KYKNOS advocates strongly against any form of violence or harassment at work including violence and harassment due to gender and shows zero tolerance to any kind of behaviour likely to be considered as such.

KYKNOS is aware of the importance of the relevant regulations and the individual obligations imposed by the applicable laws. KYKNOS applies the measures and the actions and abides by the obligations deriving from the provisions of Part II of Law no. 4808/2021 and the empowering provisions thereof. In this context and as per the provisions of Articles 9 and 10 of Law no. 4808/2021 (Part II) KYKNOS has shaped and developed the policies set out in and adopted under this document, which specify the rights and obligations of the employees and the employer with regard to any form of violent behaviour or harassment at work, as well as measures applied in order to prevent and fight against the relevant risks.

The purpose of such policies is the consolidation, enhancement and further assurance of a healthy work environment that respects, promotes and ensures adherence to human dignity and the right of each individual to be in a workplace and work without facing any form of violence and harassment and without fearing to be exposed to such risks.


As “violence and harassment” are understood the forms of behaviour, the acts, the practices or threat thereof aiming at, leading to or likely to lead to corporal, psychological, sexual or financial harm and occurring either once or repeatedly.

As harassment” are understood the forms of behaviour aiming at or resulting in the offence of the person’s dignity and the creation of an intimidating, hostile, degrading, humiliating or aggressive environment, irrespective of whether such forms of behaviour constitute a form of discrimination and comprise also harassment due to gender or other reasons of discrimination.

As “harassment due to gender” are understood the forms of behaviour relating to a person’s gender and aiming at or resulting in the offence of the person’s dignity and the creation of an intimidating, hostile, degrading, humiliating or aggressive environment. Such forms of behaviour also comprise sexual harassment as well as forms of behaviour relating to sexual orientation, or a person’s sexual expression, identity or features.

The term “company” or “employer” means KYKNOS.

The term “employees” means the employees of KYKNOS in Greece or of the individual companies being the group’s members from the business point of view, irrespective of the contractual status of their employment, under either permanent or fixed term agreements entered into either directly or through third-party providers (employees that are borrowed genuinely and by profession).

The term “employees employed through other third-party employers” means: (a) the employees employed under employment agreements or relationships with temporary employment undertakings (T.E.U.), and (b) the employees made available in order to provide their work services to another employer (secondary / user employer) under a written genuine borrowing agreement.

The term “other employees” means all the employees, except those engaged under an employment agreement, including those employed under a contract for independent services or a work contract and all apprentices, any employee employment of whom has been terminated as well as people seeking employment and people employed in the informal economy.

As “policies” are understood the policies adopted under this document and more specifically those aiming at (a) preventing and fighting against violence and harassment at work, and (b) managing internal complaints.


The policies are addressed and apply to all employees, people employed through third-party employers and other employees of the company irrespective of the contractual status of their employment. Especially as regards people employed through third-party employers, in case of infringement of the ban of any form of violence and harassment by a borrowed employee, the relevant file shall be transmitted by KYKNOS to the Temporary Employment Undertaking (T.E.U,) or to the initial employer (depending on whether such borrowing is made by profession or is genuine respectively), as enforcement of disciplinary power remains vested with them.

The employees providing their services to the facilities of KYKNOS on behalf of other undertakings (contractors) cooperating with KYKNOS must comply with the rules of KYKNOS’s policies. However, such employees are not subject to KYKNOS’s disciplinary power but to the disciplinary power of their employer company which remains fully liable in case of disciplinary offence from its employees’ part.


Harassment and violence risks at work
KYKNOS shows zero tolerance towards any conduct constituting violence or harassment at work against its employees and other people working for it. Nevertheless, such fact does not exclude completely the risk of any employee manifesting a hostile or intimidating behaviour or any other form of violent conduct that may affect the colleagues’ dignity and embarrass the same by offending them.

Such policy applies to all work premises and to all spaces where the employees participate in KYKNOS’s activities or in activities on its behalf, and in any case either in KYKNOS’s facilities or out of them, and whether the employees are physically present or participate online or through the telephone or another technological method without physical presence. Such risks may occur especially: (a) at the workplace including all the premises and facilities of the company (offices, common areas, personal hygiene and care facilities, changing rooms and accommodation that the employer may provide etc.), private or public spaces where the employees and other people working provide their services or/ and where the same receive their fees or/ ands take their break for rest, entertainment or any other reason, (b) in the communications relating to work including those made using information technology, and (c) in transport from and to work, in movement/ traveling for business purposes, in training as well as in events and social activities connected to employment.

The management of each company, the relevant employees and the other employees shall ensure the identification and comprehension of new and particular risks in the work context in order to address them and prevent the adverse consequences thereof. Prevention Measures/ Action for the Staff’s Information and Awareness
KYKNOS adopts to the extent possible any expedient measure and applies any reasonable adaptation of the work conditions so as to ensure that the work environment is preserved safe and that the relations of the employees be distinguished by mutual respect, decency, cooperation and professionalism.

KYKNOS undertakes the following specific action on the one hand in order to ensure to the extent possible that their employees and other people working for them shall demonstrate the required care and furthermore be more aware in behaviour matters in the context of their work and on the other hand and at the same time in order to ensure that the requisite measures of prevention, review, restriction and fight against the relevant risks have been taken as well as that there will be an organized, regular and continuous monitoring of such incidents or conducts of similar kind.

More specifically KYKNOS:
(a) Ensures that each year all the employees are trained in matters of respect of their colleagues’ dignity, mutual assistance, cooperation and equal treatment and that all of them commit themselves to comply with the policies and practices of KYKNOS Business Principles including also the practices for Respect, Dignity and Fair Treatment aiming at establishing and preserving a working environment based on such principles;

(b) Ensures that all the employees are trained informed on a regular basis, when required, both as regards the methods of prevention and the methods of combatting violence and harassment incidents;

(c) Invites their employees and other people working for them to be on their guard and ready, if they identify conducts on such kind occurring either against them or against their colleagues, to report the same directly pursuant to the complaint policy and to take the prescribed action;

(d) Draws the attention of the heads of departments to be extra responsible, to supervise and to identify any misconduct in the groups they supervise (at the directorate, department or other work subgroups) and take them into account in assessing the performance of their subordinates as well as in organising work. At the same time, the superiors must endeavour to prevent – of course after they become aware of a risk of manifestation of any form of violence and harassment – situations that under certain circumstances may lead to such violence or/ and harassment incidents.

In accordance with what is set out above the employees and other people working the conducts which may develop into or cause violence or harassment incidents include without limitation:

  • Accusations against colleagues
  • Verbal threats and insulting behaviours
  • Use of offending, degrading or other indecent expressions against colleagues
  • Visual forms of harassment including without limitation posters, animated cartoons, funnies, photographs etc. that are offending and degrading pursuant to the law and the characteristics of each case
  • Lack of self-control (brutal movements/ behaviour)
  • Unjustified complaints about an unfair or biased treatment in a regular or frequent basis
  • Refusal of acceptance of criticism in the context and in the performance of work. It is specified however that the relevant arrangement does not affect or restrict the right to criticize to which any person and any employee is entitled in accordance with the law and in the framework of his/ her employment relationship
  • Inadequate personal care including but not limited to inadequate observance of hygiene rules
  • Deterioration of the employment conditions including but not limited to extended absence and systematically inadequate performance of work
  • Sexual proposals and suggestions towards colleagues as well as revenge or threat to retaliate due to rejection of sexual proposals.
  • Physical contact such as touching, pinching, gestures of sexual nature, pushing etc.

(e) Monitors and supervises compliance with business principles, practices and policies of the Company in order to adopt the appropriate measures in the work place;

(f) Ensures that are minimized to the extent possible the cases of isolation of the employees and other persons working in the areas where work is provided and at the same time encourages and enhances the opportunity thereof to communicate with their superiors and other colleagues in the case of incidents that could develop into manifestations of violence or/ and harassment behaviour;

(g) Encourages and ensures the organisation of targeted meetings with the staff in order to discuss and to address such matters.

Fight Measures
In the event of manifestation of violent conduct or harassment at the workplace, then the officials/ employees the competences and duties whereof relate to the resolution of such matters must be notified immediately and as soon as possible.

At a first level, the purpose of the notification concerns the de-escalation of tension, the avoidance of further risks, the removal of the persons involved and the securing of the avoidance of any further contact and communication between the persons involved (reported as perpetrator and victim) likely to flare the tempers. In order to achieve such purpose the officials responsible shall use a calm way of communication, with politeness and civility and of course without any violence, avoiding any offences, verbal exaggerations and unneeded actions that are of no use, while as a last resort the relevant police authorities must be called if felonies or other unlawful acts are perpetrated and this is deemed necessary due to the severity and criticality of the situation.

At a second level, immediately after the violence/ harassment incident it must be ensured that all the persons involved are safe, that they be provided with first aid and the requisite medical care, if required, that the victim and the other employees and other persons working that may have been involved in the incident be provided with psychological or other support, that be secured the safeguard of all exhibits/ means of evidence, that be questioned all the persons involved as soon as their condition permits, as well as the other employees and other persons working who were present during the facts constituting the illegal behaviour and the conditions in which and how such facts have taken place, and that be recorded and registered the relevant information in order to be verified, that the incident be investigated and that the disciplinary and other internal processes enshrined by the company be followed, in any case with respect to human dignity and in accordance with the law.

KYKNOS encourages the psychological support of the employees.

Rights of Employees and other Members of Staff
Each employee who suffers a violence and harassment incident against him/ her is entitled to complaint and report it to his/ her employer but also to leave his workplace for a reasonable period of time, without any salary cut or other adverse consequence, if such employee is convinced and it does appear that there is an imminent serious risk for his/ her life, health or security, especially when, in spite of the measures that have been adopted, he/ she continues to be harassed as per the relevant laws.

In this case, the victim of violence or harassment should have previously informed in writing his/ her immediate superior or/ and the head of the directorate/ department of Human Resources, reporting the violence and harassment incident and the data and facts confirming and proving such conviction of his/ hers, to wit that there is a serious risk for his life, health or security. In any case, if the risk ceases, the employee incurring the risk must return to his/ her workplace immediately and in all cases as soon as he/ she is informed accordingly by his/ her employer.

The other persons working have the same rights respectively.

Notwithstanding and in parallel with the above-mentioned rights, KYKNOS has enshrined in order to address violence or/ and harassment incidents a specific policy/ process for the management of internal complaints which applies to any kind of fault and is set out below.

Information, Rights and Obligations of Employees Exercising Managerial Right or/ and Representing the Employer
The officials exercising the managerial right and/ or representing the employer must demonstrate a particular diligence in matters of violence and harassment, be informed and trained continuously for the prevention and addressing of matters of such nature, follow the relevant procedures, instructions and recommendations laid down by KYKNOS and assist their subordinates in any manner whatsoever in case of occurrence of a violence or harassment incident, with discretion, respect and objective judgment.

In case of direct and imminent danger, the officials exercising the managerial right and/ or representing the employer have the right and the obligation to apply what is prescribed by the applicable laws and the relevant procedures, instructions and recommendations laid down by KYKNOS, aiming at preventing and addressing incidents of violence and harassment at work, even without the employer’s prior special approval.

The officials exercising the managerial right and/ or representing the employer must keep secrecy and confidentiality as regards questions of violence and harassment and show the requisite diligence, objectivity, professionalism and discernment in dealing with such incidents. At the same time, they must comply with KYKNOS’s procedures and protocols in order to avoid unjustified exposure and shaming of the persons alleged as perpetrators or victims.

Appointment of Person Responsible (“Liaison”)
The employer has appointed Mr. Alexandraki Alexandra, HR Director, as responsible to instruct and inform the employees and other persons working in respect of prevention and addressing violence and harassment at work. The role of such person is strictly informative and consists in instructing and informing the employees and other persons working irrespective of whether the latter are reporting an incident or file a complaint or not.

Communication therewith may be carried out through e-mail or telephone or through a meeting. Protection of personal data is an obligation of the person named above in the performance of her duties. The contact details of the person of reference are the following: (a) E-mail: speakout@kyknoscanning.com and (b) Telephone: 0030 6948682183. In case of change of such details the employees and other persons working shall be notified though the company’s webpage or through other appropriate means.


Complaint/ Report Process
Any employee who becomes aware of a violence or harassment incident must, if this is practicable, inform orally or in writing the person causing violence or harassment that his/ her specific conduct is illegal and infringes the company’s policies and principles, asking him/ her to cease and to refrain from such conduct.

Irrespective of what is set out above, it is the right but also an obligation of every employee and any other person who may be working that becomes aware of any conduct of harassment or/ and manifestation of violence at work and in the context thereof to denounce/ report that specific illegal and offending conduct by following the procedure described in the policies.

KYKNOS has implemented a practice/ procedure in respect of the reporting of possible infringements, aiming at timely, fairly, objectively and effectively investigating and addressing the consequences and the hazards deriving from such a behavior. All the employees are encouraged to externalize and notify their thoughts and concerns, when they feel that a principle of the company is infringed, and especially inter alia when there are conducts of violence and harassment at work and of lack of respect and dignity towards the colleagues.

The procedure in such a case is the following:
The complainant immediately notifies the case
Α. Either to his/ her superior;
Β. Or/ and to the Head of the Directorate of Human Resources;
C. Or/ and to the person responsible for compliance with the company’s principles, practices and policies (business integrity officer);
D. Or by sending an e-mail to a specific e-mail address indicated by KYKNOS to that effect.
E-mail address: speakout@kyknoscanning.com

In all the above-mentioned cases, the employer’s responsible for compliance with the company’s principles, practices and policies (business integrity officer) is mandatorily notified.

In all the above-mentioned cases, the complainant’s anonymity may be preserved (if the complainant so wishes), whether the complainant is an employee or another person reporting such a matter, at any stage or level of the procedure this may be requested, while the complainant’s personal data are kept strictly confidential and protected.

Access to the complainant’s personal data (where the same have been declared at the time of the complaint and no request has been raised from the complainant’s part for the observance of absolute anonymity during the complaint’s investigation procedure) shall be allowed to the person against whom the complaint has been filed, the occupational doctor, the employer’s and KYKNOS’s responsible for compliance with the company’s principles, practices and policies (Business Integrity Officer), as well as to the company’s officials charged with investigating the complaint and adopting measures in the event of assessment of the infringement denounced, in any case in the context of the powers and in fulfilment of their duties. The Business Integrity Officer may delegate the complaint’s investigation to a special investigation team that is formed especially to that effect within KYKNOS and will assist such Officer in his/ her task. The investigation team shall be notified such personal data of the complainant as are required for the performance of its duties, unless the complainant has objected thereto.

The result of the complaint’s investigation shall be notified by the Business Integrity Officer to the company’s management so that on one hand disciplinary rules be applied and on the other hand and in parallel the company make all necessary decisions and implement specific actions.
In the cases set out below, the complaint’s report and investigation and the individual duties and powers of the Business Integrity Officer shall be carried out under the following distinctions:
(a) In the event KYKNOS has not appointed a specific person as exclusively responsible for compliance with the company’s principles, practices and policies (Business Integrity Officer), and
(b) in case the complaint concerns the Business Integrity Officer, the Managing Director or the person authorized thereby shall be responsible;
(c) In case the Business Integrity Officer is impaired for any reason whatsoever, the substitute thereof shall be responsible or in the case where no substitute has been appointed or such substitute is also impaired, the Managing Director or the person authorized thereby shall be responsible;
(d) In the event the complaint concerns the Managing Director or a member of the company’s Board of Directors the report shall be filed with the Business Integrity Officer who shall inform in writing the Board of Directors of the fact of the complaint, while the investigation of the latter shall be made by a 3-member Committee to be formed by the Board of Directors in which shall participate a legal counsel, if this is practicable, as well as an independent person who is not employed by the company.

No measures may be taken against the person responsible for compliance with the company’s principles, practices and policies (Business Integrity Officer) by reason of the exercise of his/ her powers and duties in accordance with the law, KYKNOS’s policies and the company’s Staff Rules. A person not having an employment relationship with KYKNOS may also be appointed as responsible for compliance with the company’s principles, practices and policies (Business Integrity Officer).

It is important to specify that, if the complainant wishes to remain anonymous, then the complaint may not be investigated in depth so that the complainant’s identity is not disclosed to any third parties through the investigation, depending of course on the circumstances of each case. The complainant is protected from any retaliation/ revenge due to his/ her complaint, while KYKNOS commit themselves to protect the complainant and take any measure for the avoidance of such acts. Each employee who considers that he/ she suffers such a behaviour is encouraged but has also the obligation to report it to KYKNOS pursuant to this policy. Nevertheless, if the complaint is proven false, the complainant shall be liable towards KYKNOS and the person against whom the complaint had been filed to compensate any damage the latter may have suffered.

The person so denounced may be informed and be provided with a copy of the complaint, if he/ she has so requested and to the satisfaction of the employer and the relevant organs all the requisite measures have been adopted and there is no risk for the victim and the securing of the exhibits aiming at having the case investigated. The employer may refuse to provide the complaint or/ and any other documents, if the employer has such right under the law, as well as in any other case where there is an imminent risk. In any case, the person denounced shall be informed of the content of the complaint against him/ her when he/ she will be invited by the relevant organs in order to be examined and provide explanations in respect of the incident constituting the content of the complaint.

The company’s management and competent officials (the Business Integrity Officer, the head of the Department of Human Resources, the occupational doctor etc.) shall cooperate in any relevant matter relating to the evolution and improvement of the relevant procedures and ensure that the company’s policies and other procedures are understood by the employees and other persons working and also that they do serve the purpose for which they have been laid down.

Complaint Management/ Investigation Procedure
For each complaint for violent behaviour or harassment that may be filed in any of the above-mentioned manners, an investigation team shall be appointed following a relevant consultation and approval by the Managing Director. The investigation team must be formed by officials, employees or other people working for KYKNOS or/ and third parties, provided that in this last case they do have specialised experience and knowledge as well as warranties for the observance of secrecy and confidentiality, in any case following a relevant consultation and approval by the Managing Director.

The investigation of each case must be carried out immediately and its recommended that it be completed within 60 days, while at the discretion of the relevant organs said period may be extended either ex officio or following a relevant request of the parties involved for as long as lasts the incident’s investigation procedure by the Labour Inspection. A summary report with the elements that have been taken into account and the results of the investigation may be drawn up. The care of drawing up such report is the duty of the Business Integrity Officer and the report shall be taken into account by the company’s management and disciplinary organs in the adoption of their decision.

The persons who compose the investigation team as well as the Business Integrity Officer may exercise their duties exclusively or in parallel with other duties, even when they are part of the company’s staff.

The receipt, investigation and examination of the complaints shall be made impartially, with respect to the secrecy and protection of the information’s confidentiality, but also protecting the personal data of the subjects involved (the victim, the perpetrator and the witnesses). The employer encourages and does not hinder in any manner whatsoever the receipt and investigation of the complaints and ensures that investigation be conducted with respect to human dignity, to the authorities, to KYKNOS’s policies and to the applicable laws.

The Business Integrity Officer may have access to the company’s files, to audiovisual material and to the content of the employment file of the persons involved, if and to the extent these are necessary in order to investigate the complaint. Under the same restrictions such data may be notified care of the Business Integrity Officer and to the persons composing the complaints’ Investigation Team. The head of the directorate/ department of Human Resources and the other officials of the employer must cooperate with the persons and organs that are responsible for the investigation of the complaints and assist them in collecting information under the above-mentioned conditions. In case of refusal or disagreement between the persons named above with regard to the expediency and necessity of collection of the requisite material, the opposite views shall be quoted in writing and the company’s Managing Director shall decide in consultation with the legal department, where there are (also) legal questions.

The collection, processing and retention of the data and information of each complaint must be carried out in a manner ensuring the secrecy and confidentiality thereof. To that effect the employer shall take the necessary technical, organizational and other measures that are proportionate to the size and capacities of the business thereof and always pursuant to the applicable laws. The witness testimonies are mandatorily taken into account provided that they are given with named names and in writing, whereas, if the witnesses ask from the Business Integrity Officer to not disclose their identity, then the testimony thereof does not suffice by itself for the complaint’s establishment and the imposition of sanctions to the perpetrator unless the content thereof coincides with and is confirmed by other means of evidence.

The accused perpetrator must have the possibility on the one hand to be informed of the entirety of the case’s means of evidence that the Business Integrity Officer has collected and taken into account as the same are stated in his/ her report (but not of the report’s content which remains secret) and on the other hand and at the same time the possibility to file his/ her views on the case and the means of evidence documenting such views, timely and in any case at a time prior to the imposition of any disciplinary sanction or other unfavourable measure against him/ her.

The employer and the Business Integrity Officer must immediately upon being informed of the complaint and if they deem necessary take all the necessary measures at their discretion aiming at ensuring the integrity of the persons involved pursuant to the applicable laws, especially in the case where the complaint’s plausibility is reasonably assumed. The employer may either ex officio or following the suggestion of the Business Integrity Officer take additional measures if it deems necessary. It is specified that the procedure of the complaint’s investigation does not affect the employer’s right to terminate the employment agreement of the persons involved or of any of them, irrespective of the merits and the verification of the complaint and even before completion or the opening of the relevant procedure, provided that the complaint has been filed lawfully and not abusively (vengefully).

Complaint/ Report Investigation Results
In case that from the investigation of the complaint it is not assessed that a violence/ harassment incident has occurred the results/ findings shall be notified only to the complainant.

In case of confirmation of the complaint’s subject-matter, the employer shall ensure that the person so denounced shall be imposed the sanctions provided by law et the company’s Staff Rules and policies, and shall moreover take all expedient and necessary measures at its discretion for the victim’s protection (either it is the complainant him/ herself or not) in the context of the employment relationship, in order to prevent that such an incident or behaviour is repeated.

Measures – Sanctions

The measures and the sanctions that may be taken and imposed by the employer in case of confirmation of the complaint’s content, as well as in case of filing of false and malicious complaint, depending naturally on the severity of each case, comprise:

  • An oral or written compliance recommendation;
  • Change of the workplace, change of position, of time and/ or way of the provision of law;
  • Termination of employment or cooperation subject to the prohibition of the abuse of the right of art. 281 C.K

The measures and the sanctions provided in the policies do not affect and do not preclude the imposition of disciplinary sanctions contemplated by the company’s Staff Rules. It is specified that, if the procedure described above in respect of complaints for violence and harassment behaviour has preceded, no further procedure so that disciplinary or other sanctions be imposed, is required.

Malicious Complaints
In the event it is assessed that false complaints, accusations and grievances have been filed against a colleague, if the complainant has acted although knowing the complaint is false or/ and in bad faith (malicious complaint), then the complainant’s motives shall be examined and sanctions may be imposed against the same. Such behaviour constitutes a serious disciplinary fault.

Appeal to and Cooperation with the Authorities
The person offended by incidents of violence and harassment shall be informed of his/ her entitlement to appeal at the same time to the relevant administrative authorities (Labour Inspection and the State Ombudsman) as well as to the judicial authorities at his/ her discretion. The employer and the company’s competent organs shall cooperate with any relevant public, administrative and judicial authority which requests either ex officio or upon the request of the victim or a third party the provision of data and information in the context of the jurisdiction thereof as per the law.

After completion of the investigation procedure, the complaints and the evidence collected in the context thereof shall be filed electronically or/ and in hard copies and be kept secret and confidential for as long as prescribed by the company’s relevant policies. The material obtained by unfounded complaints or complaint based on tainted evidence may be destroyed immediately following completion of the investigation procedure unless the Business Integrity Officer makes a reasoned request that the material be kept for a certain period of time. Access to the content of the complaint and to the material collected following completion of the investigation procedure and of the possible imposition of disciplinary sanctions shall be reserved to the Business Integrity Officer and the other officials of the employer within the context of their powers and duties thereof respectively, and in any case to the extent necessary and in accordance with the applicable laws and the company’s relevant policies.

The employer is entitled to restrict or to refuse the access of its competent officials to the above-mentioned data. It is specified that (a) the material of the complaints and the content thereof shall be kept by the company and constitute the assets thereof, and (b) the subjects of the personal data preserve the rights contemplated by the laws and the company’s relevant policies, and may receive further clarifications upon their request.

The policies and procedures described in this document are supplemented by the law provisions and constructed pursuant to the purpose thereof. The policies and procedures hereof do neither affect nor alter the rights and obligations of the employer and of the employees and the other persons working for the company as such rights and obligations are defined by the legislation, the employment agreement, the Collective Labour Conventions, the Staff Rules and the other regulatory sources of law, whereas in case of conflict the rules of labour laws shall prevail.

The employer reserves the right to vary its existing policies and procedures or even to enact new policies and procedures in replacement of the old ones, in each case in accordance with the applicable laws, if the employer deems that the company’s business is better served thereby.

The policies and procedures described in this document and embodied therein shall be posted on the company’s webpage and on the notice boards of the individual facilities thereof.