GREECE Law and Practice Contributed by: Semina Zavitsanou, Yannis Ragos, Maria Siraga and Panagiota Kelali, POTAMITISVEKRIS
Athens, Greece; New York, USA; and the US District Court for the Northern District of Illinois.
POTAMITISVEKRIS 11 Omirou Street 10672
Athens Greece
Tel: +30 210 33 80000 Fax: +30 210 33 80020
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1. Opening an HR Internal Investigation 1.1 Circumstances In general, HR internal investigations in Greece are typically initiated when the employer receives a for - mal complaint or report (either through the chan - nels established under the Greek Labour Code (p.d. 62/2025 – the GLC) or internal policies). Under the GLC provisions on preventing and addressing vio - lence and harassment in the workplace, employers must ensure that complaints are properly received and examined. This obligation is activated when an employee (or other protected person, such as an independent contractor or a trainee/intern) submits a report alleging conduct that may constitute pro - hibited behaviour. The employer may also initiate an investigation upon receiving sufficiently specific, cred - ible information, even from an anonymous source, suggesting a potential breach of workplace rules or ethics. However, purely informal remarks or vague rumours do not, on their own, trigger a legal duty to investigate. Employers may nonetheless conduct a preliminary assessment to determine whether a formal investigation is warranted. 1.2 Bases Greek law provides the following primary legal bases for carrying out HR internal investigations, distinguish - ing between cases where an investigation is required by law and cases where it is carried out within the
framework of employment discipline and workplace governance. • Articles 58–9 GLC – Violence and Harassment in the Workplace: Employers are under a statutory obligation to investigate formal complaints relating to violence or harassment in the workplace. Such investigations must be conducted promptly, con - fidentially and impartially, in accordance with the procedures laid down by law and the employer’s internal policies, ensuring the protection of the people involved and compliance with due process requirements. • Law 4990/2022 – Whistle-Blowing and Breaches of EU Law: Organisations falling within the scope of Law 4990/2022 are required to establish internal reporting channels and to investigate reports con - cerning breaches of EU law. The Internal Reporting Officer is legally required to follow up on reports and take appropriate action, which may include conducting an internal HR investigation, subject to statutory timelines, confidentiality obligations and safeguards for reporting people. • Articles 422–424 GLC – Internal Work Regula - tions and Disciplinary Matters: Employers with 70 or more employees are legally required to adopt Internal Work Regulations, which typically include disciplinary rules and procedures and provide a framework for conducting HR internal investiga - tions into disciplinary misconduct. Employers with
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