EN
EN

1. DEFINITIONS

For the purpose of this document, the meaning of the following terms has been clarified:

a) A child is any person under 18 years of age including children with disabilities and children with special educational needs.

b) A strange adult is any person over the age of 18 who is not the child's parent or legal guardian.

c) Harming a child means committing a crime against a child.

d) Crime against a child - all crimes against a child are crimes that can be committed against adults, in addition to crimes that can only be committed against children (such as sexual abuse under Article 200 of the Penal Code). Due to the nature of tourist facilities, where seclusion may be easily achieved, the crimes most likely to occur on their premises will be crimes against liberty (Article 189 of the Penal Code, Article 189a of the Penal Code and Article 19ra of the Penal Code), against sexual freedom and morality, in particular, rape (Art. 197 of the Penal Code), sexual abuse of insanity and helplessness (Article 198 of the Penal Code), sexual abuse of dependence or critical position (Article 199 of the Penal Code), sexual abuse of a person under 15 years of age (Article 200 of the Penal Code), grooming (seduction of a minor through remote communication - Article 200a of the Penal Code), and crimes concerning violation of bodily integrity (Article 217 of the Penal Code).

2. PREAMBLE

Bearing in mind the regulations of the Law of May 13, 2016 on Preventing the Threat of Sexual Offenses (Journal of Laws of 2023, item 1304, as amended) and the content of the United Nations Guiding Principles on Business and Human Rights, recognizing the important role of business in ensuring respect for children's rights, in particular the right to protect their dignity and freedom from all forms of harm, Centrum Zdrowia i Wypoczynku IKAR, 78-roo Kolobrzeg, ul. Rodziewiczówny 24, hereinafter referred to as IKAR, adopts this document as a model of policies and procedures in case of suspicion of harm to a child staying at IKAR. This document is also adopted to prevent any threats against children. We will implement the child protection policy at our facility through these rules:

a) IKAR conducts its operational activities with the utmost respect for human rights, in particular, the rights of children as persons particularly vulnerable to harm.

b) IKAR, owned by the Centrum Zdrowia i Wypoczynku IKAR Sp z o. o. 78-100 Kolobrzeg, ul. Rodziewiczówny 24, NIP (Tax Number) 671-15-62-089, REGON number 330921693, recognizes its role in conducting socially responsible business and promoting desirable social attitudes.

c) In particular, IKAR underlines the importance of the legal and social obligation to notify law enforcement authorities of any case of suspected child abuse and undertakes to train its staff in this regard.

d) IKAR undertakes to educate its staff on circumstances indicating that a child staying at the facility may be harmed and on how to respond promptly and appropriately to such situations.

e) One of the forms of effective child abuse prevention is the identification of the child in the facility and his/her relationship to the adult with whom he/she resides in the facility. The staff shall take all possible steps to carry out the identification of the child and his or her relationship to the adult with whom he or she stays in the facility, based on a procedure, clearly defined rules, and good practice.

3. RULES TO SAFE RELATIONS BETWEEN IKAR STAFF AND MINORS, IN PARTICULAR PROHIBITED BEHAVIOR TOWARD MINORS

a) All persons working with children must be safe for them, which means, among other things, that their employment history should indicate that they have not harmed any child in the past.

b) Every person employed by the Centrum Zdrowia i Wypoczynku IKAR Sp. z o.o. for work related to education, recreation, and childcare, including those employed under an employment contract, civil law contract, apprentice, trainee, or volunteer, regardless of the person's nationality and age, must be compulsorily checked in the Register of Sexual Offenders (https://rps.ms.gov.pl/). Each time the Human Resources Department shall verify the personal data of an employee delegated to the above activities in the registry before signing the contract. A printout shall be added to the personal file of the person verified.

c) All employees hired to work with children, should submit a statement of clean criminal record and that there are no proceedings against them for acts against children.

d) If external entities are hired, contracts with these entities should be supplemented with an annex with a statement from the entity in question, with the obligation of the entity to obtain the consent of its employees, to provide a feasible opportunity for IKAR to enforce an appropriate standard for the screening of employees by the entity for their safety for children. Such a provision should assume the ability to control compliance with the obligation, for example, on pain of immediate termination of the contract and contractual penalty. Any person employed by a subcontractor and working with children is required to show a printout from the Sex Offender Register.

4. RULES AND PROCEDURES FOR IDENTIFYING A MINOR STAYING IN THE IKAR FACILITY AND HIS/HER RELATIONSHIP TO THE ADULT WITH WHOM HE/SHE IS STAYING IN THE FACILITY

When a reservation indicates the stay of a child, the receptionist is required to check in all persons who are in the room with the child by completing individual check-in forms. The person who is the child's guardian is required to complete the child's data and degree of relationship on the registration card. If the child's guardian is not the legal guardian, the receptionist cannot check in the guests until the degree of relationship is clarified or the child's permission is received from the legal guardian. The receptionist should immediately inform the immediate supervisor of the situation. At the same time, it should be noted that grandparents, in the case of full parental rights held by the parents, are not legal guardians as understood by the Family and Guardianship Code, and it is reasonable for them to have the parents' written consent concerning the above situation unless the establishment of kinship and the child's behavior does not raise any doubts.

5. RULES AND PROCEDURES FOR RESPONDING IN CASE OF A REASONABLE SUSPICION THAT THE WELFARE OF A MINOR IN THE IKAR FACILITY IS AT RISK

Any employee with a reasonable suspicion that a child staying at IKAR is being abused is obliged to inform the immediate supervisor, who decides on the personal response and contacts the police depending on the dynamics of the situation and circumstances.

A reasonable suspicion of child abuse exists when:

a) The child disclosed the fact of abuse to the facility's 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, it responds incoherently and/or chaotically and/or becomes embarrassed or other circumstances may indicate abuse, e.g., finding pornographic materials involving children in an adult's room.

d) Disturbing noises of child abuse/possibility of child abuse or exploitation are coming from the hotel room.

e) Disturbing behavior of an adult towards a child is observed (including using CCTV).

In a situation of escalating tensions between an adult suspected of possible child harm or an unclear relationship with a child, the main aim should be to:

a) Ensure safety for oneself.

b) Ensure the safety of the child.

c) Inform the intervention patrol.

d) Deescalate tensions and have a calm conversation.

6. IKAR'S STAFF CONDUCT POLICY ON VIOLENCE AGAINST CHILDREN WITH DISABILITIES OR SPECIAL EDUCATIONAL NEEDS

a) IKAR undertakes to regularly educate staff on handling children with disabilities or special educational needs.

b) As part of the training, staff should familiarize themselves with the rules on how to deal with a disabled child whose behavior on the premises may indicate that he or she is experiencing violence from a parent/guardian.

c) Recognizing the signs of abuse of disabled minor hotel guests is an extremely difficult task. Facility staff usually lack knowledge of the minor guest's type of disability, the pattern of behavior that characterizes a person with a particular disability, and the specifics of their relationship with the parent/guardian. A significant factor impeding the identification of symptoms that may indicate a child is being abused is the time of contact between the employee and the minor while performing work duties.

d) However, when performing their tasks, they should pay special attention just as they do to minor visitors without disabilities:

* visible injuries (bruises, burns, bites, etc.), the origin of which is difficult to explain, injuries are at different stages of healing,

* unreliability, inconsistency of explanations offered by the child for injuries,

* visible fear when the child interacts with a parent/guardian or other adult, phobias,

* somatic ailments (abdominal pain, headaches, vomiting, nausea),

* isolation from other people, especially parents/guardians,

* depressive symptoms, self-harm, suicidal thoughts,

* unconvincing or contradictory information or a parent/guardian's refusal to explain the reasons for the child's injuries,

* continued humiliation, insulting the child by the parent/guardian, using pejorative terms, vulgarities against the child,

* overstepping of the parent/guardian of acceptable limits in physical contact with the child,

* a parent/guardian's disturbed contact with reality, e.g., reacting inadequately to the situation, speaking incoherently, and other disturbing, unusual behavior.

e) An IKAR employee who observes disturbing behavior towards a child and/or the child's parent/guardian when performing their duties should immediately report it to their immediate supervisor.

7. PROCEDURES AND PERSONS RESPONSIBLE FOR REPORTING SUSPECTED CRIMES AGAINST A MINOR AND NOTIFYING THE GUARDIANSHIP COURT

Anytime there is a suspicion of committing a crime, or when a crime has been committed, the IKAR management is obliged to cooperate with law enforcement agencies and report accordingly.

In case of situations not described in this procedure, each employee should be guided primarily by his/her safety, the welfare of the child, and other good practices.

8. THE SCOPE OF COMPETENCE OF THE PERSON RESPONSIBLE FOR PREPARING IKAR'S STAFF FOR APPLYING STANDARDS. THE PRINCIPLES FOR PREPARING SUCH PERSONNEL FOR THEIR APPLICATION AND THE MANNER OF DOCUMENTING THIS ACTIVITY

The procedures have been favorably reviewed by the coordinator for the Minor Protection Standards. The coordinator's name and details are available to IKAR's controlling entities. The persons responsible for implementing and adhering to this procedure are: the director of the Centrum Zdrowia i Wypoczynku IKAR Sp.zo.o. and the heads of departments at IKAR.

* Employees employed under the Employment Contract, Civil Law Contract sign a statement of familiarity with the Minor Protection Standards applicable at IKAR.

* Persons supervising subcontractor employees are required to provide information on the scope of this procedure.

9. PERIODIC AUDIT OF IMPLEMENTED SAFETY STANDARDS

Evaluating the implemented safety standards and updating them, if required, against current legislation will be carried out periodically at least once every two years by the Management of the Centrum Zdrowia i Wypoczynku IKAR Sp. zo.o.

10. HOTEL MARKING

Information on IKAR's child protection standards is available at the IKAR reception desk and on the website: www.ikar-centrum.pl.

11. EXAMPLE TEMPLATE OF CONSENT FOR THE CHILD'S STAY WITH A PERSON WHO IS NOT A PARENT OR LEGAL GUARDIAN (template to be downloaded on the last page of the pdf).

Place, date

AUTHORIZATION TO LOOK AFTER THE CHILD

I (name and surname of the parent/legal guardian)

residing at (address of parent/legal guardian)

holding an identity card (series and number)

being the parent/legal guardian, having the right to care for: (child's name) (child's PESEL number)

residing at (child's address)

I authorize Mr/Mrs (name of the person who receives the authorization) (address of the person who receives the authorization)

holding an identity card (series and number)

to provide care, and conduct current affairs and emergencies related to the care of the above child during his/her stay at the Centrum Zdrowia i Wypoczynku IKAR, 78-100 Kołobrzeg, ul. Rodziewiczówny 24.

for the period of

I am aware of the criminal liability for submitting a false statement under Article 233 $ 6 of the Act of June 6, 1997. - Penal Code (Art. 233 of the Penal Code).

(signature of parent/legal guardian)