Child Protection Standards

At PUHIT Kraków Sp. z o.o. facilities, based in Kraków.

Under Article 22c of the Act of 13 May 2016 on counteracting threats of sexual crime and protecting minors, these Standards for the Protection of Minors apply at all PUHIT Kraków sp. z o.o. hotel and accommodation facilities, based in Kraków.

INTRODUCTION
Glossary
§ 1

Whenever used:

1. PUHIT means PUHIT Kraków sp. z o.o., based in Kraków (ul. Fatimska 41a, 31-831 Kraków), KRS: 0000300761, NIP: 6750002302;
2. Standards means the Standards for the Protection of Minors at PUHIT facilities;
3. Facility means any hotel or accommodation facility managed by PUHIT;
4. Child means a person under 18;
5. Child’s Carer means any adult under whose care a Child stays at a PUHIT Facility;
6. Personnel means everyone employed by PUHIT, regardless of employment basis or extent, including employment contracts, contracts of mandate, other civil-law contracts and internships, and PUHIT associates providing services at Facilities;
7. Harm to a Child means any Personnel, Child’s Carer, another Child or third party act or omission violating a Child’s rights or welfare, especially mental or physical health or safety, including through distance communication;
8. Coordinator means the person(s) responsible at PUHIT for receiving and handling reports of Harm to a Child, filing notifications, and preparing Personnel to apply the Standards, including preparation rules and its documentation.

CHAPTER I
Facility Personnel
§ 2

1. Before work starts, Facility Personnel employees must give PUHIT a National Criminal Register certificate of no criminal record covering offences in Chapters XIX and XXV and Articles 189a and 207 of the Criminal Code, and the Act of 29 July 2005 on counteracting drug addiction, plus a certificate from all sections of the Register of Sex Offenders.
2. If an employee fails to provide the latter at PUHIT’s request, PUHIT may obtain it independently.
3. Employees must declare citizenship(s) and countries lived in during the last 20 years, counting from Standards introduction or employment with PUHIT, whichever is later.
4. Employees who are not Polish citizens or lived during that period outside the Republic of Poland must provide information from their citizenship country’s criminal register, obtained for professional or voluntary child-contact activities, or criminal-register information if that country’s law does not issue information for those purposes.
5. Personnel must treat Children respectfully, respecting their rights and freedoms and caring for their welfare and safety, and respond to every sign of Harm described in these Standards.
6. Personnel must read the Standards when announced and after every update.

§ 3

1. Expected conduct towards a Child: be patient and respectful; listen and explain understandably; establish professional, trust-inspiring contact; tell the Child assistance is available for Harm or other concerning or doubtful situations; tell the Child where the Standards are displayed at the Facility; consider the welfare and safety of a Child moving around the Facility without a Carer; and consider special needs, including disability and special educational needs.
2. Unacceptable conduct includes: shouting at, shaming, humiliating, disregarding or insulting the Child; psychological or physical violence; touching without consent except where the Child’s health or life is threatened; private-channel contact; recording the Child’s image without the Child’s and Carer’s consent; and offering alcohol, tobacco products or other intoxicants.
3. Personnel witnessing or learning of such conduct by another Personnel employee, a Child’s Carer or another third party must immediately inform the Coordinator under these Standards.

CHAPTER II
Procedure for identifying a Child and the Child’s Carer
§ 4

1. When a Facility reservation is made, reception Personnel must establish the identities of reservation Children, adults staying with them, and those adults’ relationships to the Children.
2. At check-in, reception Personnel must establish each Child’s identity by: asking for an identity document, including school ID, identity card, passport or other document with the Child’s photograph, in traditional or electronic form; if none, establishing the Child’s relationship with the accompanying adults; and, if an accompanying adult is not the parent or legal guardian, asking that adult for the parent’s or guardian’s consent to travel with the Child.
3. If no identity document exists and the §4(2)(c) consent is unavailable, reception Personnel must obtain a written statement containing: the Child’s Carer’s and all accompanying adults’ first name, surname, PESEL, identity-document type and number, residential address, email and telephone number; the Child’s first and last name, PESEL, parents’ or legal guardians’ first and last names, and residential address; parents’ or legal guardians’ contact details; and the relationship between the Child and Carer at the Facility and between the Child and all other accompanying adults at the Facility.
4. When necessary, Facility Personnel may contact the Child’s parents or legal guardians to confirm the statement’s information.
5. If anyone refuses to show the Child’s documents or provide the §4(3) statement, reception Personnel must discreetly inform the Coordinator immediately.

CHAPTER III
Procedure for responding to suspected Harm to a Child
§ 5

1. Harm is suspected especially when the Child reports it; Facility Personnel, other adults or Children observe signs; or the Child’s appearance indicates it, e.g. bruises or scratches, or behaviour indicates it, e.g. instance;
2. taking into account the Child’s special needs, including those resulting from disability and special educational needs.
3. The following conduct towards a Child is unacceptable in particular:
   • shouting at, shaming, humiliating, disregarding or insulting the Child;
   • using any form of psychological or physical violence against the Child;
   • touching the Child without consent, except in situations threatening the Child’s health or life;
   • contacting the Child through private communication channels;
   • recording the Child’s image without the consent of the Child and their Carer;
   • offering the Child alcohol, tobacco products or other intoxicants
4. Personnel who witness or learn of conduct by another Personnel employee, a Child’s Carer or another third party referred to in paragraph 2 above must immediately inform the Coordinator in accordance with the Standards.

CHAPTER II
Procedure for identifying a Child and the Child’s Carer
§ 4

1. When making a reservation at the Facility, reception Personnel shall establish the identities of the Children covered by the reservation, the adults who will stay with them at the Facility, and those adults’ relationship to the Children.
2. When checking guests in, reception Personnel must establish the Children’s identities by:
   1. asking for the Child’s identity document, including a school ID, identity card, passport or other document with the Child’s photograph, in traditional or electronic form;
   2. if the Child has no identity document – establishing the Child’s relationship with the adults with whom they stay at the Facility;
   3. if the adult staying with the Child is not their parent or legal guardian – asking that adult to present the parent’s or legal guardian’s consent for the adult to travel with the Child;
3. If the Child has no identity document and the consent referred to in paragraph 2(c) above is unavailable, reception Personnel must obtain a written statement containing:
   • the personal details of the Child’s Carer and all adults staying with the Child at the Facility, including first name, surname, PESEL, type and number of identity document, residential address, email address and telephone number;
   • the Child’s personal details, including first and last name, PESEL, the first and last names of parents or legal guardians, and the Child’s residential address;
   • the contact details of the Child’s parents or legal guardians;
   • a statement describing the relationship between the Child and their Carer at the Facility, and between the Child and all other adults staying with them at the Facility.
4. If it is necessary to obtain the statement referred to in paragraph 3 above, Facility Personnel may contact the Child’s parents or legal guardians to confirm the information provided in the statement.
5. If a person refuses to present the Child’s documents or provide the statement referred to in paragraph 3 above, reception Personnel must discreetly inform the Coordinator of this immediately.

CHAPTER III
Procedure for responding to suspected Harm to a Child
§ 5

1. Harm to a Child is suspected in particular when:
   • the Child reports Harm;
   • signs of Harm are observed by Facility Personnel, other adults or Children;
   • the Child’s appearance indicates Harm (e.g. bruises or scratches), or their behaviour indicates it (e.g. avoiding contact with Facility Personnel, stress, tension or withdrawal).
2. If Harm to a Child is suspected, the Coordinator or the relevant authorities directly (in particular the police, prosecutor’s office or social services) must be informed immediately.
3. If the Child’s life or health is directly threatened, Personnel must immediately call emergency services at 112 and inform the Coordinator of this in the first possible date.
4. If a report of Child Abuse is submitted directly to the authorities, the reporting person must immediately inform the Coordinator of this fact, indicating which authorities were notified, for what reason and in relation to which persons.
5. If Child Abuse is suspected, the person suspected and the Child should remain under staff observation and must not be left alone. The Staff should prevent the Child and the person suspected of Child Abuse from leaving the Facility.
6. If Child Abuse is suspected, the Staff may, where possible, make a citizen’s arrest of the suspected person. The suspected person must be isolated from the Child under the supervision of two employees, and the Child placed temporarily in the care of the Coordinator.
7. If Child Abuse involving a Child with a disability or other special needs is suspected, the Staff must in each case call for medical assistance and provide the Child with care suited to their health and needs until the Child is transferred to the care of the appropriate services, parents or legal guardians.

§ 6

1. Upon receiving a report of suspected Child Abuse or information about unacceptable conduct referred to in § 3(2) of the Standards from Facility Staff, the Child’s Guardian, other adults or Children, the Coordinator shall immediately take action to clarify the suspicion.
2. The Coordinator’s actions include, in particular, interviewing the reporting person and Facility Staff and securing the Facility’s surveillance footage. These actions must not take the form of an interview with the person suspected of Child Abuse.
3. If the Coordinator considers a report of Child Abuse justified, the Coordinator shall immediately call the Police and, where possible, notify social services and the Child’s parents or legal guardians if they are not staying with the Child in the Facility.
4. The Coordinator is responsible for cooperating with the Police, including enabling the securing of all evidence of Child Abuse, such as witness statements, surveillance recordings, biological traces, and the personal data of the Child, the Child’s Guardian, the suspected person, parents and the Child’s legal guardians obtained by PUHIT. The Coordinator is responsible for enabling the Police to search the rooms occupied by the Child and the suspected person in the Facility.
5. If the Coordinator considers a report of unacceptable conduct referred to in § 3(2) of the Standards justified, the Coordinator shall notify the superior of the Staff member concerned and, where necessary, take action in accordance with the procedure for reporting suspected Child Abuse described in this chapter.

CHAPTER IV
Documentation of actions
§ 7

1. All reports submitted to the Coordinator must be made in writing or by email. In urgent cases, a report should be made orally, followed by an official note confirming this fact and containing the substance of the report, at the earliest possible date.
2. The report or official note referred to in paragraph 1 above shall be signed by the reporting person and the Coordinator.
3. The Coordinator maintains the Report Register.
4. The Report Register contains information on reports, actions taken to verify them and the outcome of the Coordinator’s actions. All documentation concerning a report, including official notes, copies of reports submitted to the authorities and documentation concerning the Child’s stay in the Facility, shall be attached to the Report Register.
5. Documentation attached to the Report Register shall be stored confidentially, in accordance with PUHIT’s internal procedures, for no longer than required or permitted by applicable law.
6. The Coordinator and persons with access to the Report Register and its attached documentation must keep information obtained from these sources confidential, excluding information provided to authorised PUHIT employees and authorised institutions.

CHAPTER V
Final provisions
§ 8

1. The Coordinator is responsible for training Facility Staff on the Standards, including recognising and responding to signs of Child Abuse.
2. The Coordinator’s details (first name, surname and contact details) shall be communicated to Facility Staff, including by being displayed in a visible place in the Facility, in a manner understandable to Children.
3. The Coordinator shall review and monitor the Standards, taking into account the need to assess, update and adapt them to current needs and compliance with applicable laws, with the participation of competent persons, at least once every two years.
4. Attached to these Standards is an Internal Instruction, which Staff are required to read and which is not subject to the disclosure referred to in paragraph 5 below.
5. These Standards shall be made available by PUHIT on the website www.puhit.com.pl and displayed in visible places in all PUHIT Facilities, including in an abridged form adapted for Children.