STANDARDS FOR THE PROTECTION OF MINORS

Introduction
The Act of 13 May 2016 on counteracting threats of sexual crime and protecting minors (Journal of Laws 2016, item 862) imposes on the hotel, as an entity providing hotel services, the obligation to implement standards for the protection of minors. Therefore:

Whenever the following are mentioned:

a) Hotel - this refers to Hotel Juvena in Międzywodzie at Leśna 4 Street.
b) Employee - this refers to a natural person employed under a contract with the operator of Hotel Juvena in Międzywodzie - Kozik Investment sp. z o.o. sp. j. based in Szczecin at Sanatoryjna 5 Street, as a result of which the natural person receives payment for performed work.
c) Personnel - this refers to hotel employees

I. Rules ensuring safe relationships between hotel personnel and minors,
and especially prohibited behaviors towards minors

1. Minors have the right to be treated by hotel personnel with equal care.
2. Hotel employees are obliged to:
   a) maintain exclusively professional relationships with minors, always considering whether the reaction, communication, or action towards the minor is appropriate to the situation, i.e., safe and justified;
   b) act openly and transparently towards minors and third parties to minimize the possibility of misinterpretation of behavior;
   c) not tolerate behavior that may constitute bullying or harassment of minors by adults.
3. The following behaviors of hotel employees towards minors are prohibited:
   a) behaviors exhibiting physical, psychological, or sexual violence, where physical violence includes behaviors that risk intentional bodily harm, such as hitting, pulling, pushing, slapping, hair pulling, choking;
   psychological violence – verbal aggression aimed at causing a sense of threat and fear;
   sexual violence – making remarks about sexual attractiveness, initiating romantic or sexual relationships;
   b) using the image of the minor for the private needs of the employee;
   c) offering minors alcohol, tobacco products, psychoactive substances; in the case of alcohol – selling alcohol and alcoholic beverages from the hotel’s offer to minors;
   d) inviting minors to hotel back-office areas and rooms;
   e) allowing minors without a legal guardian into hotel rooms and other guest-accessible areas;
   f) remaining alone in a hotel room with a minor, except in situations where leaving the minor alone in the room could threaten their well-being, health, or life.
   
   [1] Source: National Center for Counteracting Addictions. Characteristics of the phenomenon of domestic violence. https://kcpu.gov.pl/przemoc/charakterystyka-zjawiska-przemocy-w-rodzinie/

II. Rules and procedures for identifying a minor staying in the hotel facility and their relationship with the adult accompanying them

1. Identification of the minor and their relationship to the adult is carried out by the Hotel Reception employee.
2. Identification of the minor is done through:
   1) Reviewing a document allowing for establishing the minor’s identity[1];
   2) Accepting a written statement from another person whose identity was established based on identity documents[2].
3. Identification of the minor’s relationship to the adult is conducted by:
   a) Asking questions about kinship and relationship during hotel registration;
   b) Reviewing a document indicating kinship, e.g., birth certificate.
4. In case of surname discrepancies between the minor and the adult - the receptionist requires a document certifying the kinship between the adult and the minor, e.g., birth certificate, name change document, etc.
5. If the adult is not the legal guardian of the minor - the receptionist requires:
   a) a valid court decision on custody of the minor;
   b) written consent signed by the legal guardians of the minor containing: the minor’s full name and address, contact details of the legal guardian allowing direct contact at any time, personal data including at least the name, surname, PESEL number, and identity document number of the adult entrusted by the legal guardian to care for the minor. The above document should be notarized for signature authenticity. According to Article 6(1)(f) GDPR, data processing is lawful if based on the legitimate interest of the data controller – the receptionist will copy the document described in point 5.b).
6. If it is impossible to present one of the documents listed in point 5, the receptionist requires the adult to provide a phone number of the minor’s legal guardian for direct verification of the information obtained from the adult accompanying the minor. The receptionist informs the interlocutor about the processing of their personal data for purposes related to protecting the minor’s interests, who the data controller is, and where they can review the full information clause.
7. In case of refusal to cooperate in the identification of the minor and their relationship with the adult, the receptionist:
   a) first informs a superior or hotel director – depending on availability,
   b) after consultation with a superior or hotel director - informs the adult of the necessity to report the situation to the Police,
   c) informs the Police about the situation and difficulties in identifying the minor and/or their relationship with the adult. The adult and minor should remain at the hotel until the Police arrive.
   d) after the Police arrive and identify the minor and their relationship to the adult, the receptionist may continue the registration of the guests for the hotel stay.
   
   [1] Establishing identity is not the same as confirming identity. To establish the identity of a person, a document bearing a number or series, containing the person’s photo and the name of the issuing authority is sufficient.
   [2] Article 25 Identification of the person being verified. Act of 8 December 2017 on the State Protection Service (Journal 2024.325)

III. Rules and procedures for responding when there is a justified suspicion that the well-being of a minor on hotel premises is at risk

1. Every hotel employee is obliged to:
   a) pay special attention to situations that may cause concern or reasonable suspicion;
   b) remain vigilant when the relationship between the adult and the minor is not relaxed and caring, when there are signs of violence, or if the minor reports harm or requests help.
2. If there is a justified suspicion that the well-being of a minor staying at the hotel is at risk, every hotel employee is obliged to take appropriate action, in particular:
   a) immediately notify a superior about observed irregularities,
   b) in urgent cases, within the limits of applicable law – notify the Police.

IV. Procedures and persons responsible for reporting suspected crimes against minors and notifying the guardianship court

1. Every hotel employee is obliged to report any suspicion of a crime committed against a minor.
2. The report is made first and immediately to the hotel director, with notification of the supervisor. The notification to the hotel director should be oral and, at the director's request, in writing.
3. Through the hotel director - immediately - a report on the suspicion of a crime against a minor is submitted to the Police or Prosecutor's Office.
4. The person responsible for submitting notifications on behalf of the hotel is the hotel director.

V. Evaluation of standards to ensure their adaptation to current needs and compliance with applicable regulations

1. At least once every two years, the hotel will evaluate the standards to ensure they are adapted to current needs and comply with applicable regulations.
2. Conclusions from the evaluation will be documented in writing.

Międzywodzie, (update) 31 January 2025