PART A’ – GENERAL PROVISIONS
1. Introduction
Α. The company under the name “G.S. TRAVEL ANONYMOUS COMMERCIAL AND TOURISM COMPANY” (hereinafter ” GS TRAVEL”) complies with all measures and obligations relating to the implementation of the provisions of Part II of Law 4808/202, codified by 5149/2024 for the prevention and treatment of all forms of violence and harassment, including gender-based violence and harassment and sexual harassment.
Β. The purpose of this policy is to create and establish a working environment that respects, promotes, and ensures human dignity and the right of every person to a workplace free from violence and harassment. GS TRAVEL declares that it recognizes and respects the right of every employee to a working environment free from violence and harassment and that it does not tolerate any such behavior, in any form, from any person.
C. This policy is adopted in accordance with Articles 9 and 10 of Law 4808/2021 and the implementing regulations.
2. Scope of Application
1. This policy applies to all GS TRAVEL employees and workers, regardless of their contractual status, including those employed on a project basis, independent contractors, salaried employees, those employed through third-party service providers, as well as individuals attending training, including interns and apprentices, volunteers, employees whose employment relationship has ended, and job applicants.
2. Forms of violent and harassing behavior against any of the above persons may occur in particular:
a) in the workplace, including public and private spaces and spaces where the employee provides work, receives remuneration, takes breaks, in particular for rest or meals, in personal hygiene and care facilities provided by GS TRAVEL.
b) during travel to and from work, other travel, trips, training, as well as events and social activities related to work; and
c) during work-related communications, including those carried out through information and communication technologies.
3. Definitions
For the purposes of this policy, the following definitions apply:
a) “violence and harassment” means any form of behavior, act, practice, or threat thereof, which aims at, leads to, or is likely to lead to physical, psychological, sexual, or economic harm, whether occurring in a single instance or repeatedly;
b) “harassment” means any form of behavior that has the purpose or effect of violating a person’s dignity and creating an intimidating, hostile, degrading, humiliating, or aggressive environment, regardless of whether they constitute a form of discrimination, and includes harassment based on gender or other grounds of discrimination;
c) “gender-based harassment” means any form of behavior related to a person’s gender that has the purpose or effect of violating that person’s dignity and creating an intimidating, hostile, degrading, humiliating, or offensive environment. Such conduct includes sexual harassment (as defined below) and conduct related to a person’s sexual orientation, expression, identity, or gender characteristics.
d) “sexual harassment” means any form of unwanted verbal, psychological, or physical conduct of a sexual nature that has the purpose or effect of violating the dignity of a person, in particular by creating an intimidating, hostile, degrading, humiliating, or offensive environment around that person.
4. Prohibition of violence and harassment at work
1. Any form of violence and harassment that occurs during work or is related to or arises from work is prohibited, including violence and harassment based on gender, religion, race, sexual orientation, and sexual harassment.
2. For example, the following are strictly prohibited:
a) comments that include expressions of a sexual nature or other malicious comments, when directed at persons who have not expressly stated their desire to receive such comments
b) comments or persistent questions about physical appearance, gender, religion, race, or sexual orientation that cause embarrassment or discomfort
c) distribution and/or display of material of a sexual nature and any other content that is offensive to human personality or dignity (e.g., photographic, digital, printed).
d) unwanted comments with sexual connotations
e) sending messages with sexual content
f) sexual gestures or acts (e.g., any unwanted physical contact with the aim of assault or pressure to engage in sexual relations)
g) persistent requests for dates
h) threats or insinuations that sexual favors can advance one’s career or that refusal to engage in sexual relations may negatively affect one’s professional progress in the company
i) use of obscene, threatening, or offensive language, including cyberbullying
j) obscene, threatening, violent, or offensive gestures
k) coercion into sexual intercourse or contact.
m) belittling or ridiculing a person or their abilities, either in private or in front of others.
PART B’ – PREVENTING AND COMBATING VIOLENCE AND HARASSMENT AT WORK
1. Assessment of the risks of violence and harassment at work
The risks arising from violence and harassment at work can be severe, both for employees and for the company itself.
More specifically, for employees, the risks include, in particular: a) Violation of human dignity and moral damage, b) Causing anxiety, stress, anger, and fear while performing work, and c) Causing psychosomatic symptoms.
Alongside its employees, the company itself faces risks such as:
A) Disruption of labor relations and the smooth operation of the company,
B) Reduced productivity,
C) Legal and financial consequences,
D) Negative publicity.
However, the measures taken by GS TRAVEL to prevent, control, and limit the risks of violence and harassment at work and to monitor and manage such incidents or forms of behavior, its actions to inform and raise awareness among its staff on issues of violence and harassment, in combination with its methods of work organization, the nature of its activities and strict compliance with the applicable legislation on health and safety at work, contribute significantly to improving the level of protection of employees and effectively addressing the associated risks.
2. Measures to prevent, control, limit, and address risks of violence and harassment at work, and to monitor such incidents or forms of behavior
GS TRAVEL adopts measures and implements administrative practices to prevent, control, limit, and address the risks of violence and harassment in the workplace as well as to monitor such incidents or forms of behavior. Indicatively, the above measures and practices include the following:
a) Adoption of a Policy for the Management of Internal Complaints of Violence and Harassment, which is included in this document (Part C), so that any complaint or related report is received, investigated, and resolved confidentially and in a manner that respects human dignity. GS TRAVEL keeps a record of reported incidents.
b) Appointment of a contact person (“liaison”) to guide and inform employees on the prevention and handling of violence and harassment at work.
c) Encouraging the maintenance of a working environment where respect for human dignity, cooperation, and mutual assistance are core values.
d) Technical measures, such as adequate lighting, etc.
e) Actions to raise employee awareness of healthy behavior patterns, as well as issues concerning vulnerable categories of employees.
f) Guidance and support for victims of violence and harassment to help them reintegrate into the workplace.
g) Assistance to any competent public, administrative, or judicial authority in investigating incidents of violence or harassment, if requested by them.
h) Regularly evaluating the effectiveness of the preventive and response measures implemented and reviewing/updating the risk assessment and measures.
i) Any other appropriate and necessary measures to achieve the objectives of this policy.
3. Actions to inform and raise awareness among staff on issues of violence and harassment
GS TRAVEL declares its zero tolerance for violence and harassment and takes the following actions to raise awareness among its staff about these issues:
a) It hereby provides its staff with information and updates on the risks of violence and harassment, as well as on the related prevention and protection measures, on the procedures in place at company level, and on the options provided by law in such cases.
b) It may organize targeted staff meetings to discuss relevant issues and address potential risks in a timely manner.
c) It may hold seminars with mental health specialists or counseling service providers, etc.
4. Information on the rights and obligations of employees and GS TRAVEL in the event of an incident, report, or complaint, as well as on the relevant procedure.
4.1 Options for those affected by incidents of violence and harassment:
4.1.1 In the case that a person is affected by an incident of violence and harassment when accessing employment, during their working or cooperation with GS TRAVEL, or even if their contract or employment relationship with GS TRAVEL, in the context of which the incident or behavior allegedly occurred, has ended, they have:
a) the right to judicial protection,
b) the right to appeal, file a complaint, and request the resolution of a labor dispute by the Labor Inspection Authority (Labor Inspectorate), within the scope of its legal powers,
c) the right to submit a report to the Ombudsman, within the scope of his legal powers as a body promoting and supervising the principle of equal treatment, and
d) the right to file a report or complaint within GS TRAVEL in accordance with the procedure for receiving and handling complaints provided for in Part C hereof. In any case, when a report or complaint of such behavior arises within GS TRAVEL, the affected person retains the right to appeal to any competent authority.
4.1.2 Furthermore, any person subject to this policy who experiences violence or harassment has the right to leave the workplace for a reasonable period of time, without loss of pay or other adverse consequences, provided that, in their reasonable opinion, there is an imminent serious risk to their life, health, or safety, especially when the perpetrator of such behavior is a person who exercises managerial authority or represents GS TRAVEL, or when GS TRAVEL does not take the necessary and appropriate measures to restore peace in the workplace, or when such measures are not sufficient to stop the violent and harassing behavior. In this case, the person leaving is required to notify the GS TRAVEL Liaison in writing in advance, stating the incident of violence and harassment and the circumstances that justify their belief that there is an imminent serious risk to their life, health, or safety. If the danger does not exist or has ceased to exist and the affected person refuses to return to the workplace, GS TRAVEL may appeal to the Labor Inspectorate with a request to resolve the dispute, applying the relevant provisions of Article 18 of Law 4808/2021, as applicable.
4.2 Contact details of the competent administrative authorities to which any affected person has the right to appeal
a) Labor Inspectorate (SEPE): The contact details of the Regional Directorates for Labor Relations Inspection are available at the following link: Contact – Labor Inspection
SEPE complaints hotline, via the citizen service line: 1555
b) Ombudsman: 17 Chalkokondili Street, 10432 Athens, E-mail: press@synigoros.gr Tel.: (+30) 213 1306 600
c) Immediate psychological support and counseling service for women, victims of gender-based violence: SOS line 15900.
4.3 Consequences of non-compliance with this policy in the context of the employment relationship
The provisions of Part C of this policy apply.
5. Appointment of a contact person (“Liaison”)
The contact person (“Liaison”) for the purposes of this policy is defined. In this capacity, the Liaison is responsible for guiding and informing those subject to this policy on the prevention and handling of violence and harassment at work, regardless of whether they are addressed to him/her in connection with an incident or complaint of violence and harassment or not. The responsibility for informing the Management is at the discretion of the Liaison. Furthermore, the Liaison is obliged to ensure the protection of Personal Data (PD), which may come to its knowledge in the course of its duties.
Furthermore, A person is appointed as the alternate Liaison, who replaces the regular Liaison in the event of any impediment or conflict of interest or suspicion of bias or for any reason that the regular Liaison is unable to handle the incident.
6. Protection of employment and support for employees who are victims of domestic violence by any appropriate means or reasonable accommodation.
GS TRAVEL, as tangible proof of its social responsibility towards the phenomenon of domestic violence, following a request from an employee who is a victim of domestic violence, may examine, on a case-by-case basis, taking into account the nature of the employee’s duties and the company’s organizational capabilities, take appropriate measures to support the employee in keeping their job and smoothly reintegrating after such incidents, especially in cases where there are minor children or children with disabilities or serious illnesses (e.g., adoption of flexible working arrangements, etc.).
PART C’ – PROCEDURE FOR RECEIVING AND EXAMINING COMPLAINTS
1. Contact details for receiving complaints
The person responsible for receiving, examining, and handling complaints or grievances from affected persons regarding violent or harassing behavior is designated as Liaison. Complaints or grievances may be submitted to the Liaison verbally (in person or by telephone) or in writing by e-mail and, in the event of any impediment or conflict of interest or suspicion of bias or for any reason that the regular Liaison is unable to handle the incident, to the alternate Liaison (via telephone or e-mail). Where reference is made to the Liaison in this policy, the alternate Liaison is also included.
2. Investigation and examination of complaints with impartiality and protection of the confidentiality and personal data of victims and those accused
GS TRAVEL and the Liaison undertake to receive and not to obstruct the receipt, investigation, and immediate handling of any complaint regarding incidents of violence or harassment, to investigate and examine the allegations impartially, objectively, and with respect for human dignity, and to take immediate measures to protect the victim. In this context:
a) Persons submitting complaints will be informed of the receipt of their complaint and the progress of its investigation. Upon completion of the investigation, GS TRAVEL will inform the complainant of the results of the investigation.
b) The Liaison, assisted, if deemed appropriate or necessary, by the legal advisor and/or other competent executives of GS TRAVEL, shall investigate the complaints, using any appropriate means, provided that this does not contravene the law and good morals. Furthermore, if it deems it appropriate or necessary, the Liaison shall inform the Management of GS TRAVEL of the complaint and the results of the relevant investigation.
c) If possible, the Liaison shall attempt to resolve the incident in a conciliatory manner before it escalates.
d) To maintain industrial peace and ensure the integrity of the investigations, GS TRAVEL may, among other actions, transfer the person involved or the person complained about, or change their working hours, workplace, or manner of work, until the investigation is completed.
e) When examining the complaint and investigating the allegations, the Liaison may have access to GS TRAVEL’s records, audiovisual material collected by it, and other appropriate means of gathering information and evidence.
f) Before taking any action or imposing any sanction, the Liaison shall invite the accused to defend themselves, unless it reasonably considers that this is not necessary either because it would endanger the person involved, or because there is irrefutable evidence regarding the commission or non-commission of the act constituting violence and harassment, or for any other reason.
g) If the incident is also an illegal act and incurs criminal or administrative penalties, the Liaison shall cooperate with the competent authorities (including, but not limited to, the courts, the public prosecutor’s office, the Labor Inspectorate, the Ombudsman, etc.).
h) GS TRAVEL and the Liaison undertake to maintain confidentiality and protect Personal Data collected in the course of performing the above duties.
3. Prohibition of retaliation against the affected person.
GS TRAVEL commits to comply with the obligation to prohibit retaliation against affected persons, in accordance with Article 13 of Law 4808/2021 and the provisions of labor law. In this context, among other things, any unfavorable treatment of an affected person is prohibited if it constitutes retaliatory behavior or countermeasures against them due to the submission of a complaint about an incident of violence and harassment.
4. Consequences of violations of this policy
If it is found that an employee or other person employed by GS TRAVEL has violated the prohibition of violence and harassment, GS TRAVEL will take the necessary, appropriate, and proportionate measures against them in order to prevent and avoid the recurrence of similar incidents or behavior. These measures may include:
a) a compliance recommendation,
b) the imposition of disciplinary action, applying the relevant provisions of Work Regulations and/or Code of Ethics & Conduct, as applicable,
c) a change of position, working hours, place, or manner of work, on a temporary or permanent basis, or
d) termination of the employment or cooperation relationship, subject to the prohibition of abuse of rights under Article 281 of the Civil Code.
Furthermore, if a complaint is deemed to have been submitted maliciously, GS TRAVEL reserves the right to take any legal action against the complainant within the framework of the employment or cooperation contract and the law.
5. Cooperation with and provision of any relevant information to the competent authorities, if requested
GS TRAVEL, the Liaison and any other person responsible for receiving and handling complaints of violence or harassment cooperate with any competent public, administrative, or judicial authority which, either on its own initiative or upon request by an affected person, within the scope of its competence, requests the provision of data or information, and commit to provide assistance and access to such data. To this end, any data collected, in any form, shall be kept in a relevant file in accordance with the provisions of the legislation on the protection of personal data.
PART D – FINAL PROVISIONS
This policy is communicated to all GS TRAVEL employees by any appropriate means and is posted in the workplace and on the company’s website.
This policy may be updated from time to time at the discretion of GS TRAVEL (including updates regarding the details of the persons responsible as needed).
Date of Issue: 16/10/2025
