Regulations

PROCEDURES FOR THE PROTECTION OF MINORS AT HOTEL LAVENDER***

Preamble

Considering the content of the Act of May 13, 2016 on counteracting sexual crime threats and protecting minors, particularly the resulting obligation to implement standards for the protection of minors by entities providing hotel and tourism services, to the extent necessary to ensure the protection of minors and acknowledging the important role of business in respecting children's rights, especially the right to dignity and freedom from all forms of harm, Hotel Lavender adopts this document as a model of principles and procedures in case of suspicion that a child staying in the hotel is being harmed and to prevent such threats.

We will implement the child protection policy in our hotel through these principles.

1. Hotel Lavender conducts its operational activity with the utmost respect for human rights, particularly children's rights as individuals especially vulnerable to harm.
2. Hotel Lavender recognizes its role in conducting socially responsible business and promoting desirable social attitudes.
3. Hotel Lavender particularly emphasizes the legal and social obligation to report to law enforcement authorities any suspected cases of crimes against children and commits to training its staff in this area.
4. The hotel commits to educating the staff about circumstances indicating that a child staying on the premises may be harmed, as well as methods for quick and appropriate response to such situations.
5. One of the effective forms of preventing child abuse is the identification of the child staying on the premises and his/her relationship to the adult with whom they stay. Staff undertake all possible steps to carry out identification of the child and their relationship with the adult present on the premises.

Procedure in case of suspected child abuse

1. Whenever possible, identification of the child and his/her relationship with the adult present on the premises should be made.
2. In unusual and/or suspicious situations indicating possible risk of child abuse, identification is compulsorily conducted by the reception staff.
3. To identify the child and his/her relationship to the person staying on the premises, one should:
   1. Ask for the identity of the child and the child’s relationship to the person who arrived at or stays on the premises. For this purpose, one may request the child’s identity document or another document confirming that the adult has the right to care for the child on the premises. A list of sample documents is provided in the note below. In the absence of an identity document, one may ask for the child’s details (name, surname, address, PESEL number).
   2. If there are no documents indicating a kinship between the child and the adult, ask both the adult and the child about their relationship.
   3. If the adult is not a parent or legal guardian of the child, ask whether they have a document showing parental consent for the adult to travel with the child (e.g., a written statement).
   4. If the adult does not have parental consent documents, ask for the telephone number of the parents mentioned, to call and confirm that the child is staying on the premises with an unrelated adult with the knowledge and consent of the parents/legal guardians.
4. In case of resistance from the adult regarding showing the child’s document and/or indicating the relationship, explain that the procedure aims to ensure the safety of children using the hotel and has been developed in cooperation with non-governmental organizations working in this field.
5. After the matter has been positively clarified, thank them for their time ensuring the child is in good care and once again emphasize that the procedure is aimed at ensuring children's safety.
6. If the conversation does not dispel doubts about the adult and his/her intentions to harm the child, discreetly inform the supervisor and security staff (if present on the premises at that time). To avoid suspicion, one may, for example, refer to the need to use equipment behind the reception, asking the adult to wait with the child in the lobby, restaurant, or another place.
7. From the moment the first doubts appear, both the child and the adult should be under constant observation by staff and not left alone.
8. The supervisor informed about the situation decides whether to notify the police or, in case of doubts, takes over the conversation with the suspected adult to obtain further explanations.
9. If the conversation confirms the belief about an attempt or commission of a crime against the child, the supervisor notifies the police. The procedure in case of circumstances indicating child abuse is then applied.
10. If employees of other departments [premises/hotel/hotel chain], e.g., cleaning service, room service, bar and restaurant staff, relaxation zone, security, etc., witness unusual and/or suspicious situations, they should immediately inform their supervisor, who will decide on appropriate actions.
11. Depending on the situation and location, the supervisor verifies the validity of the suspicion of child abuse. To this end, appropriate measures are taken to clarify the situation or a decision is made to intervene and notify the police.

Procedure in case of circumstances indicating child abuse

1. If there is reasonable suspicion that a child staying on the premises is being harmed, immediately notify the police by calling 112 and describing the circumstances. Depending on the dynamics of the situation and circumstances, the call is made by the direct witness of the event (employee/supervisor). If the notifier is an employee, they simultaneously inform their supervisor about the event.
2. Reasonable suspicion of child abuse exists when:
   1. a child reveals to an employee of the premises that abuse is occurring,
   2. an employee observes abuse,
   3. the child shows signs of abuse (e.g., scratches, bruises), and when asked, responds inconsistently and/or chaotically or becomes embarrassed, or other circumstances may indicate abuse, e.g., finding pornographic materials involving children in the adult’s room.
3. In this situation, prevent the child and the person suspected of child abuse from leaving the premises.
4. In justified cases, a citizen's arrest of the suspected person may be made. In such a case, until the police arrive, two employees must supervise the person in a separate room away from the sight of other guests.
5. Always ensure the child's safety. The child should remain under staff supervision until the police arrive.
6. In case of justified suspicion that a crime involved contact of the child with the perpetrator’s biological material (sperm, saliva, skin), try to prevent the child from washing or eating/drinking until the police arrive.
7. After the child is taken by the police, secure monitoring footage and other essential evidence (e.g., documents) concerning the event and provide copies to the prosecutor or police upon request by registered mail or personally.
8. After intervention, describe the event in the incident log or another document designated for this purpose.

Employment of people working with children

1. All people working with children must be safe for them, which means, among other things, that their employment history should indicate they have not harmed any child in the past.
2. Every person hired by the hotel for work related to education, recreation, and care of children must be mandatorily checked in the Register of Offenders of Sexual Crimes. The check is done by printing the search results of the person from the restricted-access register, which is then placed in the personnel file of the person checked. This check must be repeated annually.
3. All employees hired to work with children, including those who may have potential contact with children, must submit a declaration of no criminal record and no ongoing proceedings for acts against children.

Definitions

For the purposes of this document, the meaning of the following terms has been specified:

1. A child is any person under 18 years of age.
2. An unrelated adult is any person over 18 years old who is not the parent or legal guardian of the child.
3. Child abuse means committing a crime to the detriment of a child.
4. A crime against a child – all crimes that can be committed against adults may also be committed against children, and additionally crimes that can be committed exclusively against children (e.g., sexual exploitation under Article 200 of the Penal Code). Due to the nature of tourist facilities where isolation can be easily obtained, the most common crimes likely to occur on their premises are crimes against sexual freedom and decency, in particular rape (Article 197 Penal Code), sexual exploitation of incapacity and helplessness (Article 198 PC), sexual exploitation of dependence or critical condition (Article 199 PC), sexual exploitation of a person under 15 years of age (Article 200 PC), grooming (seduction of a minor via remote communication means - Article 200a PC).
5. An employee hired to work with children, who must be checked in the Register of Offenders of Sexual Crimes, is any person appointed to perform such duties, including persons employed under civil law contracts, trainees, interns, and volunteers, regardless of citizenship and age.

Final provisions

1. This policy enters into force on February 15, 2024.