HUMAN RIGHTS POLICY

1. Purpose

At GEK TERNA Group we recognize the importance of respect for human rights, as the basis for responsible business behavior and contribution to sustainable development.

The purpose of this Policy, which is developed in accordance with the United Nations Guidelines for the Business Activities and the Human Rights, is primarily to show the voluntary expression of our commitment to respect for and observance of internationally recognized human rights and at the same time to demonstrate the continuous recognition of our responsibility to identify, evaluate, manage and address potential impacts on stakeholder rights.

2. Scope of Application

The present Policy covers all countries where GEK TERNA Group operates and defines the 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 form an environment of progress, aligned with set of principles as well as with meritocracy.

• We provide equal opportunities to all employees. All actions concerning employees such as promotions, remuneration, transfers to other Departments, participation in teams, etc., are based solely on meritocracy criteria related to principles, ethics, performance, skills, performance, efficiency and the qualifications of each employee.
• All employees must treat their colleagues and each associate fairly and also with respect, and must not exclude them from the Group's procedures, as long as the terms and conditions of cooperation are met.

The right of all employees to enjoy the highest possible level of protection of physical and mental health.

This is ensured through the following systematic actions:

• Implementation of a Certified System based on the international standard System of Occupational Health & Safety ISO 45001, by adopting the appropriate procedures and allocating the necessary resources for the protection of each employee.
• Implementation of Safety and Health Plans for all projects and in all operating facilities.
• Preparation of an Occupational Risk Assessment Study based on current legislation for all operating facilities.
• Regular inspections of operating facilities and construction sites by the competent personnel, as well as safety technicians, occupational physicians, while monitoring the observance of legislation and any required compliance based on changes in the legal / regulatory framework.
• Targeted training and implementation of Safety Instructions for the execution of hazardous tasks.
• Systematic implementation of personnel training programs.
• Provision of first aid in case of injury.
• Consulting employees to improve any planned action and gathering information and experiences.
• Establishment and implementation of a conformity assessment process with regard to the legislative and regulatory requirements.
• Implement a policy to combat violence and harassment at work.
• Implementation of a reporting line for issues of compliance, health and safety at work, as well as for environmental issues.
• Monitoring of the institutionalized Control Bulletins provided by the Labor Inspection Body (the so called SEPE) for the audit of implementation of the labor legislation and the guarantee on the one hand of the labor rights and on the other hand of the safety and health of the workers.
• Preparation of annual evaluation of suppliers and subcontractors, in order to fully inform the competent employees in view of new collaborations.
• Implementation and monitoring of procedures for determining requirements for protection, health and safety measures of subcontractors and suppliers.
• Physical safeguarding of facilities and control of visitor access, along with assistance of modern electronic means, with the aim, among other things, of protecting the health and safety of themselves and their employees.
• Constant contact and information update from the Official Institutions of Public Health (the so-called EODY/POY) and of Health and Safety at Work (known as SEPE/ELINYAE).
• Preparation of a Written Occupational Risk Assessment Report for a pandemic crisis, such as that of Covid-19.
• Drafting of Rules of Procedure, Protocols and Operating Instructions for the implementation of prevention and health protection measures, against a pandemic spread like that of Covid-19, under the supervision of the Incident Management Body and the Health and Safety Directorate.
• Increased presence of doctors, occupational physicians or nurses wherever and whenever required.
• Provision of appropriate Personal Protective Equipment.
• All employees without exception are provided with an additional private Life and Health Insurance contract.
• Ensuring the provision of the sanitary and technical equipment which is necessary for the health and safety of the employees each time.
• Creation of an environment of adequate hygiene conditions, with daily presence of cleaning crews, with constant presence of cleaning staff, with waste management, with collection and management of any hazardous waste through special collection bins, with regular inspections in the preparation of the necessary food & beverage supplies, with regular inspection and maintenance of cooling / heating machines, and natural or artificial ventilation.
• Ensuring the readiness of every fire safety installation in the workplace and with drill exercises in case of emergency.

The right to be free from discrimination.

• As defined in the Code of Ethics and Conduct, no discrimination of any kind is allowed on the basis of race, religion, sex, social, cultural, political, sexual orientation or any other case.
• There is full respect and protection of minority rights.
• There is full respect and protection of women's rights.

The right to freedom of association.

• Employees' right to negotiate collectively is recognized.
• The right of employees to negotiate in individual groups is also recognized.

Right to be free from slavery and forced or compulsory labor.

• We pledge that there is not and will never be forced labor or slave labor, anywhere and under any circumstances.
• We base our working relationships on mutual respect, transparency, integrity and justice.
• We create the appropriate conditions so that we can all express within the work environment our ideas, beliefs and opinions, encouraging honest and mutual communication, for every issue related to the work and activities of the Company.
• We do not and will not allow any kind of bullying, harassment and aggressive behavior in the work environment.

The rights of the children.

• We never employ people under 18 years of age.

 

B. HUMAN RIGHTS FOR CUSTOMERS AND END USERS

The right to privacy.

It is ensured through the following actions:

• Full compliance with the GDPR.
• A DPO has been designated and there is a Data Protection Unit in place.
• Personal data is subject to legal, fair and transparent processing.
• Personal data is collected only for specific, clear and legal 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 must be made to delete or correct such data without delay.
• Personal data are being kept in such a way that the underlying data can only be identified if it is necessary for processing.
• Personal data is processed in a secure manner.
• The controller is able to demonstrate compliance with the other principles of the GDPR (Accountability Principle).
• Maintaining back up and security systems.
• Information security system implementation - ISO 27001.

Avoiding bribery and corruption.

Should be indicatively ensured through the following:

• Implementation of an Anti-Corruption and Bribery Policy.
• Implementation of Corporate Gifts Policy.
• Implementation of a Policy for Donations and Sponsorships.
• Implementation of Policy with regard to Conflict of Interest.
• Installation and Implementation of a Regulatory Compliance and Anti-Bribery Management System according to ISO 37301 and ISO 37001 standards.
• Continuous information and formation of an anti-corruption culture.
• Implementation of a reporting line on issues of regulatory compliance, corruption and bribery.
• Establishment of a Regulatory Compliance Unit and a Regulatory Compliance Committee as independent bodies for monitoring regulatory compliance issues and tackling corruption.

C. HUMAN RIGHTS IN THE LOCAL COMMUNITIES OF THE GEOGRAPHICAL AREAS OF ACTIVITY

The right to a safe, clean, healthy and sustainable environment. This is secured through the following actions:

• Preparation of an Environmental Impact Study for each project.
• Faithful application of the approved Environmental Terms.
• Implementation of Environmental Management System based on the international standard ISO 14001.
• Carry out frequent inspections to monitor environmental issues.
• Analysis, assessment and monitoring of any environmental effects.
• Waste management through licensed companies and collective action systems.
• Preparation and Implementation of Emergency Plans.
• Training of personnel in environmental protection issues.
• Adequacy of technical equipment in fire detection / firefighting systems and instruments for measurement and control of environmental factors.
• Availability of leak reduction equipment and leak cleaning equipment (spill kits, oil pits).
• Implementation of environmental protection measures in accordance with the environmental conditions and the requirements of legislation.
• Analysis and assessment of environmental issues and impacts and implementation of relevant monitoring plans.
• Identifying the interests of environmental organizations for each project by implementing the Risk Assessment Procedure and by formulating a relevant action plan if required.
• Development of Corporate Social Responsibility actions for the benefit of local communities.
• Issuance of Annual Report on Corporate Responsibility - Sustainable Development (ESG).
• Monitoring changes in each legislative framework.
• Operation of a department responsible for monitoring and renewing environmental permits.

Respect for the rights of local communities.

It is ensured through the following:

• Monitoring the interests of the local but also of the wider community.
• Management of issues of interest to the Media.
• Compilation of a Corporate Social Responsibility Report and posting of the report on the company's website.

3. Policy harmonization

The policy is based on the United Nations Guidelines on Business Activities and Human Rights, taking into consideration the following:

• The United Nations Universal Declaration of Human Rights
• The United Nations International Pact on Civil and Political Rights.
• The United Nations International Pact on Social, Economic and Cultural Rights.
• The United Nations Guidelines for Business Activities and Human Rights.
• The United Nations Global Compact.
• The IOC Declaration on Fundamental Principles and Rights at Work.
• United Nations Resolution 46/7 on Human Rights and the Environment.
• The voluntary commitments of the Company’s Management for safety and human rights.

4. Roles and responsibilities

The 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, Environmental Safety, the Directorate of Human Resources, the Regulatory Compliance Unit and the respective Compliance Committee in drafting and finalizing the present Policy.

This Policy is submitted to the ESG Committee of the Board of Directors for approval.

The overall responsibility for monitoring compliance with the Human Rights Policy and its revision lies with the Human Resources Department.

Mechanism of complaints and appeals

• The Human Rights Policy is covered by the Complaints and Appeals Mechanism of the Company's Regulatory Compliance Unit, which is available at the following link: https://gekterna.integrityline.com/frontpage .