POLICIES

POLICIES

Α. Preventing and combating violence and harassment under article 9,

Β. Handling of complaints under article 10 of Law 4808/2021.

At TARGET PHARMA SOLE SHAREHOLDER LIMITED LIABILITY COMPANY (hereinafter the “Company”) safeguarding the rights of our Employees is a matter of utmost importance and, to prove this, we have undertaken to comply with all measures and obligations related to the prevention of and response to all forms of violence and harassment, including gender-based violence and harassment and sexual harassment, as well as the handling of relevant complaints.

The creation and establishment of a healthy work environment based on respect for human dignity and working without violence and harassment is our priority. Our Company recognises and respects the right of every Employee to be employed in a work environment free of violence and harassment and expressly states that it does not tolerate any such behaviour, in any form, by any person.

In light of the above, we consulted with our Employees by making them aware of the contents of this Policy and obtained their respective views on any possible objections and/or recommendations prior to the final drafting of this Policy.

More specifically:

Α. Policy on preventing and combating violence and harassment at work

1. All forms of violence and harassment, including sexual harassment and gender-based violence and harassment, occurring in the course of a person’s employment, whether directly related to or arising from it, are prohibited.

Definitions:

a) “violence and harassment” means conduct, acts, practices or threats of any kind that cause or are likely to cause physical, psychological, sexual or economic harm, whether occurring in isolation or repeatedly,

b) “harassment” means conduct of any kind which is likely to offend the dignity of a person and to create a perception of an intimidating, hostile, degrading, humiliating or offensive environment, regardless of whether such conduct involves, inter alia, sex discrimination.

c) “gender-based harassment” means conduct of any kind related to the sex of a person which has offended or is likely to offend the dignity of the person as defined in point b) above. It is clarified that such conduct includes both sexual harassment and conduct of any kind related to a person’s sexual orientation, expression, identity or gender characteristics.

Workplaces where any of the above forms of violence and harassment can be considered to take place include, in addition to the physical premises of the company where an Employee is physically present, the following:

a) all public and private areas of the company where the Employee is physically present, e.g. the management offices, the accounting department, the rest / eating / personal hygiene areas, etc.

b) places of travel to and from work, as well as other places where the Employee may be on secondment, e.g. on trips related to the nature of the work, training, and related social events.

c) the forums of communication, including both telephone communications and communications by electronic mail or communication in general.

For this reason, the Company guarantees through this Policy the undertaking of the following undermentioned actions for the purpose of protecting its Employees. Specifically, we guarantee:

a) Receiving, assessing and conducting an internal audit on any complaint lodged in full impartiality and confidentiality, respecting human dignity and ensuring that no punishment or retaliation of any kind will be imposed on the respective complainant.

b) Providing all kinds of psychological support and substantial input for access to any competent public, administrative or judicial authority.

c) Providing information on the obligations and rights of Employees, potential risks and the preventive measures taken by the Company as well as measures to protect the Employees.

d) Displaying this Policy in a prominent location in the Company’s workplace and specifically on the bulletin board, as well as notifying all Employees of this Policy either in printed and / or electronic form, as well as providing contact details to the competent administrative and judicial authorities in accordance with the applicable provisions.

In any case, however, it is clarified that we reserve the right to amend this Policy and / or the details of the reference person designated herein to receive and handle complaints of violence and harassment, after having, of course, informed the Employees.

Implementation:

a) Risk assessment:

As a Company, we are committed to assessing any possible emerging risks arising from the nature of any activity undertaken, taking into account, on the one hand, an Employee’s employment position and, on the other hand, other personal characteristics such as gender or age.

b) Risk prevention, control and response actions

In the context of implementing the Company’s commitments, as derived from the contents of this Policy, the following actions are included:

• The practical maintenance of a healthy work climate with respect for human dignity and the harmonious cooperation between Employees.
• The creation of the procedure for lodging and handling reports / complaints.
• Providing training to all Employees on their rights and obligations as well as on procedures for handling incidents of violence and raising their general awareness on issues of violence and harassment.
• Taking technical support measures such as conducting anonymous confidential surveys on the work climate and assessing the risks of violence and harassment at work, installing emergency alert notification systems, improving lighting.
• Providing practical guidance and meaningful support to any potential victims of violence and harassment.
• Continuously evaluating the measures to combat violence and harassment and any potential need to update them.

c) Information actions

The Company, through this Policy, declares its zero tolerance towards conduct of violence and harassment and commits to provide its Employees with information on emerging risks, available prevention and protection measures as well as internal procedures for reporting such incidents.

Specifically, as a Company we are committed to taking the following actions at regular intervals:

• Arranging face-to-face meetings with all Employees to hold constructive discussions and find any potential additional ways of dealing with incidents of violence and harassment.
• Arranging seminars with mental health professionals or counselling service providers, representatives of voluntary organisations, etc.

d) Rights / Obligations / Procedure

If, in the reasonable belief of an Employee, it is considered that he / she or a colleague is affected by an incident of violence and harassment during the course of and / or after the end of his / her employment, he / she has the following rights and obligations:

i) judicial protection in the substantively and territorially competent Courts,

ii) recourse to the Greek Labour Inspectorate,

iii) complaint to the Greek Ombudsman,

iv) internal complaint as set out below in the complaints handling Policy,

v) leaving the workplace for a reasonable period of time commensurate with the degree of the violation, without deduction of salary or imposition of a certain adverse consequence.

vi) In the case of voluntary leaving, the Employee must first inform the Company in writing, disclosing the facts of the conduct complained of and the reasons that, in his / her opinion, lead him / her to the conclusion that there is a serious risk to his / her life, health or safety. Of course, it must be clarified that in the event that during the Company’s review of the relevant written complaint of the Employee it is deemed that the mentioned risk is absent and the Employee refuses to return to his / her position of employment, this may trigger the Company’s right to recourse to the competent Greek Labour Inspectorate for the resolution of the relevant dispute.

• Contact details:

In the context of proper information of the Employees, this Policy as well as the access details of the competent administrative authorities, to which every affected Employee has the right of recourse (Greek Labour Inspectorate, Greek Ombudsman), will be displayed in a prominent place of the Company and specifically on the bulletin board, while similarly the contact details of the Federation of Hellenic Information Technology & Communications Enterprises will be provided through the citizens service line 1555, as well as the contact details for the provision of psychological support and counselling to the women victims on SOS Line 15900.

• Consequences and Penalties provided for

• In the event that a violation of this Policy is detected and an incident of violence and harassment is reported to have occurred in the Company’s premises, the Company is obliged to take the necessary legal and proportionate on a case-by-case basis measures against the respondent Employee, with the purpose of his / her exemplary punishment and avoidance of similar conduct in the future. In this context, the penalties provided for range from the recommendation for compliance, the change of position of employment, working hours, workplace or manner of work provision to the termination of the employment contract or the provision of services agreement, always without prejudice to the prohibition of abuse of rights under Article 281 of the Greek Civil Code.

• Any potential breach of this Policy entitles the affected Employee to claim full compensation for all his / her positive and consequential damages, as well as for his / her non-material damage.
• This Policy applies to all Employees of the Company, including its management personnel.
• It is expressly clarified that any dismissal or termination in any way of the legal relationship on which the employment is based, as well as any other unfavourable treatment of an Employee, will be considered null and void if it is deemed to constitute a form of retaliation for his / her lodged complaint.
• In any case, however, the burden of proof to rebut any claim filed before the Court or other competent authority is on the respective defendant.

e) Appointment of reference person

Mr Thanasis Mamalis is appointed as the reference person for these matters and it is envisaged that his role is, in principle, informative and concerns the provision of information to the Employees in relation to their rights and obligations.  For this reason, as the Company we guarantee the unhindered and immediate access of every Employee to the Company’s reference person. The person in question, in the context of his / her duties, must take all appropriate steps to protect the Personal Data (PD) of the Employee concerned, which may come to his / her knowledge.

f) Protection and support of Employees – victims of domestic violence

Incidents of domestic violence form also part of the framework of the implementation of this Policy, which includes, in addition to the protection of the employment itself, the granting of special leave or other work arrangements in order to support the Employee and his / her smooth reintegration into his / her employment.

Β. Policy for handling complaints at work

As a Company, we guarantee the effective handling of relevant complaints of violence and harassment at work and to this end we have ensured to take relevant measures for the receipt and review of pertinent complaints. Specifically, as a Company we are committed to the following:

a) The provision of secure, confidential and easily accessible channels of communication and the consequent appointment of a reference person within the Company to receive and review the relevant complaints and provide appropriate guidance to the complainants,

b) Conducting an internal investigation to review relevant complaints in an objective, impartial and fully confidential manner and safeguarding the personal data of each individual,

c) Prohibiting the imposition of any kind of penalties that may be considered as vindictive behaviour against the affected Employee and the complainant,

d) a description of the consequences upon establishment of breaches,

e) Providing practical and meaningful assistance to the Employee in case he / she wishes to have recourse to the competent authorities.

More specifically:

A) Secure, confidential and easily accessible communication channels:

Mr Thanasis Mamalis has been appointed as the Company’s reference person and who, in the course of the exercise of his duties, is obliged to receive and review objectively and impartially any complaints of affected Employees in relation to incidents that, in their opinion, constitute a violation of the Policy against Violence and Harassment at Work.

No restrictions are imposed by Law upon the selection of the reference person in question and it is not excluded that this specific person may form part of the Company’s staff or may merely cooperate with the Company for the performance of this duty alone.

The reference person in question is obliged, within the context of his / her duties, to adequately inform the affected Employee of his / her rights, including the right of recourse either to the substantively competent administrative authorities and / or to the substantively competent judicial authorities.

In any case, however, it is clarified that the Company has taken all the measures required by Law in terms of providing communication channels to report unlawful conduct in relation to the matters expressly mentioned in this Policy.

How to lodge a complaint about a Harassment incident:

It is at the discretion and choice of each Employee to lodge a complaint, by name or anonymously, of an incident related to a violation of applicable Law and this Policy, through the use of the reporting methods provided below:

E-mail: harassment@targetpharma.gr

By postal delivery to the following address:

TARGET PHARMA SOLE SHAREHOLDER LIMITED LIABILITY COMPANY – Complaints Reception Office, Menandrou 54, Athens 104 31

For instructions on how to submit a complaint, click here

B) Internal investigation / review of complaints with objectivity, impartiality, confidentiality and safeguarding of personal data:

The Company is committed to the seamless receipt and investigation of complaints in relation to incidents of violation of the Policy against Violence and Harassment at work and the provision of the legally required facilities to lodge a relevant complaint. In the context of assuming this obligation as a Company, we guarantee the observance of a regime of full objectivity, impartiality, confidentiality and the appropriate protection of Personal Data (PD) collected during the execution of actions to protect affected Employees.

This Policy outlines the procedure to be followed in the investigation and review of Policy-related complaints during the evidence gathering and decision-making stage as well as any cooperation with the competent state institutions. In addition, the role and duties of the Company’s reference person are specified upon receipt of a relevant complaint.

C) Prohibition of imposition of penalties against the affected Employee:

The Company is committed to ensuring the prohibition of imposition of penalties against an Employee who lodges a complaint about unlawful conduct related to this Policy.

D) Description of consequences in case of violation:

It is the Company’s obligation and commitment to take all those measures required by law to ensure the protection of its Employees and to ensure the imposition of the necessary proportionate penalties against the respondent persons in order to avoid similar conduct in the future. The penalties in question range from the recommendation for compliance, the change of position of employment, working hours, workplace or manner of work provision to the termination of the employment contract or the provision of services agreement, always without prejudice to the prohibition of abuse of rights under Article 281 of the Greek Civil Code.

E) Cooperation and provision of information to the competent authorities:

It is the obligation and commitment of the Company and its competent reference person, on the one hand, to receive and investigate a complaint related to this Policy and, on the other hand, to cooperate and provide information to any public, administrative or judicial authority competent for this purpose, within the framework of whose competence is the examination of pertinent complaints.

In the case of any amendment to this Policy, the Company has the same obligation to consult and inform our Employees.

Drawn up and signed for the Company
Athens, 03 October 2022

The Legal Representative
Tsalikis Theodoros, son of Georgios
Tax Identification Number: 008358053
Tax Office: Fourth Tax Office of Athens
Irakleitou 8, 106 73 Athens