Minor protection standards

§ 1. Preamble

Taking into account the obligation arising from the Act of May 13, 2016, on counteracting threats related to sexual crimes and the protection of minors, to introduce standards for entities providing hotel and tourist services as well as operating other collective accommodation places, in the scope necessary to ensure the protection of minors, and recognizing the important role of business in ensuring respect for the rights of Children, in particular the right to protect their dignity and freedom from all forms of harm, hotel Hit adopts this document as a model of standards, principles, and procedures in case of suspicion that a Child staying at hotel Hit is being harmed and for prevention of such threats.

§ 2. General provisions

1. Hotel Hit conducts its operational activities with the utmost respect for human rights, in particular the rights of Children as persons particularly vulnerable to harm.

2. Hotel Hit acknowledges its role in running socially responsible business and promoting desirable social attitudes.

3. Hotel Hit particularly 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. Hotel Hit commits to educating staff on circumstances indicating that a Child staying at the facility may be harmed and on ways of quick and appropriate response in such situations.

§ 3. Definitions

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

2. Child abuse – committing a prohibited act or criminal act to the detriment of a Child by any person, including a member of the Personnel, or endangering the well-being of a 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 isolation can be easily obtained, the crimes most likely to occur on their premises are crimes against sexual freedom and morality, in particular rape (Article 197 of the Penal Code), sexual abuse of incapacity and helplessness (Article 198 PC), sexual abuse of dependence or critical situation (Article 199 PC), sexual abuse of a person under 15 years of age (Article 200 PC), grooming (seducing a minor using remote communication means – Article 200a PC);

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

4. Personnel – a person employed at hotel Hit under an employment contract, civil law contract, or a member of the organization.

§ 4. Principles of identifying the Child staying at the hotel and their relationship to the adult they are staying with.

1. When accepting a Child for a stay at hotel Hit, whenever possible, identification of the Child and their relationship with the adult they are staying with should be made.

2. Identification of a Child by the Reception Personnel 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 are staying with at the hotel, one should:
1) ask for the Child's identity and the Child's relationship to the person they arrived with or are staying with in the hotel. For this purpose, you may request the Child's identity document or other 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 can ask for the Child's data (name, surname, address, PESEL number);
2) In the absence of documents confirming kinship between 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 proving the consent of the Child's Guardians for the joint trip of the adult with the Child (e.g., a written statement expressing consent of at least one parent or legal guardian of the Child);
4) if the adult does not have a consent document from the Child's Guardians, ask for the phone number of the aforementioned persons to call and confirm the Child's stay at the hotel with a stranger with the knowledge and consent of the Child's Guardians.

4. In case of resistance from the adult regarding the presentation of the Child's document or indication of the relationship, explain that the procedure serves to ensure the safety of the Children using hotel Hit and this obligation arises from generally applicable law.

5. If the conversation does not dispel doubts about suspicion toward the adult and their intentions to harm the Child, discreetly notify the Reception Manager or their appointed person. To avoid raising suspicion, you may, for example, refer to the necessity of using equipment in the back of the reception, asking the adult to wait with the Child in the lobby, restaurant, or another place.

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

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

8. If the conversation confirms the conviction about an attempt or commission of a crime against the Child, the superior notifies the police. The rules apply further in case of circumstances indicating harm to the Child.

9. If Personnel of other organizational units witness unusual or suspicious situations, e.g., cleaning service, room service, bar and restaurant staff, security, they should immediately inform the Hotel Director or their appointed person, who will decide on the appropriate actions.

§ 5. Principles and procedures for responding in case of justified suspicion that the welfare of a Child located on the premises of hotel Hit or using the services of hotel Hit is threatened.

1. Personnel have knowledge and, as part of their duties, pay attention to risk factors and symptoms of Child abuse.

2. Personnel are obliged to immediately inform the Hotel Director of any suspicion of Child abuse.

3. Intervention is conducted by the Hotel Director, who may appoint another person for this task, unless the actions of Personnel are sufficient in this regard.

4. Justified suspicion of Child abuse occurs when:
1) the Child revealed to the Personnel the fact of abuse,
2) Personnel observed abuse,
3) the Child has signs of abuse (e.g., scratches, bruises), and when asked responds inconsistently and/or chaotically and/or is embarrassed or other circumstances indicate abuse, e.g., finding pornographic materials involving Children in the adult's room;
4) the Child's Guardian or a third person 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 (if possible, with the Child's Guardian present) and the Child's Guardian, as well as separately with the abused Child (if possible, with the Child's Guardian present) and the Child's Guardian.

6. In case of suspicion that a Child experiences violence resulting in health impairment, sexual exploitation, and/or their life is threatened by another Child, or in case of repeated physical violence, repeated psychological violence, or other repeated worrying behaviours, the person intervening is additionally obliged to submit a report of the possibility of a crime or notify the nearest family court.

7. In case of suspicion of Child abuse by the Child's Guardian/person the Child is staying with in the form of:
1) violence resulting in health impairment, sexual exploitation and/or life threat, Personnel is obliged to 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 is obliged to notify the police or prosecutor's office by submitting a report of the possibility of committing a crime;
3) one-time other physical violence (e.g., spanking, pushing, shoving), psychological violence (e.g., humiliation, discrimination, ridiculing) or other worrying behaviours (e.g., shouting, inappropriate comments), Personnel is obliged to ensure the Child's safety, conduct a conversation with the Guardian/person suspected of abuse, and in case of repeated violence, the person intervening is obliged to notify the appropriate social welfare center and simultaneously submit an application to the family court to review the family situation.

8. In case a member of the Personnel suspects that the Child is abused by third parties (including a member of the Personnel) in the form of:
1) violence causing health impairment, sexual exploitation and/or life threat, Personnel is obliged to ensure the Child's safety and separate them from the person suspected of abuse and notify the police at 112 or 997;
2) other types of crimes, Personnel is obliged to ensure the Child's safety and separate them from the person suspected of abuse and inform in writing the police or prosecutor's office by submitting a report of the possibility of committing a crime;
3) one-time other physical violence (e.g., spanking, pushing, shoving) or psychological violence (e.g., humiliation, discrimination, ridiculing), Personnel is obliged to ensure the Child's safety and separate them from the person suspected of abuse. The person intervening is obliged to terminate cooperation with the person harming the Child;
4) other worrying behaviours (e.g., shouting, inappropriate comments), Personnel is obliged to ensure the Child's safety and separate them from the person suspected of abuse and the person intervening is obliged to conduct a disciplinary conversation, and if no improvement occurs, terminate cooperation.

9. In case of suspicion of Child abuse, the Child and the person suspected of abuse should be prevented from leaving the hotel.

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

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

12. In case of justified suspicion that a crime related to the Child's contact with the perpetrator's biological material (semen, saliva, skin) has occurred, as far as possible, do not allow the Child to wash or eat/drink until the police arrive.

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

14. Personnel and the person intervening are obliged to prepare an official report of the event and actions taken. The report may be in written or email form.

15. After the intervention, the event should be recorded in the registry of events threatening the welfare of the Child. The registry of events threatening the welfare of the Child is maintained by the person appointed by the Hotel Director.

§6. Employment of persons working with Children

1. 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.

2. Personnel employed by the hotel for work related to education, recreation, and care of Children must be mandatorily checked in the Register of Sexual Offenders. Checking a person in the Register of Sexual Offenders is done by printing the search results of the person with limited access, which is then attached to the personnel files of the checked person. The check must be repeated annually.

3. All employees employed to work with children, including those who may have potential contact with children, should submit a statement of no criminal record and that no proceedings for offenses against Children are pending.

§ 7. Principles ensuring safe relations between Personnel and the Child

1. The primary principle of all activities undertaken by Personnel is acting for the benefit of the Child and in their best interest.

2. Personnel treats the Child with respect and considers their dignity and needs. Use of violence against a Child in any form is unacceptable. Personnel carrying out these goals acts within the scope of applicable law, internal regulations of organizations, and their competencies.

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

4. It is forbidden to embarrass, humiliate, neglect, or offend the Child. It is forbidden to shout at the Child except in situations arising from 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, information about their family, economic, medical, care, and legal situation.

6. Personnel is obliged to assure Children that if they feel uncomfortable in any situation, due to specific behavior or words, they can tell the hotel Personnel and expect an appropriate reaction and/or help.

7. It is forbidden to offer Children alcohol, tobacco products, or illegal substances, as well as 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 objectives included in the Personnel's duties. It is forbidden to invite Children to one's residence or meet them outside working hours. This also includes contact with Children through private communication channels (private phone, email, messengers, social media profiles).

§ 8. Final provisions

1. The policy comes into effect on February 15, 2024.

2. The hotel makes the Standards available on its website and at the reception.