Standards for the Protection of Minors

in the facilities of PUHIT Kraków Sp. z o.o. based in Kraków

In view of the obligation resulting from Article 22c of the Act of May 13, 2016 on counteracting threats of criminal offenses of a sexual nature and protecting minors, to ensure the protection of minors, the following Minor Protection Standards are hereby introduced, applicable in all hotel and accommodation facilities of PUHIT Kraków sp. z o.o. based in Kraków.

INTRODUCTION
Glossary of terms
§ 1

Whenever the following terms are used:

1. PUHIT – shall mean PUHIT Kraków sp. z o.o. based in Kraków (Fatimska 41a St., 31-831 Kraków), KRS: 0000300761, NIP: 6750002302;
2. Standards – shall mean the Minor Protection Standards in PUHIT facilities;
3. Facility – shall mean any hotel and accommodation facility managed by PUHIT;
4. Child – shall mean a person under 18 years of age;
5. Child’s Guardian – shall mean any adult under whose care the Child stays in the PUHIT Facility;
6. Personnel – shall mean any person employed by PUHIT, regardless of the basis and extent of employment (including, among others, employment contract, commission contract, other civil law contracts, internship contracts), as well as PUHIT collaborators providing services on the premises of the Facilities;
7. Child Abuse – shall mean any act or omission by Personnel, Child’s Guardian, another Child or a third party infringing the Child’s rights, especially their mental or physical health or the Child’s safety, including acts and omissions via distance communication means;
8. Coordinator – shall mean the person or persons responsible within PUHIT for receiving and handling reports of Child Abuse, filing notifications, and responsible for preparing Personnel to apply the Standards, rules of Personnel preparation to their application, and documentation of this activity.

CHAPTER I
Facility Personnel
§ 2

1. Facility Personnel employees are obligated before commencing employment to provide PUHIT with a certificate of no criminal record from the National Criminal Register regarding offenses specified in chapters XIX and XXV of the Penal Code, in articles 189a and 207 of the Penal Code, and in the Act of July 29, 2005 on counteracting drug addiction, as well as a certificate from the Register of Sexual Offenders for all its sections.
2. PUHIT is entitled to independently apply for a certificate from the Register of Sexual Offenders if the employee fails to provide it upon PUHIT’s request.
3. Facility Personnel employees submit a declaration of held citizenship(s) and countries where they have lived in the last 20 years from the moment the Standards were introduced or from the start of employment with PUHIT, whichever is later.
4. Facility Personnel employees with citizenship other than Polish or who have lived in countries other than the Republic of Poland in the last 20 years are obligated to provide PUHIT with information from the criminal record of the respective country obtained for professional or volunteer activities related to contact with children, or information from the criminal record if law does not foresee issuing such information for the mentioned purposes.
5. Facility Personnel must treat Children with respect for their rights and freedoms, care for their welfare and safety, and respond to any signs of Child Abuse as described in these Standards.
6. Facility Personnel is required to become familiar with the Standards upon their announcement and after each update.

§ 3

1. Expected behaviors and standards of conduct from Facility Personnel towards the Child include:
   • showing patience and respect in contact with the Child,
   • listening to the Child and providing information in a way understandable to them;
   • establishing contact with the Child professionally and in a trusting manner;
   • informing the Child about the possibility of receiving help in situations of Child Abuse or other situations causing concern or doubts;
   • informing the Child where the Standards are displayed in 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 special needs in contact, including those arising from disabilities and special educational needs.
2. Unacceptable behaviors towards the Child particularly include:
   • yelling, embarrassing, humiliating, ignoring or insulting the Child;
   • using any form of psychological or physical violence against the Child;
   • touching the Child without consent, except in life or health-threatening situations;
   • contacting the Child through private communication channels;
   • recording the Child’s image without consent of the Child and their Guardian;
   • offering the Child alcohol, tobacco products, and other intoxicating substances;
3. Personnel who witness or become aware of behaviors from another Personnel member, Child’s Guardian, or a third party mentioned in paragraph 2 above are obliged to immediately inform the Coordinator according to the Standards.

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

1. When making a reservation at the Facility, reception staff shall verify the identity of the Children covered by the reservation, as well as adults staying with the Children in the facility, and their relationship to the Children.
2. During guest check-in, reception staff shall verify the identity of the Children by:
   1. requesting the Child’s identity document – including school ID, identity card, passport, or other photo document in traditional or electronic form;
   2. in the absence of the Child’s identity document – establishing the Child’s relationship with the adults staying in the Facility;
   3. if the adult with the Child is not the parent or legal guardian – requesting this adult to provide written consent from the parent or legal guardian to travel with the Child;
3. If the Child’s identity document and the consent mentioned in paragraph 2(c) above are missing – reception staff shall obtain a written declaration containing:
   • personal data of the Child’s Guardian and all adults staying with the Child in the Facility – including name, surname, PESEL, type and number of identity document, address, email, and phone number;
   • personal data of the Child – including name, surname, PESEL, names and surnames of parents or legal guardians, residence address;
   • contact details of the Child’s parents or legal guardians;
   • a declaration of the nature of the relationship between the Child and their Guardian in the Facility, as well as the Child’s relationship with all other adults staying there.
4. If it is necessary to obtain the declaration mentioned above, Facility Personnel is entitled to contact the Child’s parents or legal guardians to confirm the information provided.
5. In case of refusal to show the Child’s documents or provide the declaration, reception staff must immediately discreetly inform the Coordinator.

CHAPTER III
Procedure for Responding to Suspected Child Abuse
§ 5

1. Suspected Child Abuse occurs particularly in cases of:
   • a report of Abuse made by the Child;
   • observing signs of Abuse by Facility Personnel, other adults or Children;
   • when the Child’s appearance indicates Abuse (e.g., bruises, scratches), or their behavior indicates it (e.g., avoiding contact with Facility Personnel, stress, tension, alienation).
2. If Child Abuse suspicion arises, the Coordinator or the appropriate authorities (especially the police, prosecutor’s office, and social services) must be informed immediately.
3. In cases of immediate danger to the Child’s life or health, Personnel must immediately call emergency services at 112 and inform the Coordinator as soon as possible.
4. If a report of Child Abuse is made directly to authorities, the reporting person must promptly inform the Coordinator about this, indicating what authorities have been notified, for what reason, and concerning whom.
5. When Child Abuse suspicion arises, the suspected person and the Child should be supervised by personnel and not left alone. Personnel should prevent the Child and suspected person from leaving the Facility.
6. Personnel, if possible, may perform a citizen’s arrest of the suspected person. The suspect must be isolated from the Child under the supervision of two employees, and the Child handed over temporarily to the Coordinator’s care.
7. If the suspected Child Abuse involves a Child with disabilities or special needs, Personnel must always call medical help and provide care suited to the Child’s health and needs until the Child is transferred to appropriate services, parents, or legal guardians.

§ 6

1. Upon receiving a report or information of suspected Child Abuse or unacceptable behaviors mentioned in § 3 section 2 of the Standards from Facility Personnel, Child’s Guardian, other adults, or Children, the Coordinator immediately takes steps to clarify the suspicion.
2. Coordinator’s actions particularly include conducting interviews with the notifier, Facility Personnel, and securing Facility monitoring. These actions must not involve interviewing the person suspected of Child Abuse.
3. If the Coordinator finds the Child Abuse report justified, they immediately call the police and, if possible, notify social welfare and the Child’s parents or legal guardians if they are not present in the Facility.
4. The Coordinator cooperates with the Police, enabling securing evidence of Child Abuse such as witness statements, surveillance recordings, biological evidence, and personal data of the Child, Child’s Guardian, suspected person, parents, and legal guardians obtained by PUHIT. The Coordinator allows Police to search rooms occupied by the Child and suspect in the Facility.
5. If the Coordinator finds reports of unacceptable behaviors justified, they inform the supervisor of the Personnel member concerned and, if necessary, undertake actions according to the Child Abuse suspicion notification procedure described in this chapter.

CHAPTER IV
Documentation of Actions
§ 7

1. All notifications addressed to the Coordinator must be made in writing or by email. In urgent cases, notifications may be made orally, then a written report confirming the fact and containing the notification content must be prepared at the earliest opportunity.
2. The notification or official report mentioned above shall be signed by the notifier and the Coordinator.
3. The Coordinator maintains a Register of Reports.
4. The Register of Reports contains information on notifications, actions taken to verify the notification, and the outcome of the Coordinator’s activities. All documentation relating to notifications, including official reports, copies of reports lodged with authorities, and documentation relating to the Child’s stay in the Facility, shall be attached to the Register.
5. Documentation attached to the Register of Reports is stored ensuring confidentiality, in accordance with PUHIT’s internal procedures, for no longer than required or permitted under applicable law.
6. The Coordinator and persons with access to the Register of Reports and related documentation are obligated to keep information obtained confidential, except for information forwarded to authorized PUHIT employees and authorized institutions.

CHAPTER V
Final Provisions
§ 8

1. The Coordinator is responsible for training Facility Personnel in the Standards, including recognizing and responding to signs of Child Abuse.
2. Coordinator’s data (name, surname, and contact information) shall be made known to Facility Personnel, including being displayed in a visible place within the Facility, presented in a way understandable to Children.
3. The Coordinator shall review and control the Standards, considering the need for their assessment, updating, and adaptation to current needs and compliance with applicable regulations, involving competent persons, at least once every two years.
4. An internal instruction, which Personnel must familiarize themselves with and which is not subject to disclosure as mentioned in paragraph 5 below, is attached to these Standards.
5. These Standards are made available by PUHIT on the website www.puhit.com.pl and posted in visible places in all PUHIT Facilities, including in a summarized form adapted for Children’s understanding.