placing an employee on a performance improvement plan (PIP)
– assignment of tasks and guidance on how and when they must be completed
– requests for updates or progress reports on work tasks
– justified approval or denial of leave
– requests for documentation of absence due to health reasons, in accordance with applicable regulations
– moral or financial rewards for excellent employee performance
– the provision of constructive comments regarding job performance
Indicative Forms of Sexual Harassment:
– any act implying physical contact without the consent of both parties (e.g., touching, grabbing, hugging)
– requests for sexual favors accompanied by implicit or explicit threats regarding the employee’s performance evaluation, promotion, or other work‑related benefits or consequences
– subtle, implied, or explicit pressure for unwanted sexual activities
– unwanted romantic or immoral proposals, or pressure for sexual intercourse
– repeated invitations to social activities outside of work (after it has been made clear that such invitations are unwelcome)
– unwelcome flirting
– obscene remarks
– various sexual innuendos
– sexually oriented gestures, verbal expressions, comments, jokes, or remarks regarding a person’s sexuality or sexual experience
– gender‑related stereotypes or stereotypical behaviors
– showing or distributing sexual material, such as displaying images, posters, calendars, graffiti, objects, advertisements, or reading materials
– indecent, unwanted, or offensive electronic messages, emails, or phone calls.
– requests for sexual favors accompanied by implicit or explicit threats regarding the employee’s performance evaluation, promotion, or other work‑related benefits or consequences
– subtle, implied, or explicit pressure for unwanted sexual activities
– unwanted romantic or immoral proposals, or pressure for sexual intercourse
– repeated invitations to social activities outside of work (after it has been made clear that such invitations are unwelcome)
– unwelcome flirting
– obscene remarks
– various sexual innuendos
– sexually oriented gestures, verbal expressions, comments, jokes, or remarks regarding a person’s sexuality or sexual experience
– gender‑related stereotypes or stereotypical behaviors
– showing or distributing sexual material, such as displaying images, posters, calendars, graffiti, objects, advertisements, or reading materials
– indecent, unwanted, or offensive electronic messages, emails, or phone calls.
Employee Awareness – Rights & Obligations
Every individual subject to this Policy has the right:
– to be treated with respect and courtesy
– not to be subjected to violent behavior, harassment (including sexual or gender‑based harassment), adverse discrimination, or intimidation
– to report any incident of unethical conduct occurring in the workplace (in accordance with this Policy, as analyzed below), without being victimized or subjected to any adverse consequence or retaliation.
Every individual subject to this Policy is obliged:
– to comply with this Policy and all applicable procedures, for the protection of both themselves and all other individuals working for the Company
– to participate in company initiatives and training programs related to violence and harassment
– to promptly report any incident of violence or harassment to the “designated contact person”
– to cooperate in the investigation of any complaint submitted under the procedure described below
– to correct their behavior when they realize that it disturbs or offends another person (colleague, partner, etc.)
– not to feel uncomfortable, ashamed, or blame themselves for the perpetrator’s behavior
– to calmly and decisively reject and address violent or harassing conduct
– to act in good faith and not submit false, inaccurate, or defamatory complaints.
– to be treated with respect and courtesy
– not to be subjected to violent behavior, harassment (including sexual or gender‑based harassment), adverse discrimination, or intimidation
– to report any incident of unethical conduct occurring in the workplace (in accordance with this Policy, as analyzed below), without being victimized or subjected to any adverse consequence or retaliation.
Every individual subject to this Policy is obliged:
– to comply with this Policy and all applicable procedures, for the protection of both themselves and all other individuals working for the Company
– to participate in company initiatives and training programs related to violence and harassment
– to promptly report any incident of violence or harassment to the “designated contact person”
– to cooperate in the investigation of any complaint submitted under the procedure described below
– to correct their behavior when they realize that it disturbs or offends another person (colleague, partner, etc.)
– not to feel uncomfortable, ashamed, or blame themselves for the perpetrator’s behavior
– to calmly and decisively reject and address violent or harassing conduct
– to act in good faith and not submit false, inaccurate, or defamatory complaints.
Obligations of Managers & Supervisors
Within the framework of this Policy, individuals who supervise or manage Departments or Divisions of the Company shall:
– demonstrate exemplary behavior while performing their duties and guide the individuals they work with through their own example
– consistently promote this Policy to all members of their teams
– actively participate in training seminars, awareness sessions, and campaigns organized by the Company
– remain vigilant for signs of violence or harassment, observing any changes in employees’ behavior or performance and seeking their feedback
– take action before violence or harassment escalates (in the early stages), providing immediate support to address the incident and ensuring adequate supervision of the working environment
– demonstrate effective conflict‑management skills
– encourage individuals to report any incidents of violence or harassment and respond promptly, seriously, appropriately, and with full respect and empathy to every report
– immediately inform the “designated contact person” upon becoming aware of any potential incident or complaint involving violence or harassment or a potential breach of relevant legislation
– demonstrate exemplary behavior while performing their duties and guide the individuals they work with through their own example
– consistently promote this Policy to all members of their teams
– actively participate in training seminars, awareness sessions, and campaigns organized by the Company
– remain vigilant for signs of violence or harassment, observing any changes in employees’ behavior or performance and seeking their feedback
– take action before violence or harassment escalates (in the early stages), providing immediate support to address the incident and ensuring adequate supervision of the working environment
– demonstrate effective conflict‑management skills
– encourage individuals to report any incidents of violence or harassment and respond promptly, seriously, appropriately, and with full respect and empathy to every report
– immediately inform the “designated contact person” upon becoming aware of any potential incident or complaint involving violence or harassment or a potential breach of relevant legislation
Obligations of the Company
Regarding incidents of violence and harassment, the Company has the following general obligations:
to receive, investigate, and manage every complaint or report, demonstrating zero tolerance for violence and harassment, ensuring confidentiality and respect for human dignity, and not obstructing the receipt, investigation, or management of such complaints or reports
to provide assistance and access to any competent public, administrative, or judicial authority during the investigation of such an incident or behavior, if requested
to provide all individuals subject to this Policy with information on potential risks of violence and harassment in the workplace, as well as relevant preventive and protective measures, including the rights and obligations of employees and the Company.
Preventive, Control, and Risk‑Mitigation Measures Against Workplace Violence and Harassment
The Company takes measures aimed at preventing incidents of violence and harassment at work. Indicatively, the Company:
– provides information to all individuals covered by this Policy regarding potential risks of violence through informational leaflets, emails, etc.
– provides appropriate periodic training to offer guidance and advice on forms of workplace violence and harassment
– uses anonymous questionnaires completed by individuals subject to this Policy to gather feedback on working conditions and receive observations or suggestions
– has appointed a “designated contact person,” who is responsible, among other tasks, for informing individuals subject to this Policy on matters related to workplace violence and harassment.
to receive, investigate, and manage every complaint or report, demonstrating zero tolerance for violence and harassment, ensuring confidentiality and respect for human dignity, and not obstructing the receipt, investigation, or management of such complaints or reports
to provide assistance and access to any competent public, administrative, or judicial authority during the investigation of such an incident or behavior, if requested
to provide all individuals subject to this Policy with information on potential risks of violence and harassment in the workplace, as well as relevant preventive and protective measures, including the rights and obligations of employees and the Company.
Preventive, Control, and Risk‑Mitigation Measures Against Workplace Violence and Harassment
The Company takes measures aimed at preventing incidents of violence and harassment at work. Indicatively, the Company:
– provides information to all individuals covered by this Policy regarding potential risks of violence through informational leaflets, emails, etc.
– provides appropriate periodic training to offer guidance and advice on forms of workplace violence and harassment
– uses anonymous questionnaires completed by individuals subject to this Policy to gather feedback on working conditions and receive observations or suggestions
– has appointed a “designated contact person,” who is responsible, among other tasks, for informing individuals subject to this Policy on matters related to workplace violence and harassment.
Measures for Addressing Incidents of Workplace Violence and Harassment
In the event of an incident or behavior that constitutes violence or harassment in the workplace, the individual who has experienced such behavior may submit an oral or written complaint to the “designated contact person.”
The complaint may be submitted in person, by email to the designated contact person’s email address listed below, or through telephone communication with the designated contact person.
Alternatively, the individual may use the reporting channels defined in the Company’s Reporting and Incident Management Policy.
The designated contact person shall immediately forward/disclose the complaint to Management, which is responsible for evaluating both named and anonymous complaints, conducting the relevant investigations, and issuing the written conclusion.
The designated contact person thoroughly investigates every credible complaint and collects any evidence necessary. In particular, they may interview the involved parties (complainant and respondent), examine witnesses, request the submission of documents that may exist and demonstrate whether any incident of violence or harassment took place, and communicate with individuals heading the Company’s departments and divisions.
Once the investigation is completed, the designated contact person submits a written report to Management, which shall issue a justified decision on the complaint and communicate its decision—accompanied by the Committee’s findings—to the involved parties (complainant and respondent) for their acknowledgement.
The investigation, submission, and communication of the findings must be completed as soon as possible and generally no later than three (3) weeks from the date the complaint was submitted by the complainant.
Management may request further investigation by the Committee or undertake additional investigative actions itself.
If an incident of violence or harassment is established, the designated contact person shall take all necessary, appropriate, and proportionate measures, as applicable.
These measures may indicatively include: – issuing a compliance recommendation
– changing the employee’s position, working hours, workplace, or manner of work
– terminating the employment contract, cooperation agreement, supply contract, or works contract with the Company.
The investigation of complaints and the issuance of decisions thereon are governed by the following principles:
• Prohibition of Retaliation and Further Victimization of the Affected Person and Any Witnesses
All complaints, regardless of how they are submitted, shall be investigated in a manner that ensures no retaliation is imposed against the complainant and/or any witnesses.
The termination—by any means—of the legal relationship on which employment is based, as well as any other adverse treatment of a person who submits a complaint regarding violence or harassment or serves as a witness to such an incident, is strictly prohibited and void if it constitutes retaliatory behavior or a countermeasure for submitting the complaint.
• Confidentiality
All individuals who receive complaints of violence or harassment are obligated to handle such matters with absolute confidentiality.
• Anonymity
If a complaint is submitted anonymously, the investigating body may seek in‑person or telephone communication if deemed necessary for the investigation.
However, if the affected person does not wish to reveal their identity, this must be fully respected and the complaint shall remain anonymous.
• Impartiality
The investigating body acts impartially and with a full sense of duty.
If, for any reason, this is not feasible, the responsible Company representative must be informed so that appropriate measures may be taken.
• Protection of Personal Data
The personal data of all involved parties are protected to the maximum possible extent, in accordance with applicable national and EU legislation on the protection of personal data, by the designated contact person, the aforementioned Ethics Committee, and the Executive Committee.
If the affected person has filed a complaint regarding the incident of violence or harassment before any administrative or judicial authority, the Company undertakes to provide any necessary assistance and support, as well as any relevant information or documents it may possess, to such authorities.
In cases where intervention by the Authorities (e.g., Police) is deemed necessary following notification by the Company, all related actions shall be carried out under the guidance of the Company’s Legal Department.
From the moment the incident is disclosed and for as long as necessary, the Company shall ensure the provision of moral and psychological support services, assistance, and reintegration support to the victim, where deemed appropriate.
In any case, the Company reserves the right not to follow the procedure described above for managing incidents of workplace violence or harassment when it has reasonable grounds to believe that the complaint, report, or grievance has been submitted in excess of the limits set by good faith and good morals, or is manifestly unfounded.
Legal Rights of Affected Individuals
Any individual who has experienced violence or harassment has the right, in addition to filing a complaint, to:
pursue any legal right available, using appropriate legal remedies and actions
– Contact the Labour Inspection Authority (SEPE): https://www.hli.gov.gr/epikoinonia — SEPE citizen hotline: 1555
– Contact the Greek Ombudsman: Chalkokondyli 17, 10432 Athens, E-mail: press@synigoros.gr, Tel.: (+30) 213 1306 600
– Contact the Immediate Psychological Support and Counseling Service for Women Victims of Gender-based Violence — SOS Line 15900
– Request a change of workplace and/or working hours for the necessary period, provided that harassment has been documented, recommendations, reprimands, or disciplinary measures have been issued, and the harassment phenomena persist
– Refrain from work for a reasonable period, without any impact on employment rights—including salary—if they reasonably believe there is a serious threat to their life, health, or safety, particularly when necessary protective measures have not been taken or when existing measures are insufficient to stop violent or harassing behavior.
In such a case, the employee is obligated to inform the Company in advance and in writing, stating the incident of violence or harassment and the facts supporting their belief of a threat to their life, health, or safety
– Claim before the Court full compensation covering any losses or damages incurred.
Special Support Measures for Victims of Domestic Violence
The Company undertakes the commitment to safeguard employment and provide support by all appropriate means to employees who are victims of domestic violence.
To implement this commitment, the Company may, indicatively, take the following actions:
– change of position, working hours, or workplace
– change in the mode of work and access to flexible forms of employment
– provision of moral and psychological support services
– assistance to facilitate communication and access to support structures.
Designated Contact Person
The designated contact person (“Liaison”) at Company level, responsible for guiding and informing employees on the prevention and handling of workplace violence and harassment, as well as for receiving oral and/or written complaints as described above, is the person appointed by the Company.
At the effective date of this Policy, the designated contact person (“Liaison”) is:
Ms. Sunita Mochindra
E-mail: intsales@sidapharm.gr
Tel.: +30 6936 343 220
The alternate designated contact person (“Liaison”) is:
Georgia Talagozi
E-mail: office@sidapharm.gr
Tel.: +30 6982 810 360
The complaint may be submitted in person, by email to the designated contact person’s email address listed below, or through telephone communication with the designated contact person.
Alternatively, the individual may use the reporting channels defined in the Company’s Reporting and Incident Management Policy.
The designated contact person shall immediately forward/disclose the complaint to Management, which is responsible for evaluating both named and anonymous complaints, conducting the relevant investigations, and issuing the written conclusion.
The designated contact person thoroughly investigates every credible complaint and collects any evidence necessary. In particular, they may interview the involved parties (complainant and respondent), examine witnesses, request the submission of documents that may exist and demonstrate whether any incident of violence or harassment took place, and communicate with individuals heading the Company’s departments and divisions.
Once the investigation is completed, the designated contact person submits a written report to Management, which shall issue a justified decision on the complaint and communicate its decision—accompanied by the Committee’s findings—to the involved parties (complainant and respondent) for their acknowledgement.
The investigation, submission, and communication of the findings must be completed as soon as possible and generally no later than three (3) weeks from the date the complaint was submitted by the complainant.
Management may request further investigation by the Committee or undertake additional investigative actions itself.
If an incident of violence or harassment is established, the designated contact person shall take all necessary, appropriate, and proportionate measures, as applicable.
These measures may indicatively include: – issuing a compliance recommendation
– changing the employee’s position, working hours, workplace, or manner of work
– terminating the employment contract, cooperation agreement, supply contract, or works contract with the Company.
The investigation of complaints and the issuance of decisions thereon are governed by the following principles:
• Prohibition of Retaliation and Further Victimization of the Affected Person and Any Witnesses
All complaints, regardless of how they are submitted, shall be investigated in a manner that ensures no retaliation is imposed against the complainant and/or any witnesses.
The termination—by any means—of the legal relationship on which employment is based, as well as any other adverse treatment of a person who submits a complaint regarding violence or harassment or serves as a witness to such an incident, is strictly prohibited and void if it constitutes retaliatory behavior or a countermeasure for submitting the complaint.
• Confidentiality
All individuals who receive complaints of violence or harassment are obligated to handle such matters with absolute confidentiality.
• Anonymity
If a complaint is submitted anonymously, the investigating body may seek in‑person or telephone communication if deemed necessary for the investigation.
However, if the affected person does not wish to reveal their identity, this must be fully respected and the complaint shall remain anonymous.
• Impartiality
The investigating body acts impartially and with a full sense of duty.
If, for any reason, this is not feasible, the responsible Company representative must be informed so that appropriate measures may be taken.
• Protection of Personal Data
The personal data of all involved parties are protected to the maximum possible extent, in accordance with applicable national and EU legislation on the protection of personal data, by the designated contact person, the aforementioned Ethics Committee, and the Executive Committee.
If the affected person has filed a complaint regarding the incident of violence or harassment before any administrative or judicial authority, the Company undertakes to provide any necessary assistance and support, as well as any relevant information or documents it may possess, to such authorities.
In cases where intervention by the Authorities (e.g., Police) is deemed necessary following notification by the Company, all related actions shall be carried out under the guidance of the Company’s Legal Department.
From the moment the incident is disclosed and for as long as necessary, the Company shall ensure the provision of moral and psychological support services, assistance, and reintegration support to the victim, where deemed appropriate.
In any case, the Company reserves the right not to follow the procedure described above for managing incidents of workplace violence or harassment when it has reasonable grounds to believe that the complaint, report, or grievance has been submitted in excess of the limits set by good faith and good morals, or is manifestly unfounded.
Legal Rights of Affected Individuals
Any individual who has experienced violence or harassment has the right, in addition to filing a complaint, to:
pursue any legal right available, using appropriate legal remedies and actions
– Contact the Labour Inspection Authority (SEPE): https://www.hli.gov.gr/epikoinonia — SEPE citizen hotline: 1555
– Contact the Greek Ombudsman: Chalkokondyli 17, 10432 Athens, E-mail: press@synigoros.gr, Tel.: (+30) 213 1306 600
– Contact the Immediate Psychological Support and Counseling Service for Women Victims of Gender-based Violence — SOS Line 15900
– Request a change of workplace and/or working hours for the necessary period, provided that harassment has been documented, recommendations, reprimands, or disciplinary measures have been issued, and the harassment phenomena persist
– Refrain from work for a reasonable period, without any impact on employment rights—including salary—if they reasonably believe there is a serious threat to their life, health, or safety, particularly when necessary protective measures have not been taken or when existing measures are insufficient to stop violent or harassing behavior.
In such a case, the employee is obligated to inform the Company in advance and in writing, stating the incident of violence or harassment and the facts supporting their belief of a threat to their life, health, or safety
– Claim before the Court full compensation covering any losses or damages incurred.
Special Support Measures for Victims of Domestic Violence
The Company undertakes the commitment to safeguard employment and provide support by all appropriate means to employees who are victims of domestic violence.
To implement this commitment, the Company may, indicatively, take the following actions:
– change of position, working hours, or workplace
– change in the mode of work and access to flexible forms of employment
– provision of moral and psychological support services
– assistance to facilitate communication and access to support structures.
Designated Contact Person
The designated contact person (“Liaison”) at Company level, responsible for guiding and informing employees on the prevention and handling of workplace violence and harassment, as well as for receiving oral and/or written complaints as described above, is the person appointed by the Company.
At the effective date of this Policy, the designated contact person (“Liaison”) is:
Ms. Sunita Mochindra
E-mail: intsales@sidapharm.gr
Tel.: +30 6936 343 220
The alternate designated contact person (“Liaison”) is:
Georgia Talagozi
E-mail: office@sidapharm.gr
Tel.: +30 6982 810 360
