Policy for the prevention and combating of violence and harassment at work and internal complaint management procedure

Reference Person / Contact: Michaela Farmaki / Sales Administration Department / 2610-990734 ext.# 240 / farmaki@e-spetseris.gr
Responsible person for receiving complaints: George Pantelis / Sales Manager / 2610-990734 ext.# 300 / pantelis@e-spetseris.gr

EFTYCHIOS SPETSERIS S.A. adopts this Policy with the aim of preventing, dealing with and combating any form of violence and harassment that occurs during work, is related to it or results from it.
The Company expressly states that it applies zero tolerance to any form of violence, harassment, sexual harassment, gender harassment or any other behavior that offends human dignity, creates an intimidating, hostile, humiliating, degrading or aggressive work environment or may cause physical, psychological, sexual or financial harm.
This Policy is also intended to establish a clear, secure, and accessible process for submitting, receiving, investigating, and managing internal complaints or reports related to incidents of violence and harassment.

This Policy is prepared in accordance with the provisions of Law 4808/2021 on the prevention and treatment of violence and harassment at work, as the relevant regulations have been incorporated and codified in the Code of Labor Law, p.d. 62/2025, as well as in accordance with the applicable model and the instructions of M.D. 95/2026. The Policy takes into account the employer's obligations to prevent, inform, protect, investigate complaints, prohibit retaliation, cooperate with the competent authorities and take appropriate measures in case of a violation.

This Policy applies to all persons employed or cooperating with EFTYCHIOS SPETSERIS S.A., regardless of the type of their contractual or employment relationship. Indicatively, it covers employees with a full-time or part-time employment contract, employees with a work contract, independent services or a salaried mandate, temporary workers, interns, apprentices and trainees, volunteers, job applicants, as well as any third party who transacts or cooperates with the Company, such as customers, suppliers, partners. The Policy applies to incidents that take place in the workplace, in places where the employee provides work, takes a break, receives remuneration or uses sanitary facilities, locker rooms or other facilities of the Company, during travel, business trips, trainings, events or social activities related to work, as well as during work-related communication, including communication via phone, email, messaging apps, corporate systems, or social media.

For the purposes of this Policy:

• Violence and harassment are forms of behavior, acts, practices or threats thereof, isolated or repeated, that aim, lead to or may lead to physical, psychological, sexual or financial harm.
• Harassment is behavior that has as its purpose or effect the violation of the dignity of a person and the creation of an intimidating, hostile, degrading, humiliating or aggressive environment.
• Gender-based harassment is behavior that is linked to a person's gender and has as its purpose or effect the violation of their dignity and the creation of an unfavorable or offensive environment.
• Sexual harassment is any unwanted verbal, non-verbal or physical behaviour of a sexual nature, which has as its purpose or effect the insult to the dignity of a person or the creation of an intimidating, hostile, humiliating, degrading or aggressive environment.

Any behavior that may constitute violence or harassment is prohibited. Including but not limited to, verbal insults, shouting, threats, intimidation or derogatory comments, offensive jokes, innuendos or comments about gender, age, marital status, appearance, health, disability, national or social origin, religion, belief, sexual orientation, gender identity or characteristics, unwanted sexual suggestions, touching, looks, messages or comments are prohibited; sending or displaying offensive, sexually explicit or degrading material, systematic isolation, disparaging or undermining an employee, vindictive or threatening behaviour following a report or complaint, abuse of a hierarchical position or authority for the purpose of pressuring, intimidating or humiliating another person.

The above list is indicative and does not limit other behaviors that may fall under the concept of violence or harassment.

EFTYCHIOS SPETSERIS S.A. recognizes that the risks of violence and harassment may be related to the nature of the activity, the organization of work, hierarchical relationships, contact with customers, suppliers or third parties, pressure conditions, off-site work, teleworking or other special conditions.

The Company takes into account in particular risks that may concern newly hired employees, employees in positions of increased contact with third parties, employees who work alone or in isolated areas, employees with vulnerable characteristics or employees who may be more exposed to psychosocial risks. The risk assessment is reviewed periodically when the working conditions, the organization of the Company or its operating data change substantially.

EFTYCHIOS SPETSERIS S.A. takes appropriate measures to prevent, control, limit and address the risks of violence and harassment. The measures include, in particular, maintaining a working environment based on respect, dignity, cooperation and equal treatment, clearly informing all employees about the prohibition of violence and harassment, encouraging open communication with the Management, supervisors and the Reference Person, training and raising awareness among staff on the recognition and response to incidents; safe and accessible reporting and reporting channels, prompt investigation of any relevant report, evaluation of the effectiveness of measures and review where necessary.

Where required, the Company may take additional technical or organizational measures, such as improving lighting, enhancing site supervision, establishing communication procedures in emergencies, safely managing meetings with third parties, and protecting employees who work alone or in increased exposure to third parties.

The Company informs the staff about this Policy, about the risks of violence and harassment, about the available prevention and protection measures and about the complaint process.

The information can be done by posting the Policy in the workplace, sending it by e-mail, including it in printed or digital staff manuals, information meetings, trainings or any other appropriate means. The Company may organize periodic awareness-raising activities, training meetings and trainings for executives and employees for the identification, prevention and proper management of incidents of violence and harassment.

Any person who considers that he or she has been affected by an incident of violence or harassment has the right to submit an internal complaint or report in accordance with this Policy, to seek guidance from the Reference Person, to appeal to the Labour Inspectorate, the Ombudsman or the competent judicial authorities, to obtain protection from retaliation or further victimisation, to request immediate and appropriate protection measures, informing the Company in writing of the incident and the reasons for the withdrawal. The lodging of an internal complaint does not exclude or limit the right of the affected person to contact the competent authorities at any time.

All employees and associates of the Company must behave with respect, decency and professionalism, refrain from any act of violence or harassment, refrain from engaging in behaviors that offend the dignity of another person and cooperate in good faith in the event of an investigation of a report or complaint. Persons exercising managerial rights or representing the Company have an increased responsibility to prevent, recognize and deal with violent and harassment behaviors in a timely manner, not to impede the submission or investigation of complaints, to maintain confidentiality and to protect the affected persons from retaliation. The Company's Management is obliged to take all appropriate and proportionate measures to restore a safe working environment and to prevent recurrence of incidents.

The Company appoints Michaela Farmaki as the Reference Person / Liaison
Position: Sales Management Department
Phone: 2610-990734 ext. # 240
Email: farmaki@e-spetseris.gr
The role of the Reference Person is informative and supportive. The Reference Person guides and informs employees on the prevention and treatment of violence and harassment, the available communication channels, their rights and the possibilities to submit a complaint. The Reference Person must act with confidentiality, impartiality, respect for human dignity and protection of personal data.

EFTYCHIOS SPETSERIS S.A. recognizes that domestic violence can affect the safety, performance, presence and psychological state of employees. To the extent possible and depending on the circumstances, the Company may provide support to employees who are victims of domestic violence, such as flexible work arrangements, temporary change of hours, leave facilitation, change of communication, protection of personal information or referral to competent support bodies. Any relevant request is treated with discretion, confidentiality and respect.

Complaints or reports of incidents of violence and harassment may be submitted orally or in writing or by e-mail to the Reporting Person, immediate supervisor, Administration or the competent Human Resources Department, or in any other appropriate and secure way that ensures confidentiality.
The complaint should, as far as possible, include a description of the incident, date or time period, place, persons involved, any witnesses and any available evidence. The lack of complete data does not prevent the submission or initial evaluation of the report.
The Company accepts and evaluates reports in good faith, even when the facts cannot ultimately be confirmed.

Upon receipt of a complaint or report, the Company acts promptly, impartially and confidentially.
The process includes the following steps

• 1. The complaint is recorded in a secure manner and the complainant is informed that the report has been received.
• 2. An initial assessment of the incident is being carried out and it is examined whether immediate temporary protection measures are required.
• 3. A competent investigative person or team shall be appointed, without conflict of interest.
• 4. Information and data, such as documents, electronic communications, testimonies or other relevant data, are collected in compliance with the legislation on the protection of personal data.
• 5. The parties involved are given the opportunity to express their views.
• 6. The data are evaluated and a decision is taken on the appropriate measures.
• 7. The complainant shall be informed, to the extent permitted by the protection of personal data and confidentiality, of the completion of the procedure.

The investigation is carried out without undue delay. The Company seeks to complete the initial assessment within a reasonable time of receipt of the complaint and to take immediate action when there is a risk to the safety, health or dignity of any person.

During the investigation of a complaint, the Company may take interim measures to protect those involved and ensure a smooth work environment.
These measures may include, but are not limited to, temporary change of workplace, limitation of direct contact between stakeholders, temporary modification of duties, teleworking where possible, enhanced supervision or other appropriate action.
Interim measures do not constitute a penalty or a presumption of liability and are taken with a view to protecting the safety, dignity and integrity of the procedure.

The Company, the Reference Person and any competent person involved in the process must maintain strict confidentiality. The information collected in the context of a complaint is used exclusively for the purpose of investigating and managing the incident, taking action, complying with legal obligations and, where necessary, cooperating with the competent authorities.
The processing of personal data is carried out in accordance with the applicable legislation on the protection of personal data, including the General Data Protection Regulation and the Greek legislation.

EFTYCHIOS SPETSERIS S.A. absolutely prohibits any form of retaliation, adverse treatment or further victimization against a person who submits a complaint or report in good faith, provides information, testifies as a witness or participates in an investigation process. Retaliation may include, but is not limited to, dismissal, threat of dismissal, downgrading, unfavorable change of duties, change of hours as a punitive measure, exclusion from advancement opportunities, intimidation, isolation or any other adverse treatment.
Any complaint of retaliation is promptly investigated and may result in the same measures and consequences as violations of this Policy.

In the event that a violation of this Policy is found, the Company shall take the necessary, appropriate and proportionate measures, depending on the gravity of the incident, the position of the parties involved, the repetition of the behavior and the consequences for the affected person and the working environment.
The measures may include an oral or written recommendation, compulsory training or coaching, a change of duties, a change of position, a change of working hours or place of work, termination of the employment or cooperation contract, as well as any other lawful and appropriate measure. Measures are taken with respect to the principle of proportionality, labor legislation and the rights of all involved.

The Company protects all bona fide reports, even if the facts are not confirmed. However, demonstrably malicious or knowingly false complaints may constitute a violation of this Policy and may result in similar consequences.
The inability to prove an incident is not in itself considered a false or malicious complaint.

The Company cooperates with any competent public, administrative or judicial authority, if requested, and provides any necessary assistance or information within the framework of their legal responsibilities. Affected persons can contact, in particular, the Labour Inspectorate, through the citizen service line 1555, the Ombudsman, the competent judicial authorities, as well as the SOS Helpline 15900 for immediate psychological support and counselling for women victims of gender-based violence. This information is provided to be communicated to the staff and to be available in a visible place.

This Policy is posted in a prominent place at the Company's workplace and on the website and is communicated to employees by e-mail. The Company ensures that all employees, including new employees upon their recruitment, have access to the Policy and are informed of its content.

The Policy is periodically reviewed and revised when legislation, organizational structure, working conditions change or when there is a need for improvement from its implementation. Any modification to the Policy is communicated to employees in the same way as the original Policy was notified.

The Management of EFTYCHIOS SPETSERIS S.A. is committed to ensuring a safe, dignified, fair and free from any form of violence and harassment. The Company invites all employees, partners, executives and third parties who transact with it to actively contribute to the implementation of this Policy and to the maintenance of a working atmosphere of respect, trust and responsibility.