MINORS’ PROTECTION STANDARDS

Preamble

In view of the legal obligation arising from the provisions of the Act of 13 May 2016 on counteracting threats of sexual crime and the protection of minors (consolidated text: Journal of Laws of 2024, item 560), and the United Nations Guiding Principles on Business and Human Rights, recognising the important role of business in ensuring respect for children’s rights, particularly their right to dignity and freedom from all forms of harm, the Facility adopts this document as a model of rules and procedures where there is suspicion that a child staying at the Facility is being harmed, and for preventing such threats.


§1.

Definitions


For this document, the following terms are defined:

  1. Child – any person under 18.
  2. Facility Director/Coordinator – person managing the Facility and responsible for implementing this Procedure.
  3. Harm to a Child – committing an offence against a child.
  4. Unrelated adult – any person over 18 who is not the Child’s parent or legal guardian.
  5. Facility – the place where the Company conducts hotel, recreational, sports or interest-development activities, and where it organises related events.
  6. Facility Employee – any member of the Facility staff, regardless of the legal basis of their work there.
  7. Employee working with Children – a Facility Employee working with children, including a contractor, intern, trainee or volunteer, regardless of nationality or age, subject to verification in the Register of Sex Offenders.
  8. Offence against a Child – all offences that may be committed against adults may also be committed against Children, plus offences exclusively against Children (e.g. sexual abuse under Article 200 of the Criminal Code[1]). Given the nature of facilities where seclusion is easily possible, the most common offences on their premises will be offences against sexual freedom and decency, in particular rape (Article 197 of the Criminal Code), sexual exploitation of insanity or helplessness (Article 198), sexual exploitation of dependence or a critical situation (Article 199), sexual exploitation of a person under 15 (Article 200), and grooming (enticement of a minor via distance communication – Article 200a).
  9. Company – Grupa Hossa S.A., based in Gdańsk (80-280), ul. Norwida 1.
  10. Minors’ Protection Standards – Facility website’s published Procedure excerpt.

§ 2.

We will implement the Child protection Procedure at our Facility through these rules:

  1. The Facility conducts its operations with the utmost respect for human rights, particularly Children’s rights as persons especially vulnerable to harm.
  2. The Facility recognises its role in socially responsible business and promoting desirable social attitudes.
  3. The Facility particularly emphasises the legal and social duty to notify law enforcement of every suspected offence against Children and undertakes to train its staff in this regard.
  4. The Facility undertakes to educate staff about circumstances indicating that a Child staying at the Facility may be harmed and how to respond quickly and appropriately.
  5. Identifying a Child staying at the Facility and their relationship with the accompanying adult is an effective way to prevent harm. Staff take all possible steps to identify the Child and their relationship with the adult accompanying them.

§ 3.

Procedure in case of suspected harm to a Child

  1. Whenever possible, the Child and their relationship with the accompanying adult must be identified.
  2. In unusual and/or suspicious situations indicating a possible risk of harm to a Child, the Facility Employee must carry out identification at reception, where reception operates at the Facility.
  3. To identify the Child and their relationship with the accompanying person:
    a.Ask for the Child’s document (ID card, passport or school ID) and record its details in the Facility register, if maintained.
    b.Ask about the Child’s relationship with the person accompanying them to or staying with them at the Facility.
    c.If there are no documents proving the Child’s relationship to the adult, ask both the adult and the Child about it.
    d.If the adult is not the child’s parent or legal guardian, ask whether they have a document confirming parental consent for the Unrelated Adult to travel with the Child (e.g. a parent’s statement). If not, request the parents’ or guardians’ telephone number to contact them and confirm that the Child is staying at the Facility with the Unrelated Adult with their knowledge and consent. Inform the parent or legal guardian that their personal data is processed to protect the Child’s interests, and provide the controller’s details and the location where they can read the full information notice (Appendix 1 to the Minors’ Protection Standards).
  4. If an adult refuses to show the Child’s document and/or state the relationship, explain that the procedure ensures the safety of Children using the Facility and was developed in consultation with NGOs working in this area.
  5. Once the matter is resolved satisfactorily, thank them for their time in ensuring that the Child is properly cared for and reiterate that the procedure aims to protect Children.
  6. If the conversation does not dispel doubts about the adult’s suspected harm to the Child, notify the Facility Director/Coordinator and security, if present at the Facility.
  7. From the first doubts onward, both the Child and adult must remain under constant staff observation and must not be left alone.
  8. The Facility Director/Coordinator notified of the situation decides whether to notify the police or, if in doubt, takes over the conversation with the suspected adult for further clarification.
  9. If the conversation confirms an attempted or committed offence against the Child, the Facility Director/Coordinator notifies the police.
  10. All Facility Employees, including cleaning staff, housekeeping, bar and restaurant staff, leisure-area staff and security, must immediately notify the Facility Director/Coordinator if they witness unusual and/or suspicious situations. The Director/Coordinator will decide on appropriate action.
  11. Depending on the situation and location, the Facility Director/Coordinator assesses whether the suspicion of harm to the Child is justified. They take appropriate steps to clarify the situation or decide to intervene and notify the police.

§ 4.

Procedure where circumstances indicate harm to a Child

  1. Where there is reasonable suspicion that a Child staying at the Facility is being harmed, immediately notify the police by calling 112 and describing the circumstances. Depending on the situation, the call is made by the direct witness (Facility Employee/Facility Director/Coordinator). If the caller is a Facility Employee, they must also inform the Facility Director/Coordinator.


§ 5.

Employing people to work with Children

  1. Everyone working with children must be safe for them, meaning, among other things, that their employment history should show they have not previously harmed a child.


§ 6.

Final provisions

  1. The Minors’ Protection Standards, as an extract from the Procedure, are available on the Facility’s website, at reception where operated, or posted on the information board where one is provided.
  2. This Procedure will be reviewed at least every two years to ensure it meets current needs and complies with applicable law; the review findings will be documented in writing.


Appendices:
1) Appendix 1: Information notice for contacting a minor’s parent/legal guardian

[1] Act of 6 June 1997, Crim. Code (consol. text: J. Laws 2022, item 1138, as amended.)