New HR policies 🔉🔉

Purpose 

This policy (the “Policy” and/ or “Code of Conduct”) aims to establish a safe, respectful,  and inclusive workplace across all EVEST locations. It sets forth EVEST’s commitment  to preventing harassment, sexual harassment, discrimination, and retaliation in the  workplace, while promoting equal opportunities, diversity, and respectful conduct. EVEST  strives to maintain an environment where all employees, candidates, and business  partners are treated with dignity, respect, equality and fairness, free from any form of  violence, harassment, discrimination, or retaliation. 

This Policy has been developed in accordance with the provisions of the Prevention and  Combating of Violence and Harassment at Work Law of 2025 (Law 42(I)/2025) of the  Republic of Cyprus (the “Law”). The Policy sets out the framework for preventing,  identifying, reporting, and addressing any act or behavior that may constitute violence  or harassment in the workplace, as defined in the Law and related regulations. 

Scope 

This Policy applies to all EVEST employees, contractors, consultants, interns, trainees,  candidates, vendors, and visitors across all locations, as well as third parties who interact  with the organization. It covers both physical and virtual work environments, including  offsite meetings, company events, and all work-related communication platforms. More  specifically, the Code of Conduct applies within all work-related settings, including  EVEST’s premises, off-site work or business trips, work related events, conferences or  training, remote work or online communications related to work. 

This Code of Conduct sets out the principles and standards of behavior expected from  all persons in the workplace to ensure a safe, respectful, and inclusive working  environment, free from any form of violence or harassment. 

Definitions 

∙ Workplace: includes physical premises, surrounding areas, travel to/from work,  communication via ICT, employer-provided accommodation, vocational training  settings etc.;  

∙ Employee: full-time, part-time, fixed-term, open-ended, teleworkers, persons in  vocational training, even undeclared work;  

∙ Harassment: unwanted conduct (verbal, non-verbal, physical or otherwise) that  has the purpose or effect of violating a person’s dignity or creating an intimidating, 

hostile, degrading, humiliating or offensive environment, and in general means a  range of unacceptable behaviors or practices, or threats thereof, that aim at,  result in, or are likely to result in physical, psychological, or economic harm, e.g.: o Bullying, threats, intimidation, insults, physical assault; 

o Spreading malicious rumors; 

o Mockery related to personal characteristics (e.g., age, race, disability,  beliefs). 

∙ Sexual Harassment: any unwanted conduct of a sexual nature, verbal, non verbal, or physical, which has the purpose or effect of violating a person’s dignity,  particularly when it creates a hostile, humiliating, or offensive environment, e.g.: o Unwanted touching or physical contact; 

o Sexually suggestive comments or jokes; 

o Displaying or sending sexual content; 

o Requests for sexual favors (explicit or implied). 

∙ Discrimination: unfavorable treatment of a person because of their sex, gender,  age, race, color, ethnic or social origin, religion or belief, disability, sexual  orientation, family status, or political opinion, contrary to the principles of equality.  

∙ Retaliation: any adverse action taken against an employee for reporting  harassment, discrimination, or participating in an investigation. 

∙ Complainant: for the purposes of this Policy the term “Victim” or “Complainant”  refers to any person:  

a) against whom an act of violence, harassment, or other prohibited conduct  under the Law has been committed, whether recognized by a court decision  or otherwise; 

b) who alleges that such an act has been committed against them, while the  case is under internal investigation, under review by an extrajudicial  mechanism, under police investigation, by a criminal investigator, or  pending before a court; or 

c) who has submitted a complaint to an extrajudicial mechanism for violation  of the provisions of the said Law. 

For internal handling within this Policy, the terms “Victim” and “Complainant” may be used  interchangeably, recognizing that protection applies from the moment an allegation is  made, irrespective of whether a violation has been formally established. 

∙ Respondent: the term “Respondent” refers to any person against whom an  allegation, complaint, or investigation is made in relation to conduct that may  constitute an act of violence, harassment, discrimination, or retaliation within the  meaning of the Law.

Roles & Responsibilities 

EVEST responsibilities: 

✔ To prevent and address incidents of violence or harassment; 

✔ To inform and train all Employees on this Code of Conduct and their  rights; 

✔ To ensure confidentiality, impartiality, and support for affected individuals; ✔ To maintain records of complaints and actions taken. 

Employees responsibilities:  

✔ To treat all colleagues, clients, and third parties with respect; 

✔ To refrain from any form of violence, harassment, or discrimination; ✔ To cooperate in investigations and report incidents in good faith. 

Process & Workflow 

Reporting Procedure 

Any person who believes they have been subjected to, or have witnessed, violence or  harassment is encouraged to report the incident without delay.  

As such, Employees can report incidents of harassment, sexual harassment,  discrimination, or retaliation through: 

∙ Direct line manager or local TAS either verbally or via direct email  ∙ HR Department (confidential communication) 

Submission 

∙ Reports can be made verbally or via email.

∙ The report should include: 

∙ Names of involved parties 

∙ Detailed description of the incident(s) 

∙ Dates, locations, and potential witnesses 

Reports may be made: 

∙ Internally: to the Human Resources Department or the designated Responsible  Officer as per above; 

∙ Externally: to the Department of Labour Inspection, the Equality Authority, or the  Police, as provided by Law 42(I)/2025. 

Acknowledgment 

HR will formally acknowledge receipt within one (1) working day of the report. 

All complaints will be treated confidentially, investigated promptly, and resolved fairly.  Retaliation against any person who submits or participates in a complaint is strictly  prohibited. 

Investigation Process 

Preliminary Review: 

HR reviews the complaint to determine whether the issue falls within the scope of this  Policy and Code of Conduct. 

Formal Investigation: 

∙ Involves interviews with the complainant, respondent, and any witnesses. ∙ Collection of supporting evidence such as emails, chat records, or CCTV  footage (if applicable). 

∙ Aimed to be completed within a maximum timeframe of fifteen (15) working days from the acknowledgment date. 

Outcome Determination: 

∙ Findings will be shared in writing with both parties. 

∙ Potential outcomes include verbal/written warnings, mandatory training,  reassignment, suspension, or termination.

Appeal Process: 

∙ Either party can file a written appeal within 5 working days of the outcome. ∙ Appeals will be reviewed by an independent HR representative and/or CHRO. 

Confidentiality & Retaliation Protection 

∙ All reports, investigations, and resolutions will be handled with strict  confidentiality. 

∙ Retaliation against complainants or participants in an investigation is strictly  prohibited and will result in disciplinary action. 

Compliance & Exceptions 

All employees must adhere to this Policy and participate in mandatory anti-harassment  training sessions. 

Any deviations or complex cases must be reviewed and approved by the CHRO. 

In cases of legal discrepancies, local labor laws will take precedence over internal  procedures. 

Disciplinary Measures 

Where conduct in breach of this Code is established, EVEST may impose appropriate  disciplinary measures and actions, depending on the severity of the behavior, which may  include: 

∙ Verbal or Written warning; 

∙ Suspension; 

∙ Transfer or reassignment; 

∙ Termination of employment; 

∙ Referral to police or competent authorities for further actions, where conduct  constitutes a criminal offence under the local applicable Law. 

EVEST may also take preventive or corrective measures such as mediation, counselling,  or training

Protection from Retaliation 

Retaliation or threats against anyone who reports or assists in a complaint process are  strictly prohibited and will be treated as a separate disciplinary offence. 

Support for Victims 

EVEST may, where appropriate, provide: 

∙ Counselling or support services; 

∙ Adjustment of work duties, location, or schedule; 

∙ Paid leave or flexible arrangements in cases involving domestic violence, as  provided by local applicable law.  

Training and Awareness 

All employees will receive periodic training on: 

∙ Identifying harassment and discrimination; 

∙ Their rights and responsibilities under the law; 

∙ Reporting procedures and available protections. 

Managers and supervisors will receive specialized training on handling complaints and  maintaining a safe workplace. 

Monitoring and Review 

This Policy will be reviewed at least annually or sooner if required by changes in  legislation or company structure, to ensure its continued effectiveness and compliance  with applicable legislation. 

Updates will be communicated to all staff and posted on internal communication  platforms.