Violence Prevention Policy

Company: SIGMA & KAPA EISAGOGIKI S.A.

Company: SIGMA & KAPA EISAGOGIKI S.A.

Employer – Legal Representative Details

LAST NAME: PAPAIΟANNOU

FIRST NAME: VALASIA

FATHER’S NAME: SOTIRIOS

1/ Purpose

Sigma & Kappa Eisagogiki S.A. complies with all measures and obligations regarding the implementation of Part II of Law 4808/2021 for the prevention and management of all forms of violence and harassment, including gender-based violence and harassment, and sexual harassment.

The purpose of this policy is to create and establish a working environment that respects, promotes, and safeguards human dignity and the right of every person to work free from violence and harassment. Sigma & Kappa Eisagogiki S.A. acknowledges and respects every employee’s right to a workplace free from violence and harassment and does not tolerate such behavior of any kind from anyone.

This policy is adopted in accordance with Articles 9 and 10 of Law 4808/2021 and the regulatory legislation implemented accordingly, covering the persons defined in paragraph 1 of Article 3 of Law 4808/2021.

This policy establishes a framework for preventing, addressing, and combating violence and sexual harassment at work.

2/ Scope of Application

This policy applies to all employees and personnel working at Sigma & Kappa Importing S.A., regardless of their contractual status, including individuals working under service or freelance contracts, mandate agreements, third-party service providers, trainees, apprentices, interns, volunteers, and even former employees.

3/ Definitions

For the purposes of this policy:

a) “Violence and harassment” refers to behaviors, actions, practices, or threats thereof, that aim at, lead to, or may lead to physical, psychological, sexual, or economic harm, whether occurring once or repeatedly.

b) “Harassment” refers to behavior that violates a person’s dignity and creates an intimidating, hostile, degrading, humiliating, or offensive environment, regardless of whether it constitutes a form of discrimination. It includes gender-based harassment or harassment based on other grounds.

c) “Gender-based harassment” refers to behavior linked to a person’s gender that violates their dignity and creates an intimidating, hostile, degrading, humiliating, or offensive environment as defined in Article 2 of Law 3896/2010 and paragraph 2 of Article 2 of Law 4443/2016. These forms of behavior include sexual harassment under Law 3896/2010, as well as forms of behavior related to a person’s sexual orientation, expression, identity or gender characteristics. 

The above forms of behavior, violence and harassment against the persons referred to in Article 3 may take place in particular: 

  • At the workplace including public and private places and places where the employee provides work, receives remuneration, takes a break in particular, for rest or for meals, in personal hygiene and care areas, changing rooms or accommodation provided by the employer,
  • Commuting to and from work, other travel, travel, education, as well as work-related events and social activities,
  • In work-related communications, including those via information and communication technologies.


4/ Prohibition of Violence and Harassment in the Workplace

Any form of violence or harassment during or in connection with work is strictly prohibited, including gender-based violence, religious or racial harassment, sexual orientation discrimination, and sexual harassment.

Strictly prohibited behaviors include:

  • Sexually explicit or malicious comments
  • Comments or persistent remarks about appearance, gender, religion, race, or sexual orientation
  • Trafficking and/or displaying sexual material and any other content offensive to human personality or dignity (e.g. photographic, digital, printed)
  • Unwanted sexual innuendos or gestures
  • Sending sexually explicit messages
  • Unwelcome physical contact or sexual advances (e.g. any unwanted physical contact, with the aim of assaulting or coercing into sexual relations)
  • Persistent requests for dates
  • Threats implying negative career impacts for refusing sexual advances
  • Threatening/offensive language, including cyberbullying
  • Obscene, threatening, violent or offensive gestures 
  • Coercion into sexual acts
  • Ridiculing or demeaning someone or his abilities in private or in public

Prevention and Combating of Violence and Harassment

a) Assessing the risks of violence and harassment at work:

Sigma and Kapa Eisagogiki assesses the risks of violence and harassment at work by taking into account factors such as the nature of the activity, the job position, gender and age, as well as other characteristics that may constitute grounds for discrimination. It also assesses the risks of specific groups of employees (e.g. new hires).

More specifically, for employee, the risks include in particular:

  • Violation of human dignity and causing non-material damage
  • Causing anxiety, stress, anger and fear while performing work
  • Causing psychosomatic symptoms (such as headaches, tachycardia and increased blood pressure, sleep disorders, etc.)

The company also faces risks such as:

  • Disruption of operations and employee relations
  • Reduced productivity
  • Legal and financial consequences
  • Reputational damage

Sigma and Kapa Eisagogiki encourages seamless communication and undertakes to examine with absolute confidentiality and impartiality any reported behavior that offends human dignity and offends the honor and reputation of any employee. To this end, it will take all the necessary measures each time.

b) Measures to prevent, control, limit and address such risks, as well as to monitor such incidents or forms of behavior:

S and K Eisagogiki takes all necessary measures to prevent, control, limit and address these risks, as well as to monitor such incidents or forms of behavior. The company strives and encourages the maintenance of a working climate where respect for human dignity, cooperation and mutual assistance are core values.

More specifically:

– This policy is communicated to all employees of the company, posted in a prominent place in the employees’ workplace, as well as on the company’s website. In this way, the company tries to cultivate a healthy working climate and encourage open communication with the employer and immediate superiors and colleagues.

– A reference person (“contact person”) is appointed to guide and inform employees regarding the prevention and treatment of violence and harassment at work.

– S and K Eisagogiki ensures that all employees have the necessary training/information to perform their duties, especially in jobs that have a higher risk of incidents of violence and harassment.

– Training of the company’s personnel will take place, which will include informing them about the forms of harassment and violence, the responsibilities regarding any reported incidents and the appropriate way to handle incidents that come to their attention.

– Technical measures are taken, such as cleanliness, appropriate lighting of the workplace and security.

– The company provides guidance and support to victims of violence and harassment or victims of domestic violence for their reintegration into the workplace.

– The company provides assistance to any competent public, administrative or judicial authority, when investigating incidents of violence or harassment, if requested by them.

– The company regularly evaluates the effectiveness of the implemented preventive and response measures and reviews/updates the risk assessment and measures.

c) actions to inform and raise awareness among staff,

S and K Eisagogiki communicates this policy to all employees of the company, posts it in a visible place in the employees’ workplace, as well as on the company’s website and ensures that all employees have received, studied and signed it and that they are aware of the company’s procedures regarding incidents of violence and harassment, as well as where they can contact in a similar case.

d) information on the employees and employer’s rights and obligations, as well as of persons exercising managerial authority or representing the employer, to the extent of their own responsibility, in the event of an occurrence or report or complaint of such incidents, as well as on the relevant procedure

Regarding the possibilities of the affected party:

In the event that a person is affected by an incident of violence and harassment at work, he has: a) the right to judicial protection, b) to appeal, submit a complaint and request for a labor dispute to the Labor Inspectorate, within the framework of its statutory responsibilities, c) to report to the Greek Ombudsman Independent Authority, within the framework of its statutory responsibilities, as well as d) to file a complaint within the company in accordance with the complaints management policy. In any case, when a report or complaint of such behavior occurs within the company, the affected person retains every right to appeal to any competent authority.

Contact details of competent public authorities:

– Greek Ombudsman Independent Authority, 17, Chalkokondyli str., P.C. 104 32 Athens E-mail: press@synigoros.gr Tel: (+30) 213 1306 600

– Labor Inspection Body (S.E.P.E.) Contact details of Regional Directorates of Labor Relations Inspection, available at https://ypergasias.gov.gr/

– SEPE complaint telephone line 15512

– Citizen service telephone line 1555

The immediate assistance mechanisms are as follows:

– SOS line 15900 – A national service that enables women victims of violence or third parties to immediately contact a gender-based violence prevention agency. The line is staffed by psychologists and sociologists who provide immediate assistance in emergency and urgent incidents of violence on a 24-hour basis, 365 days a year.

– At the same time, there is the possibility of electronic communication for women via the e-mail address: sos15900@isotita.gr.

– 197 Telephone Line of the National Center for Social Solidarity (for calls outside the prefecture 210-197). People of all ages can anonymously request help and be informed about specialized psychosocial support and social solidarity services 24 hours a day, 365 days a year.

e) designation of a reference person (“contact”) for the guidance and information of employees regarding the prevention and treatment of violence and harassment at work,

PAOLINELI PAOLA is designated as the Reference Person for the guidance and information of employees regarding the policy for the prevention and treatment of violence and harassment.

Her role is informative and consists of guiding and informing employees, regardless of whether they contact her regarding an incident or a complaint about an incident of violence and harassment or not.

f) protection of employment and support for employees who are victims of domestic violence, to the extent possible, by any appropriate means or reasonable adaptation, 

S and K Eisagogiki recognizes that it has a social responsibility towards the phenomenon of domestic violence and demonstrates particular sensitivity to individuals who are its victims, whom it actively supports in the performance of their work and their smooth reintegration after such incidents. 

Procedure for receiving and examining complaints

a) communication channels – competent persons

Any employee against whom any incident of violence and harassment has occurred may submit a written complaint to PAOLINELI PAOLA, who is designated as Responsible for compliance with this policy. The complaint may be submitted in person or via email, specifically to the email address hrpaolineli@skimport.gr.

b) investigation and examination of complaints with impartiality and protection of the confidentiality and personal data of victims and complainants,

The employer and any competent person are committed to receiving and not preventing the receipt, to investigating and immediately managing each such complaint, to investigating and examining the complaints with impartiality and respect for human dignity, as well as to taking immediate measures to protect the affected person.

It is also provided that in any case, the aforementioned persons or services are committed to maintaining confidentiality and protecting Personal Data (PD), which are collected during the performance of the aforementioned duties.

In the context of the investigation of complaints, there will be discussions with the complainant, the person against whom the complaint is directed and any witnesses who may exist. 

Once the investigation is complete, a written report will be forwarded to the administration with the results of the investigation. The results of the investigation are communicated to both the complainant and the person against whom the complaint is directed, so that they can be informed. 

c) the prohibition of retaliation against the affected person,

S and K Eisagogiki undertakes to comply with the obligation to prohibit retaliation, in accordance with article 13 of Law 4808/2021 and with the provisions of labor legislation.

d) the description of the consequences of detected violations,

In the event that any incident of violence and harassment is detected and documented, S and K Eisagogiki proceeds, on a case-by-case basis, to take all necessary, appropriate and proportionate measures against the complainant, in order to prevent a similar incident or behavior from recurring.

Depending on the severity of the incident, these measures may include, but are not limited to: a) a written recommendation for compliance, b) a change in the job position, hours, place and method of work of the person against whom the complaint is directed, c) termination of the employment contract or cooperation with the company.

e) cooperation and provision of any relevant information to the competent authorities, if requested,

S and K Eisagogiki declares that, if requested, intends to cooperate with any competent public, administrative or judicial authority, which, either ex officio or following a request from an affected person, within the framework of its competence, requests the provision of data or information and is committed to providing assistance and access to the data (paragraph 1 of article 5 of law 4808/2021).

This policy is communicated to all employees of S and K Eisagogiki by any appropriate means and is posted in the workplaces and on the company’s website.

This policy may be revised – amended to be fully harmonized with the relevant legislation.

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