The Psychiatric Clinic of Drama S.A. “Agia Irini”, demonstrating zero tolerance for incidents of violence and harassment in the workplace, adopts the present policy in compliance with Articles 9 and 10 of Law 4808/2021, which ratified the International Labour Organization (ILO) Convention No. 190/21.06.2021 on the elimination of violence and harassment in the world of work, incorporating its text into national law.
- Purpose
The purpose of this policy is to create and consolidate a work environment that respects, promotes, and safeguards human dignity and the right of every person to a workplace free from discrimination, violence, and harassment.
The Psychiatric Clinic of Drama “Agia Irini” affirms that it recognizes, respects, and protects the right of every employee to work in an environment free from violence and harassment and will not tolerate any such behaviour in any form from any person.
- Scope – Covered Persons
This policy applies to all persons referred to in Article 3(1) of Law 4808/2021 and covers all individuals working for or associated with the Clinic, regardless of contractual status, including but not limited to: employees, contractors, service providers, trainees, apprentices, volunteers, former employees, job applicants, and other persons collaborating or interacting with the Clinic.
- Prohibited Conduct – Definitions
Violence and harassment: Behaviour, acts, practices, or threats thereof, intended or likely to result in physical, psychological, sexual, or economic harm, whether occurring as isolated incidents or repeatedly.
Harassment: Behaviour that aims at or results in violating a person’s dignity and creating an intimidating, hostile, humiliating, or offensive environment, regardless of whether it constitutes a form of discrimination; includes harassment based on sex or other protected grounds.
Sex-based harassment: Behaviour related to a person’s sex, including sexual harassment as defined by national law, as well as behaviour related to sexual orientation, gender identity, gender expression, or sex characteristics, that violates the person’s dignity and creates an intimidating, hostile, humiliating, or offensive environment.
Discrimination: Unjustified differential treatment based on prejudice or interest, including discrimination on the grounds of gender, age, language, nationality, ethnicity, disability, religion, or sexual orientation.
Examples of prohibited behaviour include, but are not limited to: discriminatory insults, threats, verbal abuse, intimidation, humiliation, physical violence or assault, persistent unwarranted criticism, offensive comments or jokes (including sexist or racist jokes), sexual propositions or quid-pro-quo offers, retaliation following rejection of sexual advances, online harassment (via SMS, email, social media), intrusive personal questions, offensive visual materials, unwanted physical contact, stalking, violation of privacy, and obstruction of normal work activities.
Permissible workplace behaviour: Legitimate supervision, performance feedback, assignment of tasks, requests for progress updates, lawful approval or refusal of leave, and recognition or rewards for good performance do not constitute violence or harassment.
- Workplace Scope
Prohibited behaviour may occur within all Clinic premises, in areas such as workstations, break rooms, sanitary facilities, and extends to work-related travel, conferences, training, work-related social events, and any communications (including email, videoconferencing, and social media) connected to the Clinic.
Domestic Violence
Domestic violence, including physical, psychological, sexual, or economic abuse by a current or former partner or family member, is recognized as a serious form of workplace violence when it manifests in the workplace (e.g., stalking, harassment during working hours or remote work).
- Risk Assessment
The Clinic, in cooperation with all departments and the occupational physician, identifies and evaluates risk factors—including psychosocial risks—related to violence and harassment in order to adjust working conditions and minimise the likelihood of incidents.
Indicative factors: high-stress work environments, isolated work areas, late-night shifts, insufficient training, individuals with a history of violent behaviour, delivery of goods or services under high pressure.
The Clinic also organises seminars, distributes information materials, and provides regular staff training to raise awareness of unacceptable behaviours and promote a culture of respect and dignity.
- Preventive Measures
The Clinic:
Informs staff of their rights and available remedies, including judicial protection, recourse to the Labour Inspectorate, and the Ombudsman.
Publicly posts contact details for competent authorities, including the Labour Inspectorate helpline 15512, the Citizens’ Service line 1555, and the SOS 15900 helpline for victims of gender-based violence.
Provides support and reasonable workplace accommodations to employees who are victims of domestic violence.
Trains managers and supervisors to recognize discrimination, violence, and harassment and to support affected employees.
Encourages participation in external training programmes and seminars on preventing and addressing workplace violence and harassment.
- Internal Complaints Procedure – Reference Person – Committee
Any employee who experiences violence or harassment may submit a verbal or written complaint to Ms Elpida Kyrilidou, Vice-President of the Board of Directors, designated as the Reference Person for this policy.
Complaints may be submitted in person or by email to elpkyr@hotmail.com and must include the identity of the alleged perpetrator and a description of the incident(s). Anonymous complaints cannot be processed.
The Reference Person investigates each complaint confidentially, may interview the complainant, the respondent, and witnesses, and may request relevant documents. Upon completing the investigation—ideally within 30 days—the Reference Person submits a written report to the Clinic’s Management and informs both complainant and respondent of the findings.
Where a violation is established, Management may impose appropriate measures, such as:
verbal or written warning, reprimand, financial penalty, temporary suspension, termination of employment or collaboration.
Malicious or unfounded complaints will be deemed inadmissible and may be further investigated by the Clinic.
The Vice-President of the Board of Directors chairs a three-member Committee for the Prevention and Response to Violence and Harassment in the Workplace, including one representative of employees (appointed by the Workers’ Union) and one representative of the scientific staff (appointed by the Scientific Director). The Committee acts in an advisory capacity to Management and meets as convened by its Chair.
- Rights of Affected Persons
In line with the law, any individual exposed to violence or harassment at work may leave the workplace for a reasonable period without loss of pay if they reasonably believe there is an imminent serious risk to their life, health, or safety—particularly when the perpetrator is the employer or when the employer fails to take adequate protective measures.
Such departure must be preceded by written notification to the Reference Person detailing the incident and the grounds for believing that there is imminent danger.
Affected persons retain the right to seek judicial protection, file complaints with the Labour Inspectorate, and report to the Ombudsman.
- Impartiality and Confidentiality
The Reference Person and the Management must act objectively, impartially, and with full respect for confidentiality. Disclosure of information to unauthorised parties is strictly prohibited.
- Prohibition of Retaliation
Any form of retaliation or victimisation against a complainant is strictly prohibited and constitutes a serious violation of this policy, subject to appropriate disciplinary measures.
- Cooperation with Authorities
The Clinic and its designated persons cooperate fully with public, administrative, and judicial authorities, providing necessary information in accordance with applicable legislation, including data-protection provisions of Law 4624/2019 implementing the EU GDPR.
For further information regarding this policy, please contact Ms Elpida Kyrilidou, Vice-President of the Board of Directors.
Drama, 5 July 2023
The President & CEO: Achilleas Papadopoulos
Legal Counsel: Anastasios Poulios
