POLICY FOR THE PREVENTION AND ADDRESSING OF
VIOLENCE AND HARASSMENT IN THE WORKPLACE

ICR IOANNOU S.A. is committed to ensuring a safe, dignified and respectful work environment, free from any form of violence, harassment or discrimination.

In compliance with Law 4808/2021, which incorporates ILO Convention 190 on the elimination of violence and harassment in the world of work, the company implements a Zero-Tolerance Policy against any related behaviour.

1. Scope of Application

This policy applies to:

• All employees, regardless of employment type or contractual relationship
• Job applicants
• Trainees and apprentices
• External partners, suppliers and any third party interacting with the company

The policy covers incidents occurring:

• On company premises
• During work-related travel, meetings or training
• Through electronic or other communication channels used for work purposes

2. Definitions

“Violence and harassment” refers to behaviors, acts, practices or threats, which aim to or result in causing physical, psychological, sexual or economic harm to an individual.

Indicative forms include:

• Verbal or physical aggression
• Psychological pressure or intimidation (mobbing)
• Sexual harassment
• Offensive, degrading or humiliating behaviour
• Retaliation against any employee who submits a report or cooperates in an investigation

3. Zero-Tolerance Statement

ICR IOANNOU S.A.:

• Does not tolerate any form of violence or harassment
• Ensures confidentiality and impartiality in the handling of all reports
• Protects employees from retaliation

Any violation of this policy may lead to disciplinary action, in accordance with the applicable labour legislation and the company’s internal regulations.

4. Prohibition of Retaliation

Any form of retaliation or adverse treatment towards an employee who submits a report or participates in an investigation is strictly prohibited.

Any form of retaliation constitutes a disciplinary offence and may result in sanctions.

5. Reporting Procedure

Any employee may submit a report or complaint:

• To their direct supervisor
• To the Human Resources Department
• In written or verbal form

All reports are handled promptly, confidentially and with full respect for personal data.

The designated Contact Person for matters of violence and harassment is:

Niki Sofi – Business Operations Manager & HR Lead (n.sofi@icr-ioannou.gr)

The Contact Person is responsible for providing information, receiving reports and guiding employees throughout the process.

The reporting and investigation procedure is carried out in accordance with the principles of objectivity, impartiality and confidentiality.
The main stages include:

• receipt of the report,
• initial assessment,
• investigation of the facts,
• communication with involved parties
• and decision-making.

Detailed guidance is provided to employees by the HR Department and the Contact Person and are implemented in accordance with this policy.

6. Prevention and Awareness

The company ensures:

• Ongoing information and training for employees
• Promotion of a culture of respect and equality
• Continuous evaluation of the effectiveness of this policy

7. Risk Assessment

The company has carried out an assessment of the risks related to potential incidents of violence and harassment across departments and job roles, in accordance with legal requirements.
This assessment is reviewed periodically, and its findings are taken into account when designing preventive and protective measures.

8. Support for Victims of Domestic Violence

ICR IOANNOU S.A. provides support to employees who are victims of domestic violence, including adjustments to working hours, leave provisions and guidance on available public and social support services, in line with the applicable protection framework.

This policy forms an integral part of the corporate culture of ICR IOANNOU S.A and it is effective from the date of its publication on the company’s official website.