STANDARDS FOR THE PROTECTION OF MINORS

Preamble

In order to ensure that our Hotels are safe places for everyone, especially the youngest, in order to protect children from all forms of harm, Nosalowy Dwór Sp. z o. o. adopts these Standards, which are to be a model of conduct for employees and associates of the Company in order to ensure the safety of all minors staying in our Hotels. This document is a set of rules and procedures used in the event of a suspicion that a child staying in our facility is being harmed and to prevent such threats, taking into account the situation of disabled children and children with special educational needs.

1. Introductory Provisions

• These Standards for the Protection of Minors in Hotels and Apartments of Nosalowy Dwór Sp. z o. o. constitute a model of standards, principles and procedures aimed at ensuring respect for children's rights and preventing all forms of their harm.
• All employees and associates of the Company, regardless of the legal form of cooperation with the Company, are obliged to comply with these principles.
• These Standards are subject to periodic verification and assessment, no less than once every two years, in order to ensure their adjustment to current needs and to applicable regulations. The conclusions from the above assessment will be documented in writing.

2. Definitions The following terms shall have the following meanings in these Standards:

2.1. Minor/child - any person who has not reached the age of 18;

2.2. Guardian of a child - the legal representative of a child: parent or guardian; foster parent; temporary guardian (i.e. a person authorized to represent a minor citizen of Ukraine who is on the territory of the Republic of Poland without adult care);

2.3. Alien adult - any person over the age of 18 who is not a parent or legal guardian of a child.

2.4. Abuse - any action or omission that has a negative impact on a child, consisting in particular of physical or psychological violence, sexual abuse or neglect of a child, constituting a crime committed to the detriment of a child, any intentional or unintentional action/omission of an individual, institution or society as a whole and any result of such action or inaction that violates the rights, freedoms and personal rights of children and/or interferes with their optimal development.

2.5. Physical violence - intentional action that causes physical injuries to the child's body, e.g. pushing, pulling; signs of physical violence are: bruises and marks on the child's body, swelling, fractures, sprains, burns, including spot burns, as well as fear of undressing, clothing inappropriate for the weather (long sleeves), wearing dark glasses, apathy/aggression;

2.6. Psychological violence - intentional action or omission that involves inappropriate interaction that has a negative impact on the child, e.g. emotional inaccessibility and neglect, blackmail, insults, threats, humiliation, shaming, blaming, denigration, rejection, developmentally inappropriate or inconsistent interactions with the child, failure to recognize or acknowledge the child's individuality and the psychological boundaries between the parent and the child

2.7. Sexual violence - involving a minor in sexual activity when they cannot give conscious consent to such activity due to the level of their development, e.g. presenting pornographic content to minors, proposing/forcing intimate relationships, rape, forcing to other sexual activities, signs of sexual violence, e.g. somatic symptoms of unknown origin, traces of physical violence, difficulties with walking/sitting, fears, phobias, depression, hyperactivity, aggression. We deal with sexual abuse when such activity occurs between a child and an adult or a child and another child, if these people are in a relationship of care, dependency, power due to age or level of development. Sexual abuse can also take the form of sexual exploitation, i.e. any actual or attempted abuse of a position of vulnerability, superiority of power, or trust, for sexual purposes, including, but not limited to, deriving financial, social or political benefits from the sexual exploitation of another person. There is a particular risk of sexual exploitation during humanitarian crises. The risk of exploitation exists both for children and their caregivers (definition from UN Bulletin ST/SGB/2003/13).

2.8. Child neglect - long-term or incidental failure to meet the basic needs of a child by persons obliged to care for the child, e.g. lack of care for the child's hygiene, failure to treat the child, failure to provide appropriate clothing, malnutrition of the child. Neglect occurs in the relationship of the child with the person who is obliged to care for, raise, care for and protect the child.

2.9. Crime - an act prohibited by law under penalty of punishment, socially harmful to a greater degree than insignificant;

2.10. Crime to the detriment of a child - all crimes that can be committed against adults can be committed to the detriment of children, and additionally crimes that can only be committed against children (e.g. sexual abuse under Article 200 of the Penal Code). Due to the specificity of tourist facilities, where it is easy to obtain the possibility of isolation, the crimes that can most often be committed on their premises will be crimes against sexual freedom and decency, in particular rape (Article 197 of the Penal Code), sexual exploitation of insanity and helplessness (Article 198 of the Penal Code), sexual exploitation of dependency or critical situation (Article 199 of the Penal Code), sexual exploitation of a person under 15 years of age (Article 200 of the Penal Code), grooming (seduction of a minor by means of distance communication - Article 200a of the Penal Code), violation of bodily integrity (Article 217 of the Penal Code), the crime of abuse (Article 207 of the Penal Code).

2.11. Other forms of child abuse than committing a crime to the detriment of a child – all forms of violence against a child that do not meet the characteristics of a crime prosecuted at the public prosecutor's office (e.g. shouting, humiliation, pulling, insults, neglecting needs, etc.).

2.12. Company - Nosalowy Dwór sp. z o. o. with its registered office in: 34-500 Zakopane, at ul. Balzera 21 d, registered in the District Court for Kraków Śródmieście in Kraków, XII Commercial Division under KRS number 0000398651, NIP: 7361714598, REGON: 122423387;

2.13. Hotels - Hotels and Apartments run by the Company - i.e. Nosalowy Dwór Resort & Spa, Nosalowy Park Hotel & Spa and Park Residence by Nosalowy;

2.14. Employee - a person employed by the Company under an employment contract;

2.15. Collaborator - a person cooperating with the Company under a civil law contract;

2.16. Employee employed to work with children - any person performing tasks or delegated to perform tasks related to the upbringing, education, recreation, treatment, provision of psychological counseling, spiritual development, practicing sports or pursuing other interests by minors or with care for them, including a person employed under an employment contract, civil law, apprentice, trainee and volunteer, regardless of the citizenship and age of such person.

3. General principles

3.1. The Company conducts its business with the utmost respect for human rights, including the rights of children, as people particularly vulnerable to all forms of harm, both physically and mentally. In its activities, the Company always ensures respect for the dignity of the child and takes actions to protect them from harm by adults.

3.2. In conducting its activities, the Company ensures a safe space for all persons staying on the premises of the Hotels, paying attention to and responding to any disturbing signals in this regard, especially in the area of ​​the safety of minors. The Company's response may include, in particular, notifying law enforcement authorities of any case of suspicion of a possible crime to the detriment of minors. Nosalowy Dwór emphas the importance of the legal and social obligation to notify law enforcement authorities of any case of suspicion of a crime to the detriment of children and undertakes to train its employees in this regard.

3.3. These Standards are part of the business model of the Company, which operates in a socially responsible manner and promotes desirable social attitudes and values ​​within its activities.

4. Obligations of the Hotel Staff

4.1. Any discrimination against minors is prohibited. Employees and co-workers are obliged to treat children in a fully professional manner, with due respect and treat them in the same way as other Guests.

4.2. Employees and co-workers, in performing their duties, take special care of the needs of children with disabilities and with special educational needs, provided that information about such needs is voluntarily disclosed by children or their legal guardians to members of the Hotel staff.

4.3. Employees and co-workers of the Hotel are obliged to behave appropriately towards minor children, in accordance with the principles of professionalism. Employees and co-workers are obliged to comply with the following principles:

• Behaviors and practices expected from employees ▪ Be patient and respectful when communicating with a child.
• Listen carefully to the child and provide answers that are appropriate to their age and the situation. When communicating with a child, try to keep your face level with the child's face.
• Assure the child that if they feel uncomfortable with a situation, they can tell you or another designated person about it and get help.
• Inform the child where the Standards are located in the facility in a version they understand. Assure them that if they have questions, they can contact you or another designated person.
• Observe equal treatment of children regardless of their gender, sexual orientation, ability/disability, social status, ethnicity, culture, religion and worldview.
• Ensure a safe space. If there are children in the area where you work, ensure that equipment and supplies are used in a manner that is consistent with their intended use and that the surroundings are safe (look for window and stair guards, restricted access to busy roads, open water, etc.).
• If you see a child/children left unattended and the situation may indicate a threat to the child's safety, take action to locate the parent/guardian. ▪ Unacceptable behaviors and practices by employees towards children in the facility
• Do not shout, embarrass, humiliate, disrespect or insult a child.
• It is not allowed to hit, nudge, push or in any way violate the physical integrity of a child, unless there is a threat to the child's health or life.
• It is not allowed to establish any romantic or sexual relationships with a child or make inappropriate proposals to them. This also includes sexual comments, jokes, gestures and sharing erotic and pornographic content with children regardless of its form.
• It is not allowed to record the image of a child for private or professional purposes (recording, photographing) without the consent of the child's parents/guardians and the consent of the child themselves. This also applies to allowing third parties to record images of children. The exception is a situation where the child's image is only a detail of a whole, such as a gathering, landscape, public event, then the consent of the child's parent/guardian is not required.
• It is forbidden to establish contact with a child through private communication channels (private telephone, e-mail, instant messaging, social media profiles) or meet with a child outside the workplace.
• It is forbidden to offer a child alcohol, tobacco products or illegal substances.
• It is forbidden to touch a child if they do not want to be touched or in a way that may be considered indecent or inappropriate.
• It is forbidden to allow a situation in which an employee remains in a Hotel room alone with a minor, except for a situation where leaving the minor alone in the room could significantly endanger their well-being, in particular health or life. If possible, it is necessary to ensure the presence of another adult, the supervision of monitoring cameras or to plan work duties so that they can return to them when such a situation has passed.
• Any contacts between a hotel employee and a minor staying at the hotel should not go beyond interactions justified by the official duties of the hotel employee.

4.4. Any inappropriate behavior (including behavior that may be indicative of child abuse, in particular the use of violence against children) by a staff member or another adult or another child towards a minor should be immediately reported to the superior or the responsible person indicated in par. 10. All persons who witnessed the inappropriate behavior (e.g. other employees, co-workers, Guests, children, contractors, etc.) are authorized and required to make a report.

4.5. In the cases indicated in par. 4.3.2, the employee or co-worker, depending on the seriousness of the offense, may suffer disciplinary or contractual consequences, including termination of the contract with the Company. If the behavior of the staff member constitutes a crime, the Company notifies the law enforcement authorities (police) of the incident.

4.6. Employees and associates of the Company are obliged to take actions in such a way as not to violate the interests of minor children and prevent abuse towards them, as well as to respond to established or suspected violations in accordance with these Standards.

4.7. In the event that an employee or associate fails to fulfill the obligations provided for in these Standards, in particular does not respond appropriately to cases of child abuse, they shall be liable under the contract on the principles specified in the contract or under disciplinary liability on the basis of the provisions of the Labor Code.

5. Company Obligations

5.1. The Company is obliged to train each employee or co-worker in the principles and obligations arising from these Standards. In particular, the employee or co-worker should receive training and clear guidelines from the employer regarding:

• identification of circumstances that may indicate harm to a minor;
• a quick way to respond to the circumstances indicated in paragraph 5.1.1.:
• the method and scope of conducting a conversation with a minor child and a person posing as their guardian,
• the method of verifying the identity of the adult and the minor, as well as assessing the relationship between the minor and the adult;
• providing appropriate information about your suspicions to your superiors or the management of the Company;
• situations when you should notify law enforcement agencies or other appropriate state services about your suspicions.

5.2. The Company implements the above education through various forms of training, including: external and internal training, e-learning, educational materials developed by the hotel and available to employees, educational materials available free of charge, developed by other organizations.

5.3. The Company undertakes to familiarize each employee or collaborator of the Hotel with these Standards before starting to perform their duties. This obligation applies to all employees, regardless of their position or scope of duties. The Company is aware that each employee or collaborator may witness or suspect child abuse and should have information on appropriate conduct. The employee or collaborator confirms familiarization with these Standards by submitting an appropriate declaration, the template of which is Annex No. 1 to the Standards.

5.4. Considering that due to the nature of the Company's activities, almost every employee or associate of the Company may have or has contact with children, the Company undertakes to inform all candidates for employment or cooperation about these Standards and to conduct a detailed interview with candidates during the recruitment process regarding their previous experience in working with children and the scope of duties in this area.

5.5. In cases required by law, the Company undertakes to request certificates of no criminal record from candidates for work directly with children, and also undertakes to check the candidate's past to the extent permitted by law, including in particular the scope described in point 9 of these Standards.

5.6. Before the arrival of Guests who have booked a stay with minor children, the Company sends them a message informing them of the following issues: - the Child Protection Standards in force at the Hotel, along with a link to the content of this document; - information that in order to ensure the highest standard of safety, it is recommended to have a document confirming the right to care for the child, e.g. the child's identity document indicating kinship, civil status certificate, court decision, and in the case of an adult stranger - notarial consent from the parent for the given person to travel with the child or consent signed by the child's parent, including the child's data, address of residence, telephone contact details for the parent and the identity document number/PESEL number of the person to whom the parent has entrusted the care of the child.

6. Procedure for determining the identity of a child during check-in at the reception

6.1. Employees and associates of the Company, regardless of their position, should remain vigilant and respond to incorrect or questionable circumstances that may indicate that a child is being harmed.

6.2. Employees and associates, in particular those responsible for reception service (checking in, checking out of Guests), in the interests of the well-being of children staying in Hotels, while respecting the privacy of all Guests, take actions aimed at determining:

• the child's identity and
• his/her relationship with the adult with whom he/she is in the Hotel.

6.3. In situations where an employee or co-worker observes unusual behavior or circumstances, including in particular the circumstances indicated in Annex 3, which may indicate the fact of child abuse, it is mandatory to identify the minor child and the child's relationship with the adult. The employee shall immediately notify the Coordinator referred to in paragraph 10 or his/her deputy of each such situation, who, if possible, should be present at the conversation.

6.4. In order to identify the child and his/her relationship with the person with whom he/she is staying in the facility, it is necessary to:

• First, inform the Guest that in order to ensure the safety of children on the premises, these Standards have been introduced, to which the Hotel is obliged by law.
• Then, ask about the child's identity and the child's relationship to the person with whom they arrived at the facility or are staying there. For this purpose, you can ask for the child's identity document or another document confirming that the adult has the right to care for the child on the premises. Examples of documents that can be used for identification include: ID card, school ID, MObywatel application, Patient's Internet Account, court order. In the absence of an identity document, you can ask for the child's data (name, surname, address). ▪ In the absence of documents indicating the relationship between the child and the adult, you should ask the adult and the child about this relationship.
• If the adult is not the child's parent or legal guardian, ask if they have a document confirming the parents' consent to the adult's joint trip with the child (e.g. a written statement, notarial consent to provide care).
• Regardless of the above, if the adult does not have any of the above documents, ask them to complete an appropriate declaration, the template of which is Annex 2. The declaration should include the child's data and the data of the adult with whom the child is staying, together with an indication of the relationship between the child and the adult. If the adult is not the child's parent or legal guardian, they should declare that the parents/legal guardians have given consent to care for the child.

6.5. In the event of resistance from an adult to produce the child's document and/or indicate the relationship, it should be explained that the procedure is intended to ensure the safety of children using the Hotel and has been developed in consultation with non-governmental organizations operating in this area.

6.6. After explaining the matter positively, thank them for the time they have spent making sure that the child is well looked after and empha once again that the procedure is intended to ensure the safety of children.

6.7. If the conversation does not dispel doubts regarding the suspicion against the adult and his/her intention to harm the child, the Coordinator referred to in paragraph 10 or his/her deputy, the supervisor (if he/she was not present during the conversation) and the security staff (if they are on the premises at the time) should be discreetly notified. The employee or co-worker asks the adult to wait with the child in a specified place (e.g. in the lobby).

6.8. From the moment when the first doubts arose, both the child and the adult should be under constant observation by the staff and not be left alone. The priority of the Hotel staff in such a situation is to ensure the safety of the minor.

6.9. The Coordinator referred to in paragraph 10 or his deputy, who has been notified of the situation, shall initiate a conversation with an adult in order to obtain explanations or shall decide to notify the law enforcement authorities (police).

6.10. In the event that employees of other departments of the Hotel, e.g. cleaning service, room service, bar and restaurant staff, relaxation zone, security or others, witness unusual and/or suspicious situations, they should immediately notify the Coordinator referred to in paragraph 10 or his deputy, who will decide on taking appropriate action.

6.11. Depending on the situation and place, the Coordinator referred to in paragraph 10 or his deputy shall verify to what extent the suspicion of child abuse is justified. To this end, he shall select appropriate measures leading to the clarification of the situation, including taking steps to establish the child's identity and his relationship with the adult (unless this has been established earlier) or shall decide to notify law enforcement agencies (police).

7. Procedure in the event of a probable child harm being identified

7.1. An employee who has a reasonable suspicion that a child staying in the facility is being or has been harmed should immediately notify the Coordinator or his deputy, who is obliged to determine the status of the case and, if the established circumstances justify such a step, to notify the police.

7.2. In the event of an existing threat to the safety of a child, an employee who has a reasonable suspicion of a child being harmed shall immediately notify the police by calling 112, describing the circumstances of the incident.

7.3. Regardless of the above, the employee shall notify the Coordinator of the incident.

7.4. A reasonable suspicion of child abuse occurs when:

• A child has disclosed to an employee or co-worker of the Hotel the fact of abuse,
• A third party (e.g. another Guest) has disclosed to an employee or co-worker of the Hotel the suspicion of child abuse, and the employee's or co-worker's observations have confirmed this fact with a high probability,
• An employee or co-worker has observed abuse or circumstances that indicate a high probability of abuse, e.g. the child has traces of abuse (traces of physical violence, e.g. scratches, bruises), and when asked, the child responds inconsistently and/or chaotically and/or becomes embarrassed, or there are other circumstances that may indicate abuse, e.g. finding pornographic materials involving children in an adult's room, including the examples of circumstances indicated in Annex No. 3.

7.5. After notifying the police, the Hotel employees should ensure that the minor and the adult who may have committed the crime do not leave the Hotel before the police arrive, and that potential evidence of the crime is not destroyed (e.g. securing recordings from surveillance cameras)

7.6. In each case, the child's safety should be ensured, which is a priority. The child should be under the care of an employee or associate of the Hotel until the police arrive.

7.7. 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 (sperm, saliva, epidermis), the child should be prevented from washing and eating/drinking until the police arrive, if possible. The reasons for applying such restrictions should be explained to the child.

7.8. After the child is collected by the police, the monitoring material and other important evidence (e.g. documents) regarding the incident should be secured and forwarded to the Coordinator, who, at the request of the services, will forward a copy to the law enforcement authorities, with confirmation of receipt.

7.9. The Coordinator describes the incident in the register.

7.10. If the Company receives information regarding the possibility of harming the child after the child's stay at the Hotel ends (e.g. finding evidence of violence against the child after the child's departure), this information is immediately forwarded to the Coordinator specified in paragraph 10, who will take steps to assess and report the above facts to the law enforcement authorities.

7.11. In justified cases, the Coordinator is also obliged to consider and consult with the Company's Legal Department the possibility of notifying the guardianship court (so-called notification under the civic duty).

7.12. If a facility employee witnesses physical violence used against a child (slapping, pulling, shouting, other listed in the definition of physical violence), he or she should try to stop the abuse and react. This provision also applies to situations where the perpetrator of physical violence is a parent, legal guardian of the child or another adult with whom the child is staying.

7.13. In the event of a child under seven years of age being left unattended, an employee who has become aware of such an event should notify their superior. The superior who has been notified of the situation shall decide on further action, taking into account the circumstances of the case. Depending on the findings, the superior shall attempt to locate the parent/legal guardian or other adult with whom the child is staying at the facility and explain that they cannot leave the child unattended. In a situation where it is not possible to locate the parent/legal guardian or other adult with whom the child is staying at the facility, or the parent/legal guardian/other adult does not want to and/or is unable to take care of the child, the superior shall notify the police of this fact. In each case, the child's safety must be ensured.

8. Procedure in the event of child abuse by an employee or other third party

8.1. In the event of a suspicion of child abuse by an employee, co-worker or other adult who is not directly employed by the Company but by an external entity, the person who received this information should immediately inform the Coordinator referred to in paragraph 10 or his deputy.

8.2. If the life or health of a child is at risk, the person who received information on this subject should immediately notify the police by calling the emergency number 112, providing their own data, the child's data (if possible), the child's location and a description of the circumstances of the case and notify the Coordinator referred to in paragraph 10 or his deputy or another decision-making person, who will notify the child's guardians/parents. The person who received information about the incident also informs the Coordinator, at least by phone and email.

8.3. In the event that an employee has committed a form of harm to a child other than committing a crime to their detriment, the Coordinator, after receiving information, should investigate all the circumstances of the case, in particular by listening to the employee suspected of harm and other witnesses to the event. In a situation where the violation of the child's welfare is significant, in particular when discrimination or violation of the child's dignity has occurred, the Coordinator should recommend appropriate personal actions in relation to this employee.

8.4. If the person who committed the harm is not directly employed by the Company but by an external entity (e.g. outsourcing), then the Company notifies the relevant employer of the suspicion concerning their employee, recommends banning them from entering the Hotel premises, and imposing consequences appropriate to the proven crime.

9. Hiring people to work with children

9.1. When hiring people to work with children, the Hotel conducts an interview regarding their previous employment in working with children, experience and education in this area. In particular, the Hotel pays attention to whether the employment history of this person does not indicate harming a child in the past.

9.2. Each person employed / delegated by the Company to work directly with a minor, related to education, recreation, sports or the pursuit of other interests by children or care for them must be checked in the Register of Perpetrators of Sexual Offences. Checking a person in the Register is done by printing the results of searching for a person in the Register with limited access, which is then placed in the personal files of the person being checked or other documentation concerning this person. The statement of the employee / co-worker / intern in connection with the obligation to check in the Register of Perpetrators of Sexual Offences is included in Annex No. 5.

9.3. Ponadto, każda osoba, o której mowa w ust. 9.2., zatrudniana / delegowana do pracy bezpośrednio z dziećmi, przedkłada Spółce informację z Krajowego Rejestru Karnego w zakresie przestępstw określonych w rozdziale XIX i XXV Kodeksu karnego, w art. 189a i art. 207 Kodeksu karnego oraz w ustawie z dnia 29 lipca 2005 r. o przeciwdziałaniu narkomanii (Dz.U. z 2023 r. poz. 172 oraz z 2022 r. poz. 2600), lub za odpowiadające tym przestępstwom czyny zabronione określone w przepisach prawa obcego.

9.4. The person referred to in par. 9.2., who holds citizenship of a country other than the Republic of Poland, shall also submit to the Company information from the criminal records of the country of citizenship obtained for the purposes of professional or volunteer activities related to contacts with children.

9.5. The person referred to in par. 9.2. shall submit to the Company a declaration of the country or countries in which they have resided for the last 20 years, other than the Republic of Poland and the country of citizenship, and at the same time shall submit to the employer or other organizer information from the criminal records of these countries obtained for the purposes of professional or volunteer activities related to contacts with children.

9.6. If the law of the country referred to in par. 9.4 does not provide for the issuance of information for the purposes of professional or volunteer activities related to contacts with children, information from the criminal records of that country shall be submitted.

9.7. If the law of the country from which the information referred to in par. 9.4.-9.6. is to be submitted does not provide for its preparation or no criminal register is kept in a given country, the person referred to in par. 9.1. shall submit to the Company a declaration of this fact together with a declaration that he or she has not been finally convicted in that country of prohibited acts corresponding to the offences specified in Chapters XIX and XXV of the Penal Code, in Art. 189a and Art. 207 of the Penal Code and the Act of 29 July 2005 on Counteracting Drug Addiction and no other judgment has been issued against her in which it was stated that she has committed such prohibited acts, and that she is not obliged under a court decision, other authorised body or act to comply with the ban on occupying any or specific positions, performing any or specific professions or activities related to the upbringing, education, recreation, treatment, provision of psychological counselling, spiritual development, practicing sports or pursuing other interests by minors, or with caring for them.

9.8. The declarations referred to in paragraphs 9.5. and 9.7. are submitted under penalty of criminal liability for making a false declaration. A declaration of the following content is submitted under declarations submitted under penalty of criminal liability: "I am aware of criminal liability for making a false declaration." This declaration replaces the authority’s notice of criminal liability for submitting a false declaration.

9.9. The Company shall attach the information and declarations referred to in paragraphs 9.3.-9.7. to the employee's personal file or documentation concerning the person permitted to perform such activity.

9.10. In the event of using the services of external entities, the Company shall include a provision in the agreement with this entity enabling the enforcement of an appropriate standard in the scope of checking by this entity of employees, in terms of their safety towards children. The provision enables the Company to control the fulfilment of the obligation under penalty of immediate termination of the agreement and contractual penalty or other sanctions related to failure to fulfil the terms of the agreement in this respect. A template of the declaration regarding the application of child protection standards for outsourcing companies employed by the Hotel constitutes Annex No. 6.

10. Person responsible

10.1. The President of the Management Board of the Company shall supervise the application of the Standards.

10.2. The President of the Management Board of the Company shall appoint a person responsible for the implementation of these Standards, hereinafter referred to as the Coordinator. (Coordinator).

10.3. The responsibilities of the person indicated in section 10.2. include:

• preparing and implementing this procedure and familiarizing employees with it;
• training employees in its application and documenting this activity, in accordance with the procedures adopted by the Company;
• consulting on all doubtful cases and making decisions regarding reporting the case to law enforcement authorities;
• In justified cases, the Coordinator is obliged to consider and consult with the Company's Legal Department the possibility of notifying the guardianship court (so-called notification as part of a civic duty).
• in the event of a justified suspicion that a crime has been committed, the Coordinator is responsible for securing evidence, including monitoring recordings, and providing them in the form of copies upon request of the services;
• conducting the procedure in a situation where a child has been harmed by an employee of the facility or another adult who is not directly employed by the Company but by an external entity;
• preparing a report to law enforcement authorities or the guardianship court;
• keeping a register of events and documenting interventions, reported events related to child abuse on the premises of the Hotels, the fact of reporting the case to law enforcement agencies;
• monitoring and proposing updates to the Standards if necessary (e.g. changes in the law, streamlining of procedures, etc.).

10.4. The Coordinator's data is available to all employees and Guests, including children. The data includes information on how to contact the Coordinator (e-mail address, telephone number, availability: working days and hours).

10.5. Monitoring and evaluation include verification of the implementation of the Standards, responding to signals of violations of rules and procedures and proposing changes to the document, especially in terms of adapting them to current needs and compliance with applicable regulations.

10.6. The Coordinator conducts a survey among employees and collaborators of the Hotels once every 2 years to monitor the level of implementation of the Standards.

10.7. The Coordinator processes the surveys completed by employees, prepares a monitoring report on this basis, which is then forwarded to the President of the Management Board of the Company. The President of the Management Board introduces the necessary changes to the document and announces the new wording of the Standards for the Protection of Minors.

11. Final Provisions

11.1. At every stage of applying the procedures resulting from these Standards, it should be remembered that they may constitute an inconvenience for Guests, therefore, it is necessary to show understanding for their reactions by explaining to them the necessity, both actual and legal, of carrying out the procedures in question in the Hotel. However, the reaction of a hotel Guest cannot constitute a reason for departing from the procedures.

11.2. All procedures provided for in the Standards should be applied in a proportionate manner to the situation and in a rational manner.

11.3. In the scope not regulated in these Standards, the relevant provisions of the Act of 13 May 2016 on counteracting threats of sexual crime and the protection of minors (Journal of Laws of 2024, item 560) and the Act of 25 February 1964 - the Family and Guardianship Code (Journal of Laws of 2023, item 2809) shall apply.

11.4. The Hotel reserves the right to refuse to continue providing services to an adult Guest in the event of non-compliance or reasonable suspicion of non-compliance with these Standards during their stay at the Hotel.

11.5. The Hotel may refuse to accept an adult Guest who has violated the Standards during their previous stay, in particular by harming a Minor on the Hotel premises or by committing a sexual offence to the detriment of a Minor on the Hotel premises.

11.6. These Standards enter into force on 15.02.2024.

11.7. These Standards are available to Staff, Minors and their guardians on the Company's website, as well as in a publicly accessible place in the Hotel.

11.8. These Standards in a shortened version, understandable to Minors, are also made available in the manner indicated in paragraph 11.7.

Statement