MINOR PROTECTION STANDARDS

at the facilities of PUHIT Kraków Sp. z o.o., with its registered office in Kraków

In view of the obligation under Article 22c of the Act of 13 May 2016 on Counteracting Threats of Sexual Crime and the Protection of Minors to ensure the protection of minors, these Standards for the Protection of Minors are hereby introduced and apply at all hotel and accommodation facilities of PUHIT Kraków sp. z o.o., with its registered office in Kraków.

INTRODUCTION
Glossary
§ 1

Whenever the following terms are used:

1. PUHIT means PUHIT Kraków sp. z o.o., with its registered office in Kraków (ul. Fatimska 41a, 31-831 Kraków), KRS: 0000300761, NIP: 6750002302;
2. Standards means the Standards for the Protection of Minors at PUHIT facilities;
3. Facility means any hotel or accommodation facility managed by PUHIT;
4. Child means a person under 18 years of age;
5. Child’s Guardian means any adult under whose care the Child stays at a PUHIT Facility;
6. Personnel means every person employed by PUHIT, regardless of the basis or extent of employment (including an employment contract, contract of mandate, other civil-law contracts or internship agreements), as well as PUHIT’s associates who provide services at the Facilities;
7. Harm to a Child means any act or omission by Personnel, the Child’s Guardian, another Child or a third party that violates the Child’s rights or interests, in particular the Child’s mental or physical health or safety, including acts and omissions carried out via means of remote communication;
8. Coordinator means the person or persons responsible at PUHIT for receiving and reviewing reports concerning Harm to a Child, submitting notifications, and preparing Personnel to apply the Standards, including the rules for such preparation and documenting this activity.

CHAPTER I
Facility Personnel
§ 2

1. Before commencing employment, Facility Personnel must provide PUHIT with a criminal-record certificate from the National Criminal Register covering offences specified in Chapters XIX and XXV of the Criminal Code, Articles 189a and 207 of the Criminal Code, and the Act of 29 July 2005 on Counteracting Drug Addiction, as well as a certificate from the Register of Sex Offenders covering all its sections.
2. If an employee fails to provide the certificate from the Register of Sex Offenders at PUHIT’s request, PUHIT may independently apply for its issuance.
3. Facility Personnel must submit a declaration of their citizenship(s) and the countries in which they have lived during the last 20 years preceding the introduction of the Standards or commencement of employment at PUHIT, whichever occurred later.
4. Facility Personnel who are not Polish citizens or who have lived during the last 20 years in countries other than the Republic of Poland must provide PUHIT with information from the criminal register of the country of which they are citizens, obtained for professional or volunteer activities involving contact with children, or information from the criminal register if that country’s law does not provide for issuing information for the above purposes.
5. Facility Personnel must treat Children with respect for their rights and freedoms, with concern for their welfare and safety, and must respond to all manifestations of Harm to a Child as described in these Standards.
6. Facility Personnel must familiarise themselves with the Standards upon their announcement and after each update.

§ 3

1. The conduct and standards expected of Facility Personnel towards a Child include:
   • showing patience and respect when interacting with the Child,
   • listening to the Child and providing information in a way the Child can understand;
   • establishing contact with the Child professionally and in a way that inspires trust;
   • informing the Child that assistance is available in cases of Harm to a Child or other situations causing concern or doubt;
   • informing the Child where the Standards are displayed at the Facility;
   • paying attention to the welfare and safety of a Child moving around the Facility without a Child’s Guardian;
   • taking into account the Child’s specific needs, including those arising from a disability or special educational needs.
2. The following conduct towards a Child is prohibited in particular:
   • shouting at, shaming, humiliating, disregarding or insulting the Child;
   • using any form of psychological or physical violence against the Child;
   • touching the Child without consent, except in situations posing a threat to the Child’s health or life;
   • contacting the Child through private communication channels;
   • recording or otherwise capturing the Child’s image without the consent of the Child and the Child’s Guardian;
   • offering the Child alcohol, tobacco products or other intoxicating substances
3. Personnel who witness or learn of conduct by another member of Personnel, the Child’s Guardian or another third party referred to in paragraph 2 above must immediately inform the Coordinator in accordance with the Standards.

CHAPTER II
Procedure for identifying the Child and the Child’s Guardian
§ 4

1. When making a reservation at the Facility, reception Personnel establish the identity of the Children covered by the reservation, the adults who will stay with the Children at the Facility, and those persons’ relationship to the Children.
2. When checking guests into the Facility, reception Personnel must establish the Children’s identity by:
   1. requesting the Child’s identity document, including a school ID, identity card, passport or another document bearing the Child’s photograph, in traditional or electronic form;
   2. if the Child has no identity document, establishing the Child’s relationship with the adults accompanying the Child at the Facility;
   3. if the adult accompanying the Child at the Facility is not the Child’s parent or legal guardian, requesting that adult to present the parent’s or legal guardian’s consent for the adult to travel with the Child;
3. If the Child has no identity document and the consent referred to in paragraph 2(c) above is unavailable, reception Personnel must obtain a written declaration containing:
   • the personal data of the Child’s Guardian and all adults staying with the Child at the Facility, including first name, surname, PESEL number, type and number of identity document, residential address, email address and telephone number;
   • the Child’s personal data, including first name and surname, PESEL number, the first names and surnames of the parents or legal guardians, and the Child’s residential address;
   • the contact details of the Child’s parents or legal guardians;
   • a statement describing the relationship between the Child and the Guardian at the Facility, and the Child’s relationship with all other adults staying with the Child at the Facility.
4. If it is necessary to obtain the declaration referred to in paragraph 3 above, Facility Personnel may contact the Child’s parents or legal guardians to confirm the information provided in the declaration.
5. If a person refuses to present the Child’s documents or submit the declaration referred to in paragraph 3 above, reception Personnel must immediately and discreetly inform the Coordinator.

CHAPTER III
Procedure for responding to suspected Harm to a Child
§ 5

1. Harm to a Child is suspected in particular in the event of:
   • a report of Harm made by the Child;
   • signs of Harm observed by Facility Personnel, other adults or Children;
   • the Child’s appearance indicating Harm (e.g. bruises or scratches), or the Child’s behaviour indicating it (e.g. avoiding contact with Facility Personnel, stress, tension or withdrawal).
2. Upon suspecting Harm to a Child, the Coordinator or the relevant authorities directly, in particular the police, prosecutor’s office or social services, must be informed immediately.
3. In the event of an immediate threat to the Child’s life or health, Personnel must immediately call for help at emergency number 112 and inform the Coordinator at the earliest opportunity.
4. If a report of Harm to a Child is made directly to the authorities, the reporting person must immediately inform the Coordinator, stating which authorities were notified, why, and regarding which persons.
5. When Harm to a Child is suspected, the person suspected and the Child should remain under Personnel observation and must not be left alone. Personnel should prevent the Child and the person suspected of Harm to a Child from leaving the Facility.
6. If Harm to a Child is suspected, Personnel may, where possible, make a citizen’s arrest of the suspected person. The suspected person must be isolated from the Child under the supervision of two employees, and the Child placed temporarily in the Coordinator’s care.
7. If Harm to a Child with a disability or other special needs is suspected, Personnel must in every case call for medical assistance and provide the Child with care adapted to the Child’s health condition and needs until the Child is handed over to the care of the appropriate services, parents or legal guardians.

§ 6

1. Upon receiving a report of suspected Child Abuse or information about unacceptable conduct referred to in § 3(2) of the Standards from Facility Staff, the Child’s Guardian, another adult or a Child, the Coordinator immediately takes steps to investigate the suspicion.
2. The Coordinator’s actions include, in particular, interviewing the reporting person and Facility Staff and securing the Facility’s monitoring footage. These actions must not take the form of an interview with the person suspected of Child Abuse.
3. If the Coordinator considers a report of Child Abuse justified, the Coordinator immediately calls the Police and, where possible, notifies social services and the Child’s parents or legal guardians, if they are not staying with the Child at the Facility.
4. The Coordinator is responsible for cooperating with the Police, including enabling the securing of all evidence of Child Abuse, such as witness statements, monitoring recordings and biological traces, as well as the personal data of the Child, the Child’s Guardian, the suspect, and the Child’s parents and legal guardians obtained by PUHIT. The Coordinator is responsible for enabling the Police to search the rooms occupied by the Child and the suspect at the Facility.
5. If the Coordinator considers a report of unacceptable conduct referred to in § 3(2) of the Standards justified, the Coordinator notifies the employee’s supervisor of this fact and, if necessary, takes action in accordance with the procedure for reporting suspected Child Abuse described in this chapter.

CHAPTER IV
Documentation of actions
§ 7

1. All reports submitted to the Coordinator must be made in writing or by email. In urgent cases, a report may be made orally, followed as soon as possible by an official note confirming this fact and stating the content of the report.
2. The report or official note referred to in paragraph 1 above must be signed by the reporting person and the Coordinator.
3. The Coordinator maintains a Register of Reports.
4. The Register of Reports contains information on reports, actions taken to verify them and the results of the Coordinator’s actions. All documentation concerning a report is attached to the Register of Reports, including official notes, copies of reports submitted to authorities and documentation concerning the Child’s stay at the Facility.
5. Documentation attached to the Register of Reports is stored confidentially, in accordance with PUHIT’s internal procedures, for no longer than required or permitted by applicable law.
6. The Coordinator and persons with access to the Register of Reports and its attached documentation must keep information obtained from these sources confidential, except for information disclosed to authorised PUHIT employees and authorised institutions.

CHAPTER V
Final provisions
§ 8

1. The Coordinator is responsible for training Facility Staff on the Standards, including recognising and responding to signs of Child Abuse.
2. The Coordinator’s details (first name, surname and contact details) are communicated to Facility Staff, including by posting them in a visible place at the Facility, in a manner understandable to Children.
3. The Coordinator reviews and monitors the Standards, taking into account the need to assess, update and adapt them to current needs and ensure compliance with applicable regulations, with the participation of competent persons, at least once every two years.
4. An Internal Instruction is attached to these Standards. Staff must familiarise themselves with it, and it is not subject to the disclosure referred to in paragraph 5 below.
5. These Standards are made available by PUHIT on www.puhit.com.pl and posted in visible places at all PUHIT Facilities, including in an abbreviated form adapted for Children to read and understand.