Creating a safe, respectful and inclusive working environment is no longer just a matter of good corporate practice—it is also a growing compliance obligation for employers.
Under Ministerial Decision 95/2026, issued within the framework of the new Labour Code (Presidential Decree 62/2025), a new official policy template has been introduced for the prevention and management of workplace violence and harassment, as well as for the handling of internal complaints.
The updated framework strengthens the responsibilities of employers and reinforces the protection available to individuals in the workplace.
Which businesses are required to adopt a policy?
The obligation applies to private-sector businesses employing more than 20 employees.
When calculating the employee threshold, employers should also take into account:
- Employees under any type of employment agreement
- Seconded employees
- Personnel supplied through Temporary Employment Agencies (TEAs)
Workers provided through Temporary Employment Agencies are counted for both the direct and indirect employer when assessing the employee threshold.
Who is covered by the policy?
The scope of protection extends beyond traditional employment relationships
and includes:
- Employees, regardless of employment status
- Contractors providing services or working under project agreements
- Apprentices, trainees and interns
- Individuals undergoing vocational training
- Volunteers
- Job applicants
- Former employees
- Individuals engaged in informal work arrangements
The legislation aims to ensure that all individuals connected to the workplace are protected from violence and harassment.
What should the policy include?
The official template sets out a number of minimum requirements that employers must address.
Risk assessment
Employers should identify and assess potential risks of violence and harassment across different roles, departments and work environments.
Preventive and response measures
The policy should establish measures designed to prevent incidents and address inappropriate behaviour when it occurs.
Internal reporting procedures
Clear procedures should be in place for reporting, investigating and managing complaints.
Designated point of contact
Businesses should appoint an appropriate person to receive reports and provide guidance throughout the process.
Confidentiality and data protection
All complaints must be handled with appropriate confidentiality while ensuring compliance with applicable data protection requirements.
Protection against retaliation
Employees and other individuals who submit complaints or participate in investigations must be protected from retaliation.
Support measures
The policy should include provisions for supporting individuals affected by violence, including cases related to domestic violence where relevant.
Disciplinary measures
Employers should define the consequences of policy violations and establish appropriate disciplinary procedures.
How is the policy adopted within the organisation?
The implementation process varies depending on the structure and organisation of the business.
Businesses with Internal Work Regulations
The policy may be incorporated into the Internal Work Regulations and linked to the company's disciplinary procedures.
Businesses without Internal Work Regulations
The policy may be adopted following consultation through a Company Collective Labour Agreement or, where applicable, through employee representatives.
Implementing the policy within the organisation
Employers should ensure that the policy is:
- Communicated to all personnel
- Easily accessible within the workplace
- Integrated into internal procedures and compliance processes
- Published on the company website, where applicable
Should existing policies be reviewed?
Although businesses that have already adopted workplace violence and harassment policies under previous requirements may remain compliant,
reviewing existing documentation is strongly recommended.
Changes in legislation, organisational structure and operational practices may require updates to ensure ongoing compliance and effectiveness.
Why does compliance matter?
A workplace violence and harassment policy is not simply a formal document.
It is closely linked to:
- Employment law compliance
- Corporate governance
- Internal disciplinary procedures
- Management accountability
- Labour inspections and regulatory audits
- Risk management and business continuity
Failure to implement appropriate measures may expose organisations to legal, financial and reputational risks.
How AFS Can Support Your Business
At AFS, we support businesses in navigating complex employment law and compliance requirements.
- Labour law compliance
- HR και Payroll
- Regulatory compliance
- Internal policies and procedures
- Employment law advisory services
AFS consultants undertake:
- Assessment of whether your company falls under the obligation
- Drafting or updating workplace policies
- Tailoring policies to the specific needs of the business
- Integrating policies into internal procedures and compliance processes
- Strengthening the organisation's overall legal and operational compliance framework
In an environment of increasing regulatory scrutiny and evolving compliance requirements, proactive preparation remains one of the most effective ways for businesses to protect their people, operations and reputation.
Thanasis Karmiris | Payroll Manager at AFS
