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§ 1. Preamble

Considering the obligation arising from the Act of 13 May 2016 on counteracting the threat of sexual offenses and protecting minors to introduce standards for entities providing hotel and tourist services, as well as for other collective accommodation facilities, 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 protection of their dignity and freedom from all forms of abuse, Blu Apartments Sarbinowo adopts this document as a model of standards, principles, and procedures in the event of suspicion that a Child staying at Blu Apartments Sarbinowo is being harmed and to prevent such threats.

§ 2. General Provisions

1. Blu Apartments Sarbinowo conducts its operations with the utmost respect for human rights, particularly the rights of Children as individuals who are especially vulnerable to abuse.
2. Blu Apartments Sarbinowo recognizes its role in conducting socially responsible business and promoting desirable social attitudes.
3. Blu Apartments Sarbinowo emphas in particular the importance of the legal and social obligation to notify law enforcement of any suspected crime against a Child and undertakes to train its staff in this regard.
4. Blu Apartments Sarbinowo undertakes to educate staff on circumstances indicating that a Child staying at the facility may be abused and on how to respond quickly and appropriately to such situations.

§ 3. Definitions

1. Child - any person under the age of 18;
2. Child abuse - the commission of a prohibited act or criminal offense against a Child by any person, including a member of Staff, or a threat to the welfare of a Child, including neglect. All offenses that can be committed against adults can also be committed against Children, as well as offenses that can only be committed against Children (e.g., sexual exploitation under Article 200 of the Penal Code). Due to the specific nature of tourist facilities, where opportunities for isolation can easily be obtained, offenses most likely to occur on their premises will be offenses against sexual freedom and morality, in particular rape (Article 197 of the Penal Code), sexual exploitation of the incapacity or helplessness of another (Article 198 of the Penal Code), sexual exploitation of dependency or a critical situation (Article 199 of the Penal Code), sexual exploitation of a person under the age of 15 (Article 200 of the Penal Code), grooming (seducing a minor using remote communication means - Article 200a of the Penal Code);
3. Child's guardian - a person authorized to represent a Child, in particular their parent or legal guardian. Under these Standards, a foster parent is also considered a guardian;
4. Staff - a person employed by Blu Apartments Sarbinowo under an employment contract, a civil law contract, or a member of an organization.

§ 4. Rules for identifying a Child staying at Blu Apartments Sarbinowo and their relationship to the adult with whom they are staying at the facility.

1. When admitting a Child for a stay at Blu Apartments Sarbinowo, whenever possible, the Child should be identified and their relationship with the adult with whom they are staying at the hotel should be determined.
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. In order to identify the Child and their relationship to the person they are staying with at the hotel, it is necessary to:
   a) ask about the Child's identity and their relationship to the person with whom they arrived at or are staying at the hotel. For this purpose, you can request the Child's identification document or another document confirming that the adult has the right to care for the Child (e.g., birth certificate, court order). In the absence of an identification document, you can ask for the Child's data (first name, last name, address, PESEL number);
   b) in the absence of documents indicating a relationship between the Child and the adult, the adult and the Child should be asked about this relationship;
   c) if the adult is not the Child's guardian, it should be asked whether they have a document proving the consent of the Child's guardians to the adult's joint trip with the Child (e.g., a written statement expressing the consent of at least one of the Child's parents/legal guardians);
   d) if the adult does not have a document of consent from the Child's guardians, the phone number of the aforementioned should be requested in order to call and confirm the Child's stay at the hotel with an unfamiliar adult with the knowledge and consent of the Child's guardians.
4. In the event of resistance from the adult to present the Child's document or indicate the relationship, it should be explained that the procedure serves to ensure the safety of the Children using the facility and that such an obligation results from the provisions of generally applicable law.
5. If the conversation does not dispel doubts about the suspicion against the adult and their intention to harm the Child, the Reception Manager or a person designated by them should be discreetly notified. In order not to arouse suspicion, you can, for example, refer to the need to use equipment at the back of the reception desk, asking the adult to wait with the Child in the lobby, restaurant or other place.
6. From the moment the first doubts arise, both the Child and the adult should be under the constant supervision of the Staff and not left alone.
7. The coordinator or a person designated by them decides to notify the police or, if in doubt, takes over the conversation with the suspected adult to obtain further explanations.
8. If the conversation confirms the belief that an attempt has been made or a crime has been committed against the Child, the supervisor notifies the police of this fact. The principles in the case of circumstances indicating harm to the Child shall apply further.
9. If the Staff of other organizational units, such as housekeeping, room service, bar and restaurant staff, or security, witness unusual or suspicious situations, they should immediately notify the Hotel Director or a person designated by them, who will decide on taking appropriate action.

§ 5. Rules and procedures for responding in cases of a reasonable suspicion that the welfare of a Child staying at or using the services of Blu Apartments Sarbinowo is at risk.

1. Staff have the knowledge and, as part of their duties, pay attention to risk factors and symptoms of child abuse.
2. Staff are obliged to immediately inform the Hotel Director of any suspected child abuse.
3. The intervention is carried out by the Hotel Director, who may assign another person to this task, unless the actions of the Staff are sufficient in this regard.
4. A reasonable suspicion of child abuse exists when:
   a) the Child has disclosed the fact of abuse to the Staff;
   b) the Staff has observed abuse;
   c) the Child has signs of abuse (e.g., scratches, bruises), and when asked, responds inconsistently and/or chaotically or/and becomes embarrassed or there are other circumstances that may indicate abuse, e.g., finding pornographic material involving Children in an adult's room;
   d) the Child's guardian or a third party reports the fact of child abuse.
5. In the event of suspicion of abuse of a Child by another Child staying at the hotel (e.g., during group activities), a conversation should be held with the Child suspected of causing harm (if possible, in the presence of the Child's guardian) and the guardian, as well as separately with the victimized Child (if possible, in the presence of the guardian) and the guardian.
6. In the event of suspicion that a Child is experiencing violence resulting in bodily harm, sexual exploitation or/and their life is at risk or repeated physical violence, repeated psychological violence or repeated other disturbing behaviors from another Child, the intervening person is additionally obliged to report the possibility of committing a crime or notify the nearest family court.
7. In the event of suspicion of abuse of a Child by the Child's guardian/person with whom they are staying at the hotel in the form of:
   a) violence resulting in bodily harm, sexual exploitation and/or their life is at risk, the Staff is obliged to ensure the safety of the Child and separate them from the guardian/person with whom they are staying who is suspected of abuse and notify the police at 112 or 997;
   b) other crimes, the intervening person is obliged to notify the police or the prosecutor's office by filing a report of the possibility of committing a crime;
   c) one-time other physical violence (e.g., slapping, pushing, shoving), psychological violence (e.g., humiliation, discrimination, ridicule) or other disturbing behaviors (i.e., shouting, inappropriate comments), the Staff is obliged to ensure the safety of the Child, conduct a conversation with the Child's guardian/person with whom they are staying who is suspected of abuse, in the case of repeated violence, the intervening person is obliged to notify the appropriate social welfare center, simultaneously submitting an application to the family court for an insight into the family situation.
8. In the event that a member of the Staff suspects that a Child is being abused by third parties (including a member of the Staff) in the form of:
   a) violence resulting in bodily harm, sexual exploitation or/and their life is at risk, the Staff is obliged to ensure the safety of the Child and separate them from the person suspected of abuse and notify the police at 112 or 997;
   b) other types of crimes, the Staff is obliged to ensure the safety of the Child and separate them from the person suspected of abuse and inform the police or the prosecutor's office in writing, filing a report of the possibility of committing a crime;
   c) one-time other physical violence (e.g., slapping, pushing, shoving) or psychological violence (e.g., humiliation, discrimination, ridicule), the Staff is obliged to ensure the safety of the Child and separate them from the person suspected of abuse. The intervening person is obliged to terminate cooperation with the person harming the Child;
   d) other disturbing behaviors (i.e., shouting, inappropriate comments), the Staff is obliged to ensure the safety of the Child and separate them from the person suspected of abuse, and the intervening person is obliged to conduct a disciplinary conversation, and in the absence of improvement, terminate cooperation.
9. In the event of a suspicion of child abuse, the Child and the person suspected of abusing the Child should be prevented from leaving the hotel.
10. In justified cases, a citizen's arrest of the suspected person may be carried out. In such a situation, until the police arrive, the person should be kept under the supervision of two employees in a separate room, away from the sight of other Guests.
11. In each case, the safety of the Child must be ensured. The Child should be under the care of an employee until the police arrive.
12. In the event of a reasonable suspicion that a crime has been committed related to the Child's contact with the perpetrator's biological material (semen, saliva, skin), the Child should, as far as possible, be prevented from washing and eating/drinking until the police arrive.
13. After the Child has been picked up by the police, the monitoring material and other relevant evidence (e.g., documents) concerning the incident should be secured and, at the request of the services, a copy should be sent by registered letter or in person to the prosecutor or police.
14. The Staff and the intervening person are obliged to prepare a service note on the incident and the actions taken. The note may be in written or email form.
15. After the intervention, the incident should be described in the register of incidents threatening the welfare of the Child. The register of incidents threatening the welfare of the Child is kept by a person designated by the Hotel Director.

§6. Employing persons to work 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. Staff employed by the hotel for work related to education, recreation and care for Children must be checked in the Register of Sex Offenders. Checking a person in the Register of Sex Offenders is carried out by printing the results of a search for the person in the Register of Sex Offenders with restricted access, which is then attached to the personal file of the person being checked. The check should be repeated annually.
3. All employees employed to work with children, including those who may have potential contact with children, should submit a declaration of no criminal record and that no proceedings are pending for acts against Children.

§ 7. Principles ensuring safe relationships between Staff and Children

1. The paramount principle of all actions undertaken by the Staff is to act for the good of the Child and in their best interests.
2. The Staff treats the Child with respect and takes into account their dignity and needs. Any form of violence against the Child is unacceptable. In achieving these goals, the Staff acts within the framework of applicable law, the organization's internal regulations and their competence.
3. The Staff is obliged to maintain a professional relationship with Children and to always consider whether the reaction, message or action towards a Child is appropriate to the situation, safe, justified and fair to other Children.
4. It is forbidden to embarrass, humiliate, belittle or insult the Child. It is forbidden to shout at the Child in a situation other than one 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. The Staff is obliged to assure Children that if they feel uncomfortable in any situation, with a particular behavior or words, they can tell the hotel Staff and can expect an appropriate response and/or help.
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 act against a Child is unacceptable.
9. Contact with Children should only take place during working hours and concern purposes falling within the scope of the Staff's duties. It is forbidden to invite Children to one's place of residence or to meet with them outside working hours. This also includes contacts with Children through private communication channels (private phone, e-mail, messengers, social media profiles).

§ 8. Final provisions

1. The Policy enters into force on February 15, 2024.
2. The hotel makes the Standards available on its website and at the reception.