Corporate Policy

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All employees of MICHAEL M. TSONTOS SA, Management and Staff, are committed to always operate within the framework of the applied regulations and the applicable legislation, having as a basic and non- negotiable aim the complete and consistent satisfaction of those interested in the existence and operation of the parties regarding the quality of its products and services and its management of enviromental issues and issues related to health and safety at work.

This commitment is implemented through the development and implementation of a Corporate Management System that fully meets the requirements of ISO 9001:2015, EN ISO 14001: 2015 and OHSAS 18001: 2007 and is characterized by:

Continuous effort for:

  • The clarification of the operating framework and its changes.
  • The search for the purpose of identifying materials, processes, products and emissions related to its operation that cause or may cause negative environmental impacts and identification and implementation of measures to avoid, reduce or control these effects wherever this is possible and economically viable.
  • The research for the purpose of identifying and evaluating the risks to the personnel, the installations, the Subcontractors and anyone affected by its operation and identification and implementation of measures to avoid, reduce or control these impacts.
  • Τhe development and maintenance of a working environment that enables the active participation of human resources, the exploitation of its potential for the benefit of the Company and the practical recognition of its offer.
  • The maintenance in full awareness of the staff and the executives on issues relatedd ot quality, enviroment and health and safety at work.
  • The ensurance of safe working conditions in all workplaces (offices and construction sites), focusing on the prevention of accidents at work and occupational diseases and taking all necessary measures of protection and preparation against emergencies.
  • The development and maintenance of communication and excellent working relationships with suppliers and subcontractors, the local community, as well as with any competent body for the proper operation of the Company and the effective management of the environmental and health and safety risks at work.
  • The periodic retrospect of the correctness of its operation and its effectiveness in managing issues related to the quality of its products and services, the environment and health and safety at work and seeking ways towards its continuous improvement.
  • The exploitation of the results from its decision-making and elimination and prevention of unwanted situations with the aim of continuously improving the products of its activity and its mode of operation.

POLICY AGAINST VIOLENCE AND HARASSMENT

MICHAEL M. TSONTOS S.A. condemns all forms of violence and harassment that occurs in the course of, linked with or arising out of work, including gender-based violence and harassment and sexual harassment, and declares its zero tolerance to incidents of violence and harassment in the workplace. Specifically:

  1. MICHAEL M. TSONTOS S.A. adheres to all measures and obligations regarding the implementation of the provisions of Law 4808/2021, Part II on preventing and combating all forms of violence and harassment, including gender-based violence and harassment and sexual harassment
  2. The purpose of this policy is to create and consolidate a work environment that respects, promotes and ensures human dignity and the right of every person to a world of work free from violence and harassment. MICHAEL M. TSONTOS S.A. recognizes, respects and protects the right of every employee to a work environment free from violence and harassment and does not tolerate any such behaviour, of any form, by any person.
  3. The present policy is adopted in accordance with Articles 9 and 10 of Law 4808/2021 and the applicable regulatory legislation, applies to the persons referred to in paragraph 1 of Article 3 of Law 4808/2021 and henceforth enters into force alongside MICHAEL M. TSONTOS S.A. Corporate Policy.

All employees of MICHAEL M. TSONTOS S.A., Management and Staff, are committed to always operating within the framework of this policy, having as their main objective A. the prevention and combating of all forms of violence and harassment and B. the effective management of such incidents should they arise.

 

Α. Preventing and combating violence and harassment at work

a) The company, in collaboration with all its departments and the competent occupational physician, assesses the risks of violence and harassment at work, by strengthening the concept of psychosocial risks in the occupational risk assessment study, taking into account any inherent risk arising from the nature of activity, job position, factors such as gender and age or other discriminatory characteristics, as well as risks concerning specific groups of employees (such as new hires).

b) The company takes measures to prevent, control, limit and combat these risks, as well as to monitor such incidents or forms of behaviour. In particular, the company:

    • promotes positive employee relations and encourages the maintenance of a working environment where respect for human dignity, collaboration and mutual aid are key values,
    • ensures open communication with the employer, supervisors and colleagues,
    • has established a reports/complaints management procedure in accordance with part B. hereof,
    • ensures that employees have the necessary training and information to perform their duties, especially in jobs that carry a greater risk of workplace violence and harassment (e.g. working in groups, working at night, on holidays and in isolated areas),
    • ensures that the working conditions are appropriate (e.g. lighting, housekeeping, security) and friendly for all employees, always in compliance with applicable law provisions,
    • takes action to raise employees’ awareness of healthy behaviour patterns (e.g. avoiding addictions), but also for issues concerning vulnerable groups of employees,
    • guides and supports victims of violence and harassment as well as victims of domestic violence in their reintegration into the workplace,
    • trains employees in violence incident management procedures,
    • evaluates on a regular basis the effectiveness of applied preventive measures and countermeasures and revises/updates the assessment of risks and measures accordingly.

c) The company takes actions to inform and raise awareness among the staff and is committed to providing personnel with information in accessible formats, depending on the case, on the risks of violence and harassment, as well as the related prevention and protection measures, the procedures applied at company level and the options given by law in case of such incidents. As part of staff awareness, the company organizes targeted meetings to discuss relevant issues and address potential risks in a timely manner. It also encourages the participation of management executives and employee representatives in training seminars on the recognition and management of risks of violence and harassment at work.

d) The company provides information on the rights and obligations of the employees and the employer, as well as the persons exercising managerial authority or representing the employer, to the extent and degree of their own responsibility, in the event of occurrence or report or complaint of such incidents, as well as on the relevant procedure for receiving and examining complaints. In case a person is affected by an incident of violence and harassment during access to employment, during the employment relationship or even if the contract or employment relationship under which the incident or conduct allegedly occurred has ended, they have the right to: i) judicial protection, ii) appeal, submit a complaint and apply for an investigation of a labour dispute at the Labour Inspectorate, within the framework of its statutory powers, iii) report to the Greek Ombudsman, within the framework of its statutory powers, as well as iv) complaint within the company in accordance with the complaint management policy. In any case, when there is a report or complaint of such behaviour within the company, the affected person retains every right to appeal to any competent authority.

Contact details for the relevant administrative authorities include:

The rights and consequences of non-compliance in the context of the employment relationship are provided for in articles 12-15 of Law 4808/2021 and are supplemented at the company level by the report/complaint procedure for incidents of violence or harassment, as adopted and described in part B. of the present policy.

e) The company designates the human resources manager as the reference person (“liaison”) responsible for guiding and informing employees in the prevention and fight against violence and harassment at work. The role of the reference person is informational; to guide and inform employees regardless of whether they address the reference person about an incident or complaint of violence and harassment or not. Employees can access the reference person in person by visiting the reference person office, by phone at (+30) 28210 88038 – ext. 710 or electronically at respect@tsontos.gr.

In any case, the reference person is committed to the protection of Personal Data, which may come to their knowledge while exercising their role.

f) The company ensures employment protection and support to employees victims of domestic violence by any appropriate means or reasonable adjustment, as possible, taking measures including the provision of special leave or flexible working arrangements at the request of the employees victims of domestic violence, in order to support them in keeping their job and in their smooth reintegration after such incidents, especially in cases where there are minor children or children with disabilities or serious illnesses.

 

Β. Procedure on the reception and review of complaints

a) The company guarantees safe and easily accessible communication channels for receiving complaints and designates the reference person/”liaison” of paragraph A.e) hereof, as the competent person within the company for receiving and examining complaints and informing the complainants. If the reference person is involved in the complaint, the complaint is submitted to the person on the next rung of the hierarchy according to the organization chart of the company.

The reference person will receive, review and manage the complaints of the affected persons about violent or harassing behaviours. Any complaint should be submitted to the competent person, either in person or via email to respect@tsontos.gr.

In any case, the reference person will inform the affected person of their right, at any stage of the procedure followed within the company, to also submit a complaint to the competent administrative authorities within the framework of their competence (Labour Inspectorate and Ombudsman) as well as to the judicial authorities, at their discretion.

b) The company, including every competent person/department thereof, undertakes to receive and not impede the receipt, investigate and promptly manage any such complaint, review and examine the complaints with impartiality and respect for human dignity, as well as take immediate measures for the protection of the victim. In this context, the reference person takes into account all the evidence and the views of the persons involved and activates the company’s Message Management Procedure, in order to adopt a decision on the merit of the complaint. In any case, it is the company’s commitment to maintain confidentiality and protect Personal Data, which are collected during the exercise of the above duties.

c) Regardless of the outcome of the complaint, any kind of retaliation and further victimization of the complainant by any employee or anyone in any way collaborating with the company is expressly prohibited. In any case, the company is committed to complying with the obligation to prohibit retaliation, in accordance with Article 13 of Law 4808/2021 and the provisions of the labour legislation. In particular, the termination of the legal relationship on which the employment is based upon is prohibited and void, as well as any other adverse treatment of the complainant, as long as it constitutes retaliatory behaviour or countermeasures: a) for reasons of gender or family status, b) when it constitutes vindictive behaviour by the employer, due to the employee’s intransigence to sexual or other harassment against them, c) when it is done as a counteraction of the employer to a protest, complaint, testimony or any other action of the affected person.

d) In the event that the prohibition of violence and harassment at work is indeed violated, there are consequences, with the company taking all the necessary, appropriate and proportionate measures on a case-by-case basis against the perpetrator, in order to prevent the reoccurrence of a similar incident or behavior in the future. Taking into account the gravity and seriousness of the violation, the measures imposed on the perpetrator may include reprimand and recommend compliance, change of position, working hours, place or method of providing services or termination of the employment or partnership relationship, subject to the prohibition of the abusive exercise of a right of Article 281 of the Civil Code.

Any person who experiences an incident of violence and harassment against them has the right to leave the workplace for a reasonable time, without loss of income or other adverse consequence, provided they previously inform the employer in writing and have reasonable justification to believe there is an imminent serious risk to their life, health or safety, in particular, when the employer is the perpetrator of such behaviour or when the employer does not take the necessary appropriate measures to restore work peace, or when these measures are not sufficient to stop the behaviour of violence and harassment. In any case, the violation of the prohibition of violence and harassment at work gives rise, among other things, to a claim for full compensation of the affected person for their direct and indirect damage, as well as moral damage.

e) The company, including every competent person/department thereof, commits itself to collaborating with every competent public, administrative or judicial authority, which, either ex officio or following the submission of an affected person’s request, within the scope of its competence, requests the provision of data or information, and undertakes to provide assistance and access to the data. For this purpose, any information collected, in any form, is kept in a relevant file in compliance with the provisions of Law 4624/2019, on the operation of Hellenic Data Protection Authority and measures for implementing Regulation (EU) 2016/679.

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