Standardy ochrony małoletnich

Child protection standards in GLAR Conference & SPA Hotel

Preamble

Bearing in mind the contents of the United Nations Guiding Principles on Business and Human Rights, recognizing the important role of business in ensuring respect for the rights of children, in particular the right to protection of their dignity and freedom from all forms of harm, “Poręczenia Kredytowe” Ltd. (hereinafter referred to as “the Company”) adopts this document as a model policy and procedures to be followed in case of suspicion of harm to a child who is staying at the Conference and Training Center in Wisełka Hotel GLAR Conference & SPA (hereinafter referred to as “the Hotel”) and to prevent such threats. We will implement our Hotel's child protection policy through these rules:

1. The hotel shall conduct its operational activities with the utmost respect for human rights, especially the rights of children as vulnerable to harm.

2. The hotel recognizes its role in conducting socially responsible business and promoting desirable social attitudes.

3. In particular, the hotel stresses the importance of the legal and social obligation to notify law enforcement authorities whenever a crime is suspected to have been committed against children, and undertakes to train its staff in this regard.

4. The Hotel undertakes to educate its Staff on the circumstances indicating that a Child staying at the facility may be harmed and on how to respond promptly and appropriately to such situations.

5. One of the forms of effective prevention of child abuse is the identification of the child staying in the facility and his/her relationship to the adult with whom he/she is staying in the facility. Hotel staff shall take all possible steps to carry out the identification of the child and his/her relationship with the adult with whom he/she is in the facility.

6. Meaning of terms:

a) Child/Minor - any person under the age of 18;

b) Hotel Employee/Personnel - A person engaged by “Poręczenia Kredytowe” Sp. z o. o. to perform duties at the Hotel, regardless of the manner in which such duties are entrusted, including a person employed under a civil law contract, apprentice, trainee and volunteer, regardless of the nationality and age of such person.

I. RULES TO ENSURE SAFE RELATIONS BETWEEN MINORS AND HOTEL STAFF, IN PARTICULAR, PROHIBITED BEHAVIOR TOWARDS MINORS:

1. Contact between Personnel and Children should only take place during working hours and relate to purposes within the scope of Personnel's duties. Personnel are required to act openly and transparently to others to minimize the risk of misinterpretation of their behavior, and furthermore ensure that they remain within sight or hearing of other members of the Personnel when conducting activities with Children.

2. Hotel Personnel having direct contact with Minors shall perform their tasks in a manner that respects the rights of third parties, especially the rights of Children, with respect and in a courteous and cultured manner, refraining from any behavior that could violate the Minor's personal space, cause the Minor to feel threatened, uncomfortable or afraid.

3. Staff is obliged to consider each time whether a reaction, message or action towards a Child is appropriate to the situation, safe, reasonable and fair to other Children, and in communication with Children is obliged to be patient, listen carefully to Children and give them answers appropriate to their age and the given situation taking into account any disabilities of the Child.

4. When making decisions regarding the Child, the Staff is obliged to inform the Child and try to take into account the Child's expectations. Respecting the Child's right to privacy, if it is necessary to deviate from the principle of confidentiality to protect the Child, the Staff is obliged to explain this to the Child as soon as possible.

5. In particular, it is unacceptable:

- the use of any form of violence against minors, both verbal and, even more so, physical, including shaming, humiliating, disrespecting and insulting the Child, shouting at the Child in a situation other than for the safety of the Child or other Children; hitting, poking, pushing, any violation of the Child's physical integrity, touching the Child in a manner that may be considered indecent or inappropriate;

- disclosing sensitive information about the Child to unauthorized persons, including other Children, whereby the prohibition includes both the Child's image and information about the Child's family, economic, medical, custodial and legal situation;

- recording the image of the Child (filming, voice recording, photographing) for private purposes, as well as allowing third parties to record images of the Child without the prior consent of the Child's Guardians and the Child himself;

- Establishing any kind of relationship with a Child, especially romantic or sexual, through private communication channels (private phone, e-mail, instant messaging, social media profiles), making proposals of an inappropriate nature to a Child, including sexual comments, jokes, gestures, and sharing erotic and pornographic content with a Child regardless of its form; inviting Children to one's place of residence, meeting with Children outside working hours;

- offering Children alcohol, tobacco products or illegal substances, as well as using them in the presence of Children.

6. Hotel employees should be on the lookout for disturbing behaviors of minors that may be indicative of abuse and should attempt to contact the minor if they suspect such abuse. If a minor attempts to make contact with a staff member, he or she should listen to him or her and, if possible, obtain the fullest possible information about the minor's situation. The Staff is obliged to assure the Children that if they feel uncomfortable in a situation, towards a particular behavior or words, they can tell the Staff or the Hotel Director about it and can expect an appropriate response and/or their assistance.

7. Concern for minors with special educational needs or disabilities:

a. Minors with special needs and disabilities usually require more care. Staff are expected in such cases to be sensitive in detail, combined with issuing clear and unambiguous messages. It is of great importance to listen carefully to minors. What they say should not be ignored;

b. if there is a need to assist a minor with disabilities in personal activities, the staff should do so with full understanding of the problem and with the documented consent of the parent (guardian);

c. minors with disabilities or specific difficulties may be excluded from the group more quickly than others. For this reason, staff's ability to listen to such children is of particular importance, especially since there may be difficulties in their expression of their feelings.

II. RULES AND PROCEDURES FOR THE IDENTIFICATION OF A MINOR STAYING AT THE HOTEL AND HIS/HER RELATIONSHIP TO THE ADULT WITH WHOM HE/SHE IS STAYING:

1. Whenever possible, identification of the child and his/her relationship to the adult with whom he/she is staying at the Hotel shall be made. Identification is compulsorily carried out by the front desk employee at check-in at the Hotel and by other employees in unusual and/or suspicious situations indicating a possible risk of child abuse.

2. To identify the child and his/her relationship to the person with whom he/she is staying at the facility, the Staff:

a. asks for the child's identity and the child's relationship to the person with whom he/she has arrived at or is staying at the facility. For this purpose, you may ask for the child's ID card or other document confirming that the adult has the right to take care of the child in the facility (e.g., child's ID card indicating kinship, civil status certificate, court decision). In the absence of an identity document, ask for the child's data (name, surname, address, PESEL number);

b. in the absence of documents indicating the relationship between the child and the adult, ask the adult and the Child about this relationship;

c. if the adult is not the parent or legal guardian of the Child, ask if he/she has a court ruling on the custody of the Child or a notarized consent of the parent for the person to travel with the Child, or a document evidencing parental consent for the adult to travel together with the Child (e.g., a written statement).

d. If the adult does not have a parental consent document, ask for the phone number of the above-mentioned to call and confirm the child's stay at the facility with a foreign adult with the knowledge and consent of the parents/legal guardians.

3. In the event of resistance on the part of the adult to show the child's document and/or indicate the relationship, the Staff shall explain that the procedure serves to ensure the safety of children using the Hotel and was developed in consultation with non-governmental organizations working on the subject. After clarifying the matter in a positive manner, the Staff thanks the child for taking the time to make sure that the child is well taken care of and once again emphas that the procedure is designed to ensure the safety of children.

4. In case of difficulties in identifying the Child and obtaining confirmation that the Child is in the Hotel with the consent of legal guardians, the Staff shall inform the supervisor or the Hotel Director. From the moment the first doubts arise, both the child, especially if the child has a disability, and the adult should be under constant observation of the staff and not be left alone. The staff shall apply policies and procedures for responding in such a situation in case of a reasonable suspicion that the welfare of a minor in the Hotel is at risk..

III. RULES AND PROCEDURES FOR RESPONDING IN CASE OF A REASONABLE SUSPICION THAT THE WELFARE OF A MINOR IN THE HOTEL PREMISES OR USING TOURIST SERVICES IS AT RISK:

1. It is the responsibility of all employees to receive reports of incidents threatening a minor and to provide support to the minor. Personnel are obliged to immediately inform their immediate supervisor or the Hotel Director of any situation of harming or having information about harming a minor, verbally, as well as in writing, by submitting an appropriate memo of the incident. The note may be in writing or by e-mail.

2. In the event that the Staff, including employees of hotel departments other than the reception desk, e.g. floor service, bar and restaurant staff, SPA area, security and others, witness unusual and/or suspicious situations involving Children, they should immediately report them to their supervisor or the Hotel Director, who will decide whether to intervene. The communication should be made on the same day that the employee became aware of the suspicion or information. If the employee is no longer present at the Hotel on the day in question, he is obliged to provide the information by telephone.

3. Reasonable suspicion of child abuse occurs when:

a. The child has disclosed the fact of abuse to a Hotel employee,

b. the employee has observed the abuse,

c. The child has signs of abuse on him/her (e.g. scratches, bruises), and when asked answers incoherently and/or chaotically and/or becomes embarrassed, or there are other circumstances that may indicate abuse, e.g. finding pornographic material with children in an adult's room.

4. Forms of Child Abuse:

a. a crime has been committed against a child (e.g. sexual abuse, child abuse),

b. there has been another form of harm that is not a crime, such as shouting, physical punishment, humiliation,

c. there has been neglect of the child's vital needs (e.g., related to nutrition, hygiene or health).

5. In a situation of reasonable suspicion of a crime committed to the detriment of the Child, the Child and the person suspected of harming the Child should be prevented from leaving the Hotel. In justified cases, a civil detention of the suspected person may be made. In such a situation, until the arrival of the police, the person should be kept under the supervision of two employees in a separate room away from the view of other guests. In such a case, the safety of the child should be ensured. The child should remain under the supervision of a staff member until the arrival of the police.

6. In the case of a reasonable suspicion that a crime has been committed related to the child's contact with the perpetrator's biological material (sperm, saliva, epidermis), the child should, if possible, not be allowed to wash and eat/drink until the arrival of the police.

7. After the police pick up the child, secure the surveillance footage and other relevant evidence (e.g., documents) of the incident and, if requested by the service, provide a copy by registered mail or in person to the prosecutor or the police.

8. If it is reported that a child has been harmed by a member of the Staff, then this person shall be removed from all forms of contact with children (not only the child harmed) until the case is clarified.

9. If a member of the Hotel Staff has committed any form of harm to a child other than committing a crime to the child's detriment, the Hotel Director should investigate all the circumstances of the case, in particular, listen to the person suspected of harm, the child and other witnesses to the incident. If the violation of the child's welfare is significant, in particular if there has been discrimination or a violation of the child's dignity, the termination of the legal relationship with the person who committed the abuse should be considered or recommended to the person's superiors. If the person who perpetrated the abuse is not directly employed by the Company, but by a third party, then you should recommend banning this person from entering the institution, and, if necessary, terminate the contract with the cooperating institution.

10. In the case of suspected child abuse by another child staying at the Hotel, a conversation should be held with the child suspected of abuse and his/her guardians, and separately with the child subjected to abuse and his/her guardians. In addition, other people with knowledge of the incident should be spoken to. Together with the caregivers of the child being abused, a remediation plan should be developed to change the undesirable behavior. A plan should be developed with the caregivers of the child being abused to ensure the child's safety, including ways to isolate the child from sources of danger.During discussions, make sure that the child suspected of abusing another child is not himself being abused by caregivers, other adults or other children. If such a circumstance is confirmed, intervene with that child as well.

11. All persons who, in connection with the performance of their duties, have acquired information about child abuse or information related to it, are obliged to keep this information confidential, excluding information provided to authorized institutions as part of intervention activities. It is absolutely forbidden to inform the media about such incidents.

IV. PROCEDURES AND PERSONS RESPONSIBLE FOR FILING NOTICES OF SUSPECTED CRIMES AGAINST A MINOR AND NOTIFYING THE GUARDIANSHIP COURT:

1. In emergency situations, in case of suspicion that the life of a child is in danger or threatened with serious harm to his health, immediately inform the appropriate services (police, ambulance) by calling 112 or 998 (emergency). Informing the services is done by the staff member who first became aware of the danger and then completes the Intervention Protocol.

2. In the case of difficulties in identifying the Child and the absence of confirmation that the Child is in the Hotel with the consent of the Child's legal guardians, the Supervisor who was informed of the situation shall decide to notify the police or, in case of doubt, take over the conversation with the suspected adult for further clarification. If the conversation confirms the belief that a crime has been attempted or committed against the child, the Superior shall notify the police.

3. Depending on the situation and location outside the situations referred to in points 1 and 2, the Superior or the Hotel Director shall, on the basis of information from the Personnel, verify to what extent the suspicion of child abuse is justified. For this purpose, he selects the appropriate measures leading to clarification of the situation or decides to intervene, and then determines which entities and institutions should be informed of the suspected abuse of a minor.

4. Interventions in cases of child abuse are carried out by the Director of the Hotel, who may permanently appoint another person for this task. If such a person is appointed, his/her details (name, surname, email, telephone) will be made known to the Staff, children and guardians. In the case of the appointment of another person to conduct interventions, the term Hotel Director shall be understood as the person responsible for conducting interventions.

5. If a child abuse is reported, the Director of the Hotel shall interview the child and other persons who have or may have knowledge of the incident and the personal (family, health) situation of the child, in particular the child's guardians. The director of the institution tries to establish the course of the incident.

6. The director of the hotel shall inform the guardians of their obligation to report suspected child abuse to the appropriate institution (prosecutor's office/police or family and guardianship court).

7. After informing the guardians in accordance with the preceding paragraph, the Director of the Hotel shall submit a notice of suspected crime to the prosecutor's office/police or a request for insight into the situation of the family to the district court, family and juvenile department, social welfare center.

8. If a crime has been committed against a child, the Hotel Director shall prepare a notice of the possibility of a crime and forward it to the locally competent police or prosecutor's office.

9. If the person suspected of abuse is a child between the ages of 13 and 17, and his behavior constitutes a criminal act, the locally competent family court or the police shall also be informed by written notification.

10. If the person suspected of abuse is a child over 17 years of age, and his behavior constitutes a criminal act, then the locally competent police or prosecutor's office shall be informed by written notification.

11. If the interview with the guardians shows that they are not interested in helping the child, ignore the incident or otherwise do not support the child who has experienced abuse, the Director of the Hotel shall draw up a request for insight into the situation of the family, which shall be referred to the competent family court.

12. A protocol shall be drawn up on the course of each intervention, which shall be attached to the register of interventions kept by the institution.

13. In the event of notification to the Police or other authorized services, in terms of providing them with personal data of adults and Minors, the relevant provisions of sharing personal data with state services shall apply.

V. THE SCOPE OF COMPETENCE OF THE PERSON RESPONSIBLE FOR PREPARING THE PERSONNEL OF THE ENTITY FOR THE APPLICATION OF THE STANDARDS, THE PRINCIPLES OF PREPARATION OF SUCH PERSONNEL FOR THEIR APPLICATION, AND HOW TO DOCUMENT THIS ACTIVITY:

1. The standards shall come into force on July 23, 2024.

2. Announcement of the Standards shall be made by posting them on the Hotel's website and displaying them at the Hotel Reception Desk, also in an abbreviated version for children by July 31.

3. The Director of the Hotel familiarizes employees with the content of the Standards and communicates the rules of their application, which is done by sending the text additionally by e-mail, and this applies to all employees within 14 days of the introduction of the Standards and each time a new employee is hired or assigned new duties involving Children.

4. The Hotel staff shall confirm in writing that they have familiarized themselves with the Company's documentation and the rules set forth therein for the application of protection measures against the threat of sexual offenses and the protection of minors by submitting an appropriate statement.

5. The Hotel Director shall be responsible for training the Hotel staff in the application of the Standards for the Protection of Minors and the Company's procedures in particular with regard to:

a. the need to respond and report without undue delay to a supervisor unusual or suspicious situations in which child abuse is suspected;

b. how to communicate with the Minor and prohibited behavior.

6. Training referred to in paragraph 5 shall be conducted periodically at least once a year, Attendance at training shall be confirmed by a personal attendance list.

7. At least once every two years, the Company will evaluate the standards to ensure their adaptation to current needs and compliance with applicable regulations. The conclusions of the assessment will be documented in writing.

8. An internal register of disclosed or reported incidents or events endangering the welfare of a minor shall be created and kept at the Hotel, the maintenance of which shall be the responsibility of the Hotel Director.

Management of the Company

Child protection standards

Child protection standards in GLAR Conference & SPA Hotel

Child protection standards in GLAR Conference & SPA Hotel - children's version

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