0 Considering:
1. Respecting the child's right to protection of their dignity and freedom from all forms of harm;
2. Preventing incidents that may result in harm to the child during their stay in hotels of the Likus Hotels and Restaurants group ("Facilities"), in particular by responding as quickly as possible to irregularities in the child's relations with adults with whom the child stays in the Facilities;
3. Ensuring safe relations between the child and the staff of the Facility, and in particular preventing unauthorized behaviors towards the child;
4. Fulfilling the legal obligations imposed on Holding Liwa Sp. z o.o., KRS 324377, ul. Górczewska 53, 01- 401 Warsaw ("Company") as an entity providing hotel services; this document of the Standards for the Protection of Minors ("Standards") is adopted, which is a collection of rules and procedures applicable in the Facility to implement the above objectives. §1
I. GENERAL PRINCIPLES
1. The Company, as an entity providing hotel services, is aware of its social responsibility for conducting this activity in a manner that promotes desirable social attitudes in terms of protecting children's rights.
2. Desirable social attitudes include, in particular, setting an example of appropriate response to any harm done to children in the Facility. Appropriate response includes both immediate, actual response to noticed irregularities, as well as notifying the appropriate bodies about the suspicion of a crime being committed to the detriment of a minor.
3. Each person performing work or other services in the Facility should remain sensitive to behavior that raises suspicion that a child staying in the Facility may be harmed. The Facility's staff is trained in identifying incorrect behavior, obtaining necessary information from adults arriving at the Facility with the child and from the child themselves, as well as how to respond to these irregularities.
4. The Facility's staff is aware of the need to identify a child staying at the Facility and determine their relationship to the adult with whom the child is staying. In connection with this, identification rules and procedures are established, including the bases and purposes of processing personal data.
5. The standards are published on the Facility's website and in a visible place in the Facility. Thanks to this, minors will be aware that they can contact the Facility's staff to obtain necessary help when they are being harmed. Adults will be informed about the reasons why the Facility's staff may expect information about children and their relationships with adults.
6. A child or minor is understood as any person under 18 years of age. §2
II. SAFE RELATIONS BETWEEN FACILITY STAFF AND MINORS
1. Persons working in the Facility with children are previously verified by the Company in order to determine whether their work with children will be safe for the children. In the event that such persons are employees or collaborators of another entity performing services in the Facility on behalf of the Company, the Company imposes a contractual obligation of verification on each such entity. The Company has the right to request proper documentation of the verification carried out by this entity. This entity submits to the Company a declaration of fulfillment of the legal obligation to verify its personnel.
2. The provisions below shall apply in the event and to the extent related to conducting in the Facility activities related to the upbringing, education, recreation, treatment, provision of psychological counseling, spiritual development, practicing sports or pursuing other interests by minors, or caring for them and persons employed and permitted to engage in such activities in the Facility.
3. The Company shall carry out verification within the limits of the applicable provisions on the protection of personal data. Verification shall include checking employment history and verifying entries in the Register of Sexual Offenders ("Register"). The Company shall require from candidates to work with children - within the limits of the applicable provisions - to provide certificates from the National Criminal Register or criminal registers of other countries in which the candidate has resided in the last 20 years, or statements from the candidate.
4. The Company checks a person in the Register by printing out the results of searching for a person in the Register with limited access or in the Register of persons in respect of whom the State Commission for Combating Sexual Exploitation of Minors Under the Age of 15 has issued a decision to enter the Register. The Company places this printout in the personal files of the person being checked or in the documentation concerning the person permitted to engage in activity with children. The check is repeated once a year.
5. The check is performed regardless of the form of employment (also based on unpaid forms of cooperation, e.g. volunteering), gender, citizenship and age of the person being checked. The Company also verifies persons already employed in the Facility on the date the Standards enter into force.
6. The purpose of the verification is to establish that persons working in the Facility with children have not harmed any child in the past.
7. The diagram illustrating the process of verifying the Facility's staff constitutes Annex No. 1 to the Standards.
8. Each member of the Facility's staff is familiar with these Standards and undertakes to comply with them.
9. Each member of the Facility's staff who works with children is subject to regular training.
10. The Company appoints a person responsible for monitoring compliance with the Standards in the Facility and for staff education.
11. The Company does not allow such behaviors of a person working in the Facility with children towards children as:
• a. initiating physical contact, unjustified by the needs resulting from the performed duties;
• b. initiating a relationship with a child outside of work;
• c. using physical or verbal violence;
• d. using immoral or sexually charged jokes or proposals towards children;
• e. photographing or recording a child without the consent of the child and their guardian, unless this applies to a situation where the child's image is part of a larger whole;
• f. leaving with the child - without a justified need - the place where classes, games, etc. are held in which the child participates, without the presence of other people;
• g. giving the child alcohol or other intoxicants.
12. Proper relations between a person working in the Facility and children include in particular:
• a. ensuring the child is comfortable in direct contact;
• b. treating the child with respect and patience;
• c. communicating in a manner appropriate to the child's age;
• d. demonstrating a supportive attitude towards the child;
• e. informing the child about the possibility of obtaining help in the Facility, in the event of noticing disturbing circumstances;
• f. fair and equal treatment of children, regardless of their gender, age, disability and any other personal characteristics.
III. IDENTIFICATION OF A MINOR IN THE FACILITY AND HIS RELATIONSHIP TO THE ADULT WITH WHOM THEY STAY
1. The Facility Staff identifies the child and his/her relationship with the adult with whom they are staying in the Facility. These activities are performed by the Facility's reception staff. In the event of a justified need, any other member of the Facility's staff is also authorized to perform identification.
2. The procedure for identifying a child and their relationship to the person with whom they are staying at the Facility includes the following actions by the Facility staff:
• a. The Facility staff asks the guest for the child's document (e.g. identity card, passport, school ID, document in the mObywatel application) and the document of the adult and records their data in the system containing the data of the Facility's guests.
• b. In the absence of documents indicating the relationship of the child and the adult - the staff asks both the adult and the child about this relationship. The Company establishes an example scheme of a conversation with an adult and a child, the content of which is included in Appendix No. 4 to the Standards.
• c. If the adult is not the child's parent or legal guardian, the staff asks whether the adult has a document confirming the consent of the parents or legal guardians for the adult to travel together with the child (e.g. a written declaration). Information about the existence or lack of such a document is recorded in the system covering the data of the guests of the Facility.
• d. If the adult does not have a document confirming the consent of parents or legal guardians, the Facility staff asks for the telephone number of these persons, and then calls and confirms the child's stay in the Facility with an unfamiliar adult with the knowledge and consent of the parents/legal guardians. If possible, the child should confirm that the person with whom contact was established is his or her parent or legal guardian.
• e. If verification in the manner described above is not possible, the Facility staff asks to complete a declaration, the template of which is Annex No. 5 to the Standards.
3. In the event of the lack of willingness to present the child's document or to indicate the relationship with the child, the Facility staff explains that the procedure serves to ensure the safety of children using the Facility and has been developed in compliance with legal obligations imposed on facilities providing hotel services. The primary purpose of the questions is to ensure the safety of all children staying at the Facility.
4. After a positive explanation of the matter, the guest should be thanked for the time spent making sure that the child is well cared for.
5. If the conversation does not dispel doubts regarding the suspicion of the adult and their intention to harm the child, the Facility's receptionist notifies the supervisor of these doubts in a manner that does not arouse suspicion in the adult staying at the Facility with the child. The supervisor should also notify the Facility's security service, if they are present at the Facility. These notifications are made without the guest being present. Both the child and the adult should be under constant observation by the staff until the matter is resolved.
6. The Facility's receptionist supervisor decides to notify the Police or, in case of doubt, takes over the conversation with the adult who came to the Facility with the child, in order to obtain further explanations.
7. If the conversation confirms the conviction of an attempted or committed crime to the detriment of a child, the superior notifies the police of this fact and from that moment applies the procedure for responding in the event of a reasonable suspicion of harm to a child (item IV of the Standards).
8. Staff of departments of the Facility other than reception should immediately notify the superior of noticing suspicious or unusual circumstances or behavior, in particular those listed in paragraph 12 below.
9. In the situation described in paragraph 8 above, the superior, depending on the circumstances, verifies to what extent the suspicion of harm to the child is justified and, if necessary, conducts explanatory actions or notifies the Police.
10. The Facility Staff takes special care and pays special attention to the situation of disabled children and children with special educational needs, especially when, due to the child's disability, it is impossible to obtain information confirming the data provided by an adult.
11. Identification is mandatory if an unusual or suspicious situation is identified, indicating a possible risk of harm to the child.
12. Unusual or suspicious situations include in particular (but not exclusively) the occurrence of the following circumstances:
RECEPTION
• The Guest avoids providing their personal data or the child's data; the Guest requests an anonymous check-in or openly provides incorrect data.
• The Guest gives the impression that they do not know the child's personal data, confuses them.
• If more than one adult arrives with the child - these people provide different data about the child.
• The Guest states that they do not have their own or the child's documents; does not want to provide an explanation.
• The Guest arrives with the child late, gives the impression of being in a hurry.
• During registration, the child seems restless, stressed or forced to stay in the Facility with an adult. The child avoids eye contact with the adult with whom they arrived.
• The child does not know where they are or when asked about the purpose of their travel gives inconsistent answers.
• The child gives inconsistent answers regarding their relationship with the adult or the location of their parents.
• During registration, the Guest looks around, verifies the arrangement of the monitoring cameras, and shields themselves from the camera.
• The Guest takes the child directly to the room, gives the impression that they do not want the child to make contact with the person working at the reception desk or any other person.
• The Guest staying in the Facility with the child clearly avoids other people during their stay in the Facility, avoids conversations initiated by the staff (even so-called small talk).
• The Guest staying in the Facility with the child invites other people to the room who are not guests of the Facility.
• The Guest pays in cash or by prepaid card, and the payment is made daily (e.g. because they do not know how long they will be staying at the Property) or asks someone else to pay for the accommodation.
• The Guest rents a room for a non-standard period: for hours, for part of a day or for a very long period.
• The Guest has items that can be given to children as gifts.
• The Guest who arrives with a child does not have luggage or arrives with very little luggage.
• The Guest arrives at the Property with a child with whom they have not checked in before.
• The Guest behaves towards the child in a sexually charged manner, and the relationship between the adult and the child does not seem natural and caring.
• The Guest with a child rents a room in which there are fewer beds than people checked in - e.g. a double bed for a person adult, does not ask for an extra bed.
• The child is dressed inappropriately for the weather or inappropriately for the adult with whom they arrived (e.g. there is a clear difference in the financial status of the adult and the child).
• The child arrives at the Facility late at night or at a time when they should be at school.
• Adults who are not guests of the Facility are in the lobby, seem to observe the surroundings and make contact with the guest of the Facility who arrived with the child.
RESTAURANT, BAR
• Guest is with a child with whom he/she was not registered at the Property.
• People from outside, not registered at the Property, seem to be looking for customers and offering them something.
• Guest asks the Property staff or other people about sexual services for adults, including young people.
• Teenagers are waiting for an adult who picks them up and does not appear to be their parent or guardian.
• Children who appear to be unattended, ask for food, drinks or money.
• Suspicious exchange of cash or gifts between an adult and a child.
• Child seems restless, nervous, avoids eye contact.
• Adult behaves in a sexually suggestive manner towards a child – it is not a natural and caring relationship.
• An adult gives a child alcohol or substances that may be intoxicants.
• An adult, staying alone with the child, hurriedly buys alcohol and goes to the room with it.
• During the stay, the adult and the child do not come for the ordered breakfast or use breakfast in an unjustified hurry at a time when there are the fewest guests in the room.
SWIMMING POOL / SAUNA AREA
• Despite the child's objection to this person's presence, the adult goes with the child to the changing room, toilet, sauna.
• A child entering or staying in the swimming pool area with an adult is stressed, does not seem to enjoy being there.
• The adult behaves in a sexually charged manner towards the child - this is not a natural and caring relationship.
• An adult who is not with the child spends time in a space intended for children, watches the children.
ROOM SERVICE
• A “Do Not Disturb” card (or similar) is permanently displayed on the door of the room where children are staying.
• No consent to clean the room during the guest's stay.
• A large amount of cash is seen in the room in a visible place (this does not authorize the staff to search the Guest's personal belongings).
• Children left unattended in the room for a long time or do not leave the room at all (e.g. food is brought to them).
• There are numerous computers, mobile phones, SIM cards, payment card readers, digital media (memory cards, discs, pendrives) and other similar items in the room, which may indicate illegal transactions or possession of prohibited content.
• In the room where the guest is staying with a child, there is a camera.
• The adult and the child do not leave the room often, they almost never leave or only at times when there are few guests moving around the Facility.
• The Guest staying with the child orders meals, drinks (especially alcohol) to the room, does not allow meals to be brought inside, expects the order to be left outside or picks it up with the door slightly ajar.
• There are children's clothes or toys in the room, even though the child has not been registered for stay in the Facility.
• There is a large amount of alcohol or drugs visible in the room where the adult has registered with the child or where an unregistered child is staying.
• There are condoms or items of an erotic nature, etc. in the room where the adult has registered with the child or where an unregistered child is staying.
IV. PROCEDURE FOR RESPONDING IN THE EVENT OF REASONABLE SUSPICION OF CHILD HARM
1. In the event of a justified suspicion that a child staying in the Facility is being harmed, the Police should be notified immediately by calling 112. The call is made by the person designated by the Company to coordinate compliance with the Standards, and in the event of his unavailability - the supervisor or, at his request, the employee who conducted the conversation with the guest. In the event of the supervisor's unavailability, the call is made by the employee, immediately informing the supervisor of this fact.
2. Apart from the situation referred to in point III, sec. 8 Standards, a reasonable suspicion of child abuse occurs when:
• a. the child has disclosed to the Facility employee the fact of abuse,
• b. the employee has observed the abuse,
• c. the child has traces of abuse (e.g. scratches, bruises), and when asked, answers inconsistently or chaotically, becomes embarrassed;
• d. there are other circumstances that may indicate abuse, in particular those listed in item III, paragraph 12 of the Standards,
3. In the event of a reasonable suspicion of child abuse, the child and the person suspected of harming the child should be prevented from leaving the Facility until the Police arrive.
4. In justified cases, a citizen's arrest may be made of the person suspected of harming the child. In such a situation, until the Police arrive, the person should be detained in a separate room away from the view of other guests, under the supervision of two employees.
5. In each case, the child's safety should be ensured. The child should be under the care of a verified employee of the Facility until the Police arrive.
6. In the event of a justified suspicion that a crime has been committed related to the child's contact with the perpetrator's biological material (sperm, saliva, skin), for the purpose of future determination of possible perpetration, the child should, to the extent possible, not be allowed to wash, eat or drink until the Police arrive.
7. The monitoring material and other important evidence (e.g. documents) regarding the incident should be immediately secured and issued at the request of authorized law enforcement agencies.
8. Each member of the Facility's staff who participated in the procedure described above, draws up a memo describing the course of the incident involving them. The notes are forwarded to the General Coordinator of the Facility.
V. TAKING INTO ACCOUNT THE SITUATION OF DISABLED CHILDREN
1. When assessing the possibility of harm to a child, the Facility staff takes into account the special situation of disabled children.
2. The Facility staff takes into account that due to the specific nature of the disability, certain behaviors of a child or adult may be assessed differently.
3. In particular:
• a. behaviors of a child or adult that may arouse greater vigilance in the absence of a disability will be appropriate in relation to a child with a disability, e.g. due to the child's special needs in terms of showing emotions or calming them down, the need to obtain assistance in taking care of physiological needs, the specificity of the reaction to touch;
• b. behaviors of a child or adult that are not disturbing in the absence of a disability should arouse special vigilance of the Facility staff due to the specificity of the child's disability, e.g. the child's lack of visible reaction to harm.
4. Taking into account the specificity of the disability, the Facility staff should develop an understandable form of communication with the child, adapted to the child's psychophysical abilities and enabling the child to express their will, including acceptance or objection, to certain behaviors.
VI. COMPETENCES OF THE PERSON RESPONSIBLE FOR PREPARING THE FACILITY STAFF
1. The designated coordinator ("Coordinator") is responsible for implementing the Standards in the Facility and preparing the Facility staff to apply them.
2. The Coordinator is a person appointed who has knowledge and skills that guarantee effective implementation of the Standards, and in particular a person who:
• a. has knowledge of the provisions of the Act on Counteracting Sexual Crime Threats and the Protection of Minors;
• b. knows, understands and complies with the Standards;
• c. is able to provide first aid;
• d. has soft skills that allow for an empathetic approach to children and adults;
• e. is able to identify and resolve conflicts and other crisis situations;
• f. is constantly expanding their competences by participating in training in the scope covered by the Standards;
• g. has experience in working with children, provided that such a person is in the Facility's team and meets all other requirements.
3. The Coordinator selects the appropriate form of training in the application of the Standards for the current and each new member of the Facility's staff.
4. The training may take any form, including a webinar or reading written materials.
5. The fact that the training has been conducted is recorded in a documented statement of the Coordinator, containing information on the date and method of conducting the training and data of the Facility's staff members participating in the training. The statements are kept by the Coordinator.
VII. REVIEW AND UPDATING OF STANDARDS
1. Information on the processing of personal data in connection with the implementation of the Standards in the Facility constitutes Annex No. 7 to the Standards.
2. The Standards are verified at least once every two years to ensure their adaptation to current needs and compliance with applicable regulations. The conclusions from the conducted assessment must be documented in writing. The Coordinator is responsible for the verification.
3. A shortened version of the Standards is prepared, containing information relevant to children staying in the Facility.
4. The following are attached to the Standards:
• a. Appendix No. 1 - scheme for verifying a member of the Facility's staff
• b. Appendix No. 2 - declaration of a member of the Facility's staff regarding their country of residence and no criminal record
• c. Appendix No. 3 - declaration of a member of the Facility's staff regarding familiarization with the Standards
• d. Appendix No. 4 - sample scheme for a conversation with an adult and a child during identification
• e. Appendix No. 5 - declaration of an adult regarding their relationship with a child
• f. Appendix No. 6 - information on the processing of personal data
5. The Standards have been in force at the Facility since August 15, 2024.