STANDARDS FOR THE PROTECTION OF MINORS

§ 1. Preamble

Taking into account the obligation resulting from the Act of May 13, 2016, on counteracting threats of sexual crimes and protection of minors, to introduce standards for entities providing hotel and tourism services, as well as operating other collective accommodation places, to the extent necessary to ensure the protection of minors, and recognizing the important role of business in ensuring respect for children's rights, especially the right to protection of their dignity and freedom from all forms of harm, the Noclegi Stadion facility adopts this document as a model of standards, principles, and procedures in case of suspicion that a Child staying at the Noclegi Stadion facility is being harmed and to prevent such threats.

§ 2. General provisions

1. The Noclegi Stadion facility conducts its operational activity with the utmost respect for human rights, especially the rights of Children as persons particularly vulnerable to harm.

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

3. The Noclegi Stadion facility especially emphasizes the importance of the legal and social obligation to notify law enforcement authorities of any suspicion of committing a crime against Children and commits to training its staff in this regard.

4. The Noclegi Stadion facility commits to educating staff about circumstances indicating that a Child staying in the facility may be harmed and about ways to quickly and properly respond to such situations.

§ 3. Definitions

1. Child – any person under 18 years of age;

2. Child abuse – committing a prohibited act or punishable act to the detriment of a Child by any person, including a member of the Staff, or endangering the welfare of the Child, including neglect. All crimes that can be committed against adults can also be committed to the detriment of Children, as well as crimes that can only be committed against Children (e.g. sexual exploitation under Article 200 of the Penal Code). Due to the specifics of tourist facilities where it is easy to isolate persons, the crimes most likely to occur on their premises are crimes against sexual freedom and morality, especially rape (Article 197 of the Penal Code), sexual exploitation of incapacity and helplessness (Article 198 PC), sexual exploitation of dependence or critical situation (Article 199 PC), sexual exploitation of a person under 15 years of age (Article 200 PC), grooming (seduction of a minor using remote communication means – Article 200a PC);

3. Child's guardian – a person authorized to represent the Child, especially their parent or legal guardian. According to the standards, a foster parent is also considered a guardian;

4. Staff – a person employed at the Noclegi Stadion facility on the basis of an employment contract, civil law contract, or a member of the organization.

§ 4. Principles of identifying a Child staying in the facility and their relationship with the adult they stay with in the facility.

1. When admitting a Child to stay at the Noclegi Stadion facility, whenever possible, the Child and their relationship with the adult they stay with in the hotel should be identified.

2. Identification of the Child by the reception Staff is mandatory in unusual and suspicious situations indicating a risk of harm to the Child.

3. To identify the Child and their relationship to the person they stay with at the facility, you should:
1) ask for the Child's identity and the relationship of the Child to the person they arrived with or stay with. You may ask for the Child's identity document or another document confirming that the adult has the right to care for the Child (e.g., birth certificate, court ruling). If there is no identity document, you may ask for the Child's data (name, surname, address, PESEL number);
2) if there are no documents indicating the kinship of the Child and the adult, ask both the adult and the Child about this relationship;
3) if the adult is not the Child's guardian, ask if they have a document confirming the consent of the Child's guardians for the adult to travel with the Child (e.g., a written statement of consent by at least one of the Child's parents/legal guardians);
4) if the adult does not have a consent document from the Child's guardians, ask for their phone number to call and confirm the Child's stay with the adult person with the knowledge and consent of the Child's guardians.

4. In case of resistance from the adult to show the Child's document or indicate the relationship, explain that the procedure is to ensure the safety of Children using the Noclegi Stadion facility, and such an obligation arises from the provisions of universally applicable law.

5. If the conversation does not dispel doubts concerning the adult and their intent to harm the Child, discreetly notify the Reception Manager or a person designated by them. To avoid raising suspicion, you can, e.g., refer to the need to use equipment at the back of the reception while asking the adult to wait with the Child in the lobby, restaurant, or another place.

6. From the moment the first doubts arise, both the Child and the adult should be under constant observation by the Staff and not be left alone.

7. The Reception Manager or a person designated by them decides on notifying the police or, in case of doubts, takes over the conversation with the suspicious adult to obtain further explanations.

8. If the conversation confirms suspicion of an attempt or commission of a crime against the Child, the superior notifies the police. The rules applied in circumstances indicating harm to the Child then apply.

9. If Staff from other organizational units witness unusual or suspicious situations, e.g., cleaning service, room service, bar and restaurant staff, security, they should immediately inform the facility Manager or their designee, who will decide on appropriate actions.

§ 5. Principles and procedures of response in case of justified suspicion that the welfare of the Child on the premises of the Noclegi Stadion facility or using its services is threatened.

1. Staff possess knowledge and within their duties pay attention to risk factors and symptoms of Child abuse.

2. Staff are obligated to immediately inform the facility Manager of any suspicion of Child abuse.

3. Intervention is conducted by the facility Manager, who may assign another person to this task, unless Staff actions in this regard are sufficient.

4. Justified suspicion of Child abuse occurs when:
1) the Child reveals to the Staff the fact of abuse,
2) Staff observe abuse,
3) the Child has signs of abuse (e.g., scratches, bruises), and when asked responds inconsistently and/or chaotically or is embarrassed, or there are other circumstances indicating abuse, e.g., finding pornographic materials involving Children in an adult's room;
4) the Child's guardian or a third party reports the fact of Child abuse.

5. In case of suspicion of Child abuse by another Child staying at the hotel (e.g., during group activities), a conversation should be held with the Child suspected of abuse (preferably in the presence of the Child's guardian) and the Child's guardian, as well as separately with the abused Child (preferably in the presence of the Child's guardian) and the Child's guardian.

6. In case of suspicion that a Child experiences health-threatening violence, sexual exploitation, or life danger, or repeated physical or psychological violence, or repeatedly disturbing other behaviors from another Child, the person intervening is also obliged to file a report of a potential crime or notify the nearest family court.

7. In case of suspicion of Child abuse by the Child's guardian/person staying with the Child in the hotel in the form of:
1) health-threatening violence, sexual exploitation, and/or life danger, Staff must ensure the Child's safety and separate them from the guardian/person suspected of abuse and notify the police at 112 or 997;
2) other crimes, the person intervening must notify the police or prosecutor's office by filing a report of a possible crime;
3) one-time other physical violence (e.g., slapping, pushing, shoving), psychological violence (e.g., humiliation, discrimination, mocking), or other disturbing behaviors (e.g., shouting, inappropriate comments), Staff must ensure the Child's safety, conduct a conversation with the guardian/person suspected of abuse, and if violence repeats, the intervening person must notify the appropriate social welfare center while simultaneously submitting a family court request for family situation inspection.

8. In case a Staff member suspects a Child is harmed by third parties (including Staff) in the form of:
1) health-threatening violence, sexual exploitation, and/or life danger, Staff must ensure the Child's safety, separate the Child from the suspected person, and notify the police at number 112 or 997;
2) other types of crimes, Staff must ensure Child safety, separate the Child from the suspected person, and inform police or prosecutor's office in writing by filing a report of a possible crime;
3) one-time other physical violence (e.g., slapping, pushing, shoving) or psychological violence (e.g., humiliation, discrimination, mocking), Staff must ensure Child safety and separate the Child from the suspected person. The intervening person must terminate cooperation with the person harming the Child;
4) other disturbing behaviors (e.g., shouting, inappropriate comments), Staff must ensure Child safety, separate the Child from the suspected person, and the intervening person must conduct a disciplinary conversation and terminate cooperation if no improvement occurs.

9. In case of suspicion of Child abuse, it is necessary to prevent the Child and the person suspected of abuse from leaving the hotel.

10. In justified cases, a citizen's arrest of the suspected person may be made. In such a situation, until the police arrive, the person should be supervised by two employees in a separate room away from other Guests' sight.

11. In every case, the Child's safety must be ensured. The Child should remain under an employee's care until the police arrive.

12. In case of justified suspicion of a crime related to contact of the Child with the perpetrator's biological material (semen, saliva, skin), if possible, prevent the Child from washing or eating/drinking until the police arrive.

13. After the Child is taken by the police, secure monitoring footage and other important evidence (e.g., documents) regarding the incident and, at the request of authorities, provide copies by registered mail or personally to the prosecutor or police.

14. Staff and the intervening person are required to prepare an official report of the incident and actions taken. The report may be in written or email form.

15. After intervention, describe the incident in the register of incidents threatening the welfare of the Child. The register is kept by a person designated by the facility Manager.

§6. Employment of persons to work with Children

1. All persons working with Children must be safe for them, which means, among others, that their employment history should show no past harm to any Child.

2. Staff employed by the facility for work related to education, recreation, and care of Children must be mandatorily checked in the Register of Offenders of Sexual Crimes. Checking the person in the Register is done by printing the search results from the restricted-access Register of Offenders of Sexual Crimes, which is then attached to the personnel files of the person checked. The check must be repeated annually.

3. All employees working with children, including those who may have potential contact with children, should submit a statement of no criminal record and no ongoing proceedings against them concerning crimes against Children.

§ 7. Principles ensuring safe relationships between Staff and the Child

1. The primary principle of all actions taken by Staff is acting for the good of the Child and in their best interest.

2. Staff treat the Child with respect and take into account their dignity and needs. Any form of violence against the Child is unacceptable. Staff operate within the bounds of applicable law, internal organizational regulations, and their competencies to achieve these goals.

3. Staff are obliged to maintain a professional relationship with Children and always consider whether their reaction, communication, or action towards the Child is appropriate to the situation, safe, justified, and fair to other Children.

4. It is forbidden to shame, humiliate, neglect, or insult the Child. It is forbidden to shout at the Child except in situations related to the safety of the Child or other Children.

5. It is forbidden to disclose sensitive information about the Child to unauthorized persons, including other Children. This includes the Child's image and information about their family, economic, medical, caregiving, and legal situation.

6. Staff must assure Children that if they feel uncomfortable in any situation, regarding specific behavior or words, they can tell the facility Staff and expect an appropriate reaction and/or assistance.

7. It is forbidden to offer Children alcohol, tobacco products, or illegal substances, as well as to use them in the presence of Children.

8. Any violent action against a Child is unacceptable.

9. Contact with Children should take place only during working hours and concern purposes within the Staff's duties. It is forbidden to invite Children to one's residence or meet with them outside working hours. This also applies to contact through private communication channels (private phone, email, messengers, social media profiles).

§ 8. Final provisions

1. This policy comes into force on February 15, 2024.
2. The facility makes the standards available on its website and at the reception.