1. Purpose

At GEK TERNA Group we recognize the importance of respecting human rights as the foundation of responsible business behavior and contribution to sustainable development.

The purpose of this Policy, which is based on the guiding Principles of the United Nations on Business and Human Rights, is primarily the voluntary expression of our commitment to respect and uphold internationally recognized human rights, while simultaneously acknowledging the responsibility to identify, assess, manage, and address potential impacts on the rights of stakeholders.

2. Scope of Application

The Policy covers all countries where GEK TERNA Group operates and identifies human rights by categories of stakeholder groups, as follows:

a. Human rights for employees, subcontractors and suppliers:

The right to fair and favorable working conditions that foster an environment of progress, principles, and meritocracy.

• We provide equal opportunities to all employees. All actions concerning employees, such as promotions, compensation, transfers to other departments, participation in groups, etc., are based solely on meritocratic criteria related to the value, ethics, performance, abilities, achievements, effectiveness, and qualifications of each employee.
• All employees are expected to treat their colleagues and every collaborator fairly and with respect, and not to exclude them from the processes of the Group, as long as they meet the necessary conditions and cooperation requirements.

The right of everyone to enjoy the highest attainable standard of physical and mental health.
This is ensured through the following systematic actions:

• Implementation of a Certified Occupational Health and Safety Management System based on the international standard ISO 45001, with the adoption of appropriate procedures and allocation of necessary resources to protect every employee.
• Implementation of Safety and Health Plans for all projects and facilities.
• Conducting a Professional Risk Assessment Study based on applicable legislation for all facilities.
• Regular inspections of facilities and construction sites by competent personnel, as well as by safety technicians and occupational physicians, while monitoring compliance with legislation and any required conformity based on changes in the legislative/regulatory framework.
• Targeted training and implementation of Safety Guidelines for the execution of hazardous tasks.
• Systematic implementation of personnel training programs.
• Provision for First Aid in case of injury.
• Consultation with employees for the improvement of each planned action and for the collection of information and experiences.
• Establishment and implementation of a compliance assessment process with legislative and regulatory requirements.
• Implementation of a Policy to combat violence and harassment in the workplace.
• Implementation of a reporting hotline for compliance, health and safety issues, as well as for environmental matters.
• Monitoring of the established Inspection Reports provided by the Labour Inspection Body for controlling the implementation of labor legislation and ensuring both labor rights and the safety and health of employees.
• Preparation of an annual evaluation of suppliers and subcontractors, aiming to provide accurate information in view of new collaborations.
• Implementation and monitoring of processes for determining requirements in terms of protection measures, health, and safety of subcontractors and suppliers.
• Physical security of facilities and control of visitor access, supported by modern electronic means, with the aim of protecting the health and safety of both themselves and employees.
• Continuous contact and information from the Official Public Health Bodies (EODY / WHO) and Health and Safety at Work (SEPE / ELINYAE).
• Preparation of a Written Risk Assessment for crisis management during a pandemic, such as the Covid-19 pandemic.
• Drafting of an Internal Regulation, Protocols, and Operating Instructions for the implementation of measures for the prevention and protection of health against the spread of a pandemic such as Covid-19, under the supervision of the Incident Management Team and the Health and Safety Department.
• Increased presence of doctors, occupational physicians, or nurses whenever necessary.
• Provision of appropriate Personal Protective Equipment to all employees.
• All employees are provided with a contract for additional private Life and Health coverage.
• Ensuring the necessary health and safety equipment for healthcare and technical staff on a case-by-case basis.
• Contributing to the creation of an environment with adequate hygiene conditions, with daily presence of cleaning crews, continuous presence of cleaning staff, waste management, collection and management of any hazardous waste through specialized collection bins, regular checks on the preparation of beverages and fast food items internally, regular inspection and maintenance of refrigeration/heating and natural or artificial ventilation systems.
• Ensuring the readiness of fire safety installations in the workplace and conducting evacuation drills in case of emergency.

The right to be free from discrimination.

• Any form of discrimination based on race, religion, gender, social status, culture, politics, sexual preference, or any other category is not allowed.
• There is full respect and protection for the rights of minorities.
• There is full respect and protection for the rights of women.

The right to freedom of association.

• The right of employees to negotiate collectively is acknowledged.
• The right of employees to negotiate in individual groups is also acknowledged.

The right to be free from forced or compulsory labor.

• We commit to never having and to never allowing forced labor or labor under any conditions, anywhere.
• We base our work relationships on mutual respect, transparency, integrity, and fairness.
• We create the appropriate conditions to express our ideas, beliefs, and opinions in our work environment, encouraging open and two-way communication on any matter related to work and company activities.
• We do not tolerate any form of bullying, harassment, or aggressive behavior in the workplace.

 Children’s rights.

• We never employ workers under the age of 18.
• The right of access to safe water for human consumption and sanitary use.

b. Human rights related to customers and end users

The right to privacy.

These are ensured through the following actions:

• Full compliance with GDPR.
• Appointment of a Data Protection Officer (DPO) and the existence of a Data Protection Unit.
• Personal data undergoes lawful, fair, and transparent processing.
• Personal data is collected only for specific, clear, and lawful purposes.
• Personal data must be adequate, relevant, and limited to what is necessary for processing.
• Personal data must be accurate and up-to-date, and efforts should be made to erase or correct it without delay.
• Personal data is kept in a way that the data subject can only be identified if necessary for processing.
• Personal data is processed in a secure manner.
• The data controller is able to demonstrate compliance with the other principles of GDPR (Principle of Accountability).
• Maintenance of backups and security systems.
• Implementation of an Information Security Management System – ISO 27001.

Avoidance of bribery and corruption.

It is ensured through the following indicative measures:

• Implementation of an Anti-Corruption and Bribery Policy.
• Implementation of a Corporate Gifts Policy.
• Implementation of a Donations and Sponsorships Policy.
• Implementation of a Conflict of Interest Policy.
• Installation and implementation of a Regulatory Compliance and Anti-Bribery Management System according to ISO 37301 and ISO 37001 standards.
• Ongoing education and fostering a culture against bribery and corruption.
• Implementation of a reporting hotline for regulatory compliance, corruption, and bribery issues.
• Establishment of a Regulatory Compliance Unit and a Compliance Committee as independent bodies for monitoring regulatory compliance matters and addressing bribery.

c. Human rights in the local communities of the geographical areas of activity

To ensure the right to a safe, clean, healthy, and sustainable environment in the local communities of the geographical areas of activity, the following actions are taken:

• Conducting an Environmental Impact Assessment for each project to assess its potential environmental effects
• Strict adherence to approved Environmental Conditions to minimize any negative impacts on the environment.
• Implementing an Environmental Management System based on the international standard ISO 14001 to effectively manage environmental aspects and impacts.
• Conducting regular inspections to monitor environmental issues and ensure compliance with environmental regulations.
• Analyzing, assessing, and monitoring any environmental impacts that may arise from the company’s activities.
• Managing waste through licensed companies and collective systems to ensure proper disposal and minimize environmental harm.
• Developing and implementing Emergency Response Plans to effectively handle any environmental emergencies that may arise.
• Education and training of staff on environmental protection.
• Adequate supply of equipment for fire detection/suppression, as well as instruments for measuring and monitoring environmental factors.
• Availability of equipment for containment and cleanup of spills (spill kits, oil collection tanks).
• Implementation of environmental protection measures in accordance with environmental conditions and legal requirements.
• Analysis and assessment of environmental issues and impacts, and implementation of relevant monitoring programs.
• Identification of interests of environmental organizations for each project through the implementation of the Risk Assessment Process and development of an action plan if required.
• Development of Corporate Social Responsibility actions for the benefit of local communities.
• Publication of an Annual Corporate Responsibility – Sustainable Development Report (ESG).
• Monitoring changes in each legislative framework.
• Operation of a dedicated department for monitoring and renewing environmental permits.

Respect for the rights of local communities.

To ensure the respect of the rights of local communities, the following actions are taken:

• Monitoring the interests of the local and wider community to understand their needs, concerns, and priorities.
• Managing issues of interest through effective communication channels, including engagement with local media to address any concerns or provide updates on relevant matters.
• Drafting a Corporate Social Responsibility Report that outlines the company’s activities and initiatives related to local communities and their well-being. This report is then posted on the company’s website to ensure transparency and accountability.

3. Policy harmonization. 

The policy is based on the United Nations Guiding Principles on Business and Human Rights, taking into account the following:

• The Universal Declaration of Human Rights of the United Nations.
• The International Covenant on Civil and Political Rights of the United Nations.
• The International Covenant on Economic, Social and Cultural Rights of the United Nations.
• The United Nations Guiding Principles on Business and Human Rights.
• The United Nations Global Compact Principles.
• The Declaration of the International Labour Organization(ILO) on Fundamental Principles and Rights at Work.
• United Nations Resolution 46/7 on Human Rights and the Environment.
• The voluntary commitments of the Management for safety and human rights.

4. Roles and responsibilities

Τhe Department of Corporate Social Responsibility and Sustainable Development of the Directorate of Strategic Communication, Corporate Social Responsibility and Sustainable Development collaborated with the Department of Health, Safety and Environment, the Directorate of Human Resources, the Regulatory Compliance Unit and the respective Compliance Committee in drafting and finalizing the present Policy.

The policy is submitted for approval to the ESG Committee of the Board of Directors. The Human Resources Department is responsible for monitoring compliance with the Human Rights Policy and conducting periodic reviews.

Mechanism for complaints and grievances.

The Human Rights Policy is covered by the complaints and grievances mechanism of the Company’s Regulatory Compliance Unit, which is available at the following link.: https://gekterna.integrityline.com/frontpage .