1. PREAMBLE

Chochołowskie Termy spółka z ograniczoną odpowiedzialnością with its registered office in Chochołów, as the owner and administrator of the Facility under the name: Chochołowskie Thermal Baths, located at: Chochołów 400, 34-513 Chochołów, being a socially responsible enterprise, respecting human rights, in particular the rights of children, treats people who are particularly sensitive to harm as priority issues, requiring the highest level of attention and a restrictive approach, without accepting any abuse in this area.

The guiding principle of all activities undertaken by the Company and its staff is to act for the child’s well-being and best interests. Each staff member treats children with respect and takes into account their needs. Staff are committed to building and maintaining an organisational culture that prevents any actions or omissions, intentional or unintentional, that expose others to any harm. It is unacceptable for anyone to use any form of violence against a child. In pursuit of these goals, all staff operate within the framework of applicable law, internal regulations and their own competencies.

The Family and Guardianship Code amendment defined the conditions for effective protection of minors against broadly understood harm. The changes introduced became a determinant of the development of consistent standards of conduct in situations of suspected harm or harm to minors.

Taking the above into account, the Company has developed and implemented this document, i.e., Standards for the Protection of Minors applicable at the Chochołowskie Thermal Baths facility, as one of the elements of a systemic solution to protect minors against harm, constituting a form of securing their rights.

This document is a set of rules and procedures for dealing with situations where a minor’s safety is threatened, particularly in the event of suspicion that harm is being done to a child staying at the Chochołowskie Thermal Baths facility, and for preventing such threats. Its most important goal is to protect children against various forms of violence and to build a safe and friendly environment for them. The Company ensures that the main premises of this document and its intended objectives are known and understandable, as well as available to the entire Company and all persons and entities cooperating with it. The complete version and a shortened version (intended for minors, containing information important for them) of this document are available on the Company’s website at: https://www.chocholowskietermy.pl/ , as well as at the Company’s headquarters at: (34-513) Chochołów 400.

2. LEGAL BASIS

§ 1

This document was prepared on the basis of the following legal acts:

1. Convention on the Rights of the Child adopted by the United Nations General Assembly on 20 November 1989 / United Nations Guiding Principles on Business and Human Rights, recognising the important role of business in ensuring respect for the rights of children, in particular, the right to protection of their dignity and freedom from all forms of harm/;
2. Constitution of the Republic of Poland of 2 April 1997;
3. Act of 25 February 1964, Family and Guardianship Code;
4. Act of 28 July 2023 amending the Act – Family and Guardianship Code and certain other acts;
5. Act of 13 May 2016 on counteracting threats of sexual crime;
6. Act of 29 July 2005 on counteracting domestic violence;
7. Act of 6 June 1997, Penal Code;
8. Act of 6 June 1997, Criminal Procedure Code;
9. Act of 23 April 1964, Civil Code;
10. Act of 17 November 1964, Civil Procedure Code.

3. EXPLANATION OF CONCEPTS

§ 2

The following definitions are used in this document, which each time mean:

1. Administrator or Company – Chochołowskie Termy spółka z ograniczoną odpowiedzialnością with its registered office in Chochołów (34-513) Chochołów 400, entered into the register of entrepreneurs of the National Court Register kept by the District Court for Kraków – Śródmieście in Kraków, 12th Commercial Division of the National Court Register under the KRS number: 0000261672, REGON: 120300433, NIP: 7361640322;
2. Chochołowskie Thermal Baths, Complex, Facility or Thermal Baths – a facility under the name: Chochołowskie Thermal Baths, located at the address: Chochołów 400, 34-513 Chochołów, owned and administered by Chochołowskie Termy spółka z ograniczoną odpowiedzialnością with its registered office in Chochołów, consisting of, among others, parking lots, entrance halls, ticket offices, cloakrooms/changing rooms and showers, swimming pool and water zone (including indoor and outdoor pools, slide complex, water playgrounds, therapeutic area, silence and relaxation area), SPA zone ( Chochołowska SPA), sauna zone (Chochołowska Saunarium), normobaric chambers (Chochołowska Normobaria), sports zone, including a gym (Chochołowska Sports Centre), restaurant complex and service zone;
3. child’s data – any information enabling the identification of the child;
4. child/minor – any person up to 18 years of age;
5. Facility Management – persons managing the Facility on behalf of its administrator, i.e., Spółka Chochołowskie Termy spółka z ograniczoną odpowiedzialnością with its registered office in Chochołów, in particular, Members of the Management Board;
6. harm – committing a prohibited or punishable act to the detriment of a child by any person, including a member of the Staff, or endangering the child’s well-being, including neglect; is any intentional or unintentional act/omission of an individual, institution or society as a whole and any result of such action or inaction that violates the equal rights and freedoms of children and/or interferes with their optimal development; There are 5 basic forms of abuse:
   • Physical violence against a child is violence as a result of which the child suffers actual physical harm or is potentially at risk of physical harm. This abuse occurs as a result of an action or omission on the part of a parent or other person responsible for the child or whom the child trusts or who has authority over the child. Physical violence against a child may be a repeated or one-off activity.
   • Emotional (mental) violence against a child is a chronic, non-physical, harmful interaction between a child and an adult, including both actions and omissions. This includes, among others, emotional unavailability, emotional neglect, a relationship with the child based on hostility, blaming, denigration, rejection, developmentally inappropriate or inconsistent interactions with the child, failure to notice or recognise the child’s individuality and mental boundaries between the adult and the child.
   • Neglect is when no one makes a child feel important, special or loved, cares for him or her, or supports him or her. The child’s guardian is not interested in the child’s health, nutrition or living conditions. Neglect is the failure to meet a child’s basic needs and/or failure to respect his or her basic rights by parents, guardians or other persons responsible for the child’s care, upbringing and protection. It includes both individual situations and a persistent way of functioning in which the caregiver does not provide appropriate conditions for the child’s physical, cognitive, social, emotional and psychosexual development and well-being.
   • Sexual violence (sexual abuse of a child) is the involvement of a child by an adult/or another child in sexual activity without physical contact (e.g., exhibitionism, all forms of verbal harassment, e.g. talking about sexual content inappropriate to the child’s age or commenting in a sexual way on the appearance and child’s behaviour, sexualisation of play and image, encouraging contact with pornographic content, grooming – seduction on the Internet in order to establish contact) or with physical contact such as touching, forcing the child to touch the perpetrator’s body in a sexual way or sexual intercourse. Any sexual activity undertaken with a child under the age of 15 is a crime. Sexual abuse occurs when such activity occurs between a child and an adult or a child and another child if these people, due to their age or level of development, remain in a relationship of care, dependence, and power. Sexual exploitation may also take the form of sexual exploitation, which is any actual or attempted abuse of a position of vulnerability, power or trust for sexual purposes, including, but not limited to, profiting financially, socially or politically from the sexual exploitation of another person. There is a particular risk of sexual exploitation during humanitarian crises. The threat of exploitation exists both for children and their caregivers.
   • Peer violence (peer aggression, bullying) occurs when a child experiences various forms of violence from peers, directly or using communication technologies (Internet and mobile phones). It occurs when the action is intended to cause discomfort or harm to someone (intentionality), is systematic (repeatability), and the victim is weaker than the perpetrator or group of perpetrators. It includes verbal violence (e.g. name-calling, teasing, ridiculing), relational violence (e.g. exclusion from a group, ignoring, turning others against a person), physical violence (e.g. beating, kicking, pushing, pulling), material violence (e.g. stealing, destroying objects) and electronic (malicious SMS or e-mail, entry on a social networking site, posting photos or videos on the Internet ridiculing the victim), as well as violence during a date by a boyfriend/girlfriend, sexual abuse – touching intimate parts of the body or forcing sexual intercourse or other sexual activities by a peer, violence conditioned by gender norms and stereotypes.

7. Foreign adult – any person over the age of 18 who is not the child’s parent or legal guardian;
8. Service or Staff (or employees) – a team of people involved in the management and operation of the Facility, including in particular employees and collaborators (lifeguards, cashiers, Customer Service Office employees, SPA employees/therapists, sauna masters, catering staff, security staff, service staff cleaners, etc.), management, managers (managers), etc., regardless of the form of employment, including volunteers, interns, people assigned to internships;
9. Child guardian – a person authorised to represent the child, in particular, its parent or legal guardian; according to this document, the foster parent is also a guardian;
10. person responsible for Internet safety – a member of the Staff appointed by the Facility Management, supervising the use of the Internet by children on the Facility and children’s safety on the Internet;
11. person responsible for the Child Protection Policy – a staff member appointed by the Facility Management to supervise the implementation of the Policy, its proper application and updating;
12. person responsible for child protection – a member of the Staff appointed by the Facility Management responsible for receiving reports about threats to the child’s well-being and intervening before the competent authorities or institutions;
13. person responsible for providing support to the child – person responsible for developing a child support plan and monitoring it;
14. employee employed to work with children – any person employed to perform this type of duties, including a person employed under a civil law contract, an apprentice, an intern and a volunteer, regardless of the citizenship and age of this person;
15. violence – any single or repeated, intentional act or omission, taking advantage of physical, mental or economic advantage, violating the rights or personal rights of a child, in particular exposing him or her to the risk of loss of life or health, violating his or her dignity, bodily inviolability, freedom – in including sexual, causing damage to his or her physical or mental health, as well as causing suffering and harm;
16. Standards for the Protection of Minors/Child Protection Policy (with the indication that the words Minor and Child may be used interchangeably in these names) – the content of this document;
17. consent of the child’s parent – consent of at least one of the child’s parents/legal guardians; if there is no agreement between the child’s parents, the parents should be informed about the need for the case to be resolved by a family court.

4. GENERAL PROVISIONS

§ 3

The main principles that guide the Company in implementing this document are as follows:

1. The Chochołowskie Thermal Baths facility treats the well-being of children as a primary value and, when conducting activities related to recreation, sports and developing the interests of minors, they always respect their rights, observing the principle that harming minors, in particular using violence against them in any form, is unacceptable, and any child should always be treated with respect due to him or her and his or her dignity;
2. The Chochołowskie Thermal Baths facility fully recognises its role in running a socially responsible business and promoting desirable social attitudes, in particular, they are aware of the importance of the legal and social obligation to notify law enforcement authorities of each case of suspicion of committing a crime to the detriment of children;
3. The Chochołowskie Thermal Baths facility considers it particularly important to educate its Staff on the principles of proper behaviour towards children, including appropriate response in the event of circumstances indicating child abuse/suspected child abuse;
4. The Chochołowskie Thermal Baths facility applies the principles of safe recruitment in accordance with the requirements arising from legal provisions, in particular by checking the criminal records of persons who will have contact with minors as part of their official duties in the relevant registers.

5. RECOGNISING AND RESPONDING TO CHILD ABUSE RISK FACTORS

§ 4

1. When it comes to preventing child abuse, it is crucial to pay attention to the risk factors for child abuse.
2. Factors of child abuse should be understood as factors that may co-occur or precede violence against a child. Skilful recognition and response to risk factors help reduce the risk of violence against children.
3. The Facility’s staff knows and, as part of their duties, pays attention to risk factors and symptoms of child abuse.
4. If risk factors are identified, the Staff starts a conversation with carers, providing information about the available support and motivating them to seek help.
5. Staff monitor the child’s situation and well-being.
6. Staff members receive child protection training appropriate to their role within the Chochołowskie Thermal Baths structure and job duties and relating to their responsibility for children

§ 5

1. Each newly admitted staff member is familiarised with the provisions of the Child Protection Policy (applicable rules and procedures) and, if necessary, receives additional training regarding the rules contained in the Policy.
2. When the Policy is updated, Staff members are informed about the changes introduced and, if necessary, additionally trained.
3. The duties of the person responsible for the Child Protection Policy include:
   • ensuring that the Child Protection Policy is made available on the Company’s website and its premises;
   • preparing Staff to apply the Child Protection Policy before starting work or after making changes to this Policy;
   • delegating tasks and responsibilities related to the implementation of the Child Protection Policy in the Company to appropriate units and monitoring their implementation;
   • supervising the keeping of records of Staff members who are familiar with the Child Protection Policy before starting work or after making changes to it;
   • reviewing the Child Protection Policy in consultation and cooperation with Management, Staff and, where deemed appropriate, with children and, where possible, their parents/guardians; including analysis of recommendations provided by people responsible for Internet safety, child protection and child support;
   • monitoring whether there are difficulties in applying the Policy;
   • coordinating work related to updating the Policy;
   • developing training schedules and the scope of educational activities.
4. The person responsible for Internet security is responsible for ensuring:
   • developing rules for safe use of the Internet on the premises of the Facility;
   • availability of developed rules for staff, children, guardians and event participants;
   • safe conditions for using the Internet on computers located in the Facility;
   • installation and regular updating, at least once a month, of software that blocks access to content that is harmful and inappropriate for children’s age;
   • checking, at least once a month, whether there is content on computers with free access to the Internet that is harmful and inappropriate for the age of children (if applicable);
   • monitoring cases of cyberbullying occurring in the Facility and providing recommendations to increase Internet safety to the person responsible for updating the Child Protection Policy.
5. The person responsible for the protection of the child is responsible for, as appropriate to the situation:
   • accepting a report of a risk factor posing a threat to the child’s well-being;
   • accepting a report revealing symptoms of child abuse or child abuse; disclosed or reported incidents or events that threaten the well-being of the child, documenting them, verifying them and informing the Management about the results of the findings;
   • receiving a report of suspicion or inappropriate disclosure, dissemination or use of a child’s image or any problems revealed in this regard;
   • initiating an intervention;
   • informing the appropriate social welfare centre about the need to initiate the “Blue Card” procedure;
   • notification of the guardianship court;
   • submitting a report on suspicion of committing a crime to the detriment of a minor;
   • keeping records of events and interventions, securing documentation;
   • forwarding recommendations increasing children’s safety to the person responsible for updating the Child Protection Policy.
6. The person responsible for providing support to the child is to:
   • develop a plan to help the child;
   • cooperate with specialists providing support;
   • monitor the support provided to the child;
   • forward recommendations increasing children’s safety to the person responsible for updating the Child Protection Policy.

7. Depending on the nature of the business, the size and structure of the Staff in the Company, the above responsibilities (resulting from the role of the person responsible for the Child Protection Policy, the person responsible for Internet safety, the person responsible for child protection, the person responsible for providing support to the child) may be performed by one person. (Safeguarding Officer) or several persons designated by the Management must be indicated by name and surname.
8. If one person is selected for all of the above tasks, during his or her absence, the functions performed by that person will be temporarily taken over by another designated and appropriately instructed the Staff member.

6. INTERVENTION PROCEDURES IN CASE OF SUSPECTED CHILD ABUSE – rules applicable in the event of a short-term stay of children in the Complex as part of the regular use of the Company’s services

§ 6
Procedure in case of suspected child abuse

1. Due to the specificity of the Chochołowskie Thermal Baths facility, one of the basic forms of effective prevention of child abuse is the identification of the child staying in the Facility and his or her relationship with the adult with whom he or she is staying.
2. The staff takes all possible steps to identify the child and his or her relationship with the adult with whom he or she is at the Facility.
3. The child and his or her relationship with the adult with whom he or she is staying at the Facility should be identified whenever possible.
4. Staff must obligatorily carry out identification in unusual and/or suspicious situations indicating a possible risk of harm to the child. Examples of situations that may raise suspicions are provided in Annex No. 1.
5. To identify the child and his or her relationship with the adult with whom he or she is staying at the Facility, you should:
   • ask for the child’s identity document (ID card) or another document confirming the child’s data; Examples of other documents that can be used for identification include: school ID, MObywatel application, Internet Patient Account;
   • in the absence of an identity document or if it is refused or impossible to present it, ask both the adult and the child to provide the child’s data (e.g. name, surname, address, date of birth); Additionally, you should ask both the adult and the child about the relationship between them; an example diagram of a conversation with an adult and a child can be found in Annex No. 2;
   • if the adult is not the child’s guardian, he or she should be asked to present an appropriate document proving the parents’ consent for the adult to travel together with the child (e.g. a written declaration);
   • if an adult does not have a parental consent document, please ask for the telephone number of the above-mentioned people to call and confirm that the child is staying at the Facility with a foreign adult with the knowledge and consent of the parents/legal guardians;
   • if the adult in whose company the child is staying refuses to document the child and/or indicate the relationship between them, it should be explained that the procedure is intended to ensure the safety of children using the Chochołowskie Thermal Baths and that in accordance with the provisions of the Act of 13 May 2016 on counteracting threats of sexual crime, the Facility Staff is obliged to determine whether the child is safe;
   • once the matter has been clarified positively, thank them for taking the time to make sure the child is well cared for and emphasise once again that the procedure is intended to ensure children’s safety;
   • if the conversation does not dispel doubts about the adult accompanying the child and his or her intentions towards the child, and especially when he or she refuses to show an identity document or submit a statement containing the child’s data, the superior and security staff should be discreetly notified in such a way that no suspicion is aroused (e.g. you can invoke the need to use the equipment at the reception desk by asking an adult to wait with the child in the lobby, restaurant or other place);
   • from the moment the first doubts appear, both the child and the adult should be under constant observation of the Staff and not be left alone;
   • the superior who has been notified about the situation, in consultation with the Management or in the absence of the Management himself, decides to notify the police or, in case of doubt, takes over the conversation with an adult to obtain further explanations;
   • if the interview confirms the belief that there has been an attempt or commission of an act to the detriment of the child, the superior, in consultation with the Management or in the absence of the Management himself or herself, notifies the police of this fact; the procedure continues to apply as in the case of circumstances indicating harm to the child (§ 7);
   • In any case, when Staff members witness unusual and/or suspicious situations involving a child, including employees such as cleaning service, bar and restaurant workers, relaxation zone workers, security staff, etc., they should immediately notify their superior and, in the event of his or her absence – a decision-maker who will decide on taking appropriate actions; depending on the situation and place, the superior verifies to what extent the suspicion of child abuse is justified – for this purpose, he or she selects appropriate measures to clarify the situation or decides to carry out an intervention and, in consultation with the Management or in the absence of the Management, notifies the police on his or her own.

§ 7

Procedure in the event of disclosure of circumstances indicating child abuse

1. Disclosure of abuse may occur in the following ways:
   • the child disclosed the fact of abuse to the Facility Staff;
   • a member of staff observed abuse;
   • the child shows signs of abuse (e.g. scratches, bruises), and when asked, answers inconsistently and/or chaotically and/or becomes embarrassed, or other circumstances may indicate abuse.
2. A Staff Member who has reasonable suspicion that a child staying at the Facility is or has been abused should immediately notify the supervisor/decision-maker who assesses the situation and, if necessary, in consultation with the Management or in the absence of the Management themselves, notifies the police.
3. In the event of a direct threat to the child’s safety, a member of staff who has reasonable suspicion that the child has been abused shall immediately notify the police by calling 112 and describing the circumstances of the incident. Notwithstanding the above-mentioned notifies the immediate superior of the incident, who then contacts the Management.
4. Efforts should be made to make it difficult or even impossible for the child or the person suspected of child abuse to leave the Facility.
5. In the case specified in Art. 243 of the Criminal Procedure Code, a citizen arrest of a suspected person may be made. In such a situation, until the police arrive, the detained person remains under the supervision of security staff in a separate room away from the view of other guests/customers. Detention should respect the dignity of the detained person, if possible, without children’s participation.
6. In all cases, you must ensure your child’s safety. If possible, the child should remain under the care of a designated staff member until the police arrive. Where possible, you should try to support your child.
7. In the event of a justified suspicion that a crime has been committed resulting in the child’s contact with the perpetrator’s biological material (sperm, saliva, epidermis), the child should, if possible, not be allowed to wash or eat/drink until the police arrive. You should calmly and respectfully explain to your child why such restrictions have been placed on him or her.
8. After the police take over the child, the monitoring material and other relevant evidence (e.g. documents) regarding the incident should be secured and handed over to the Management, which, at the request of the services, will forward a copy of it by registered mail or in person to the prosecutor or the police.
9. After the intervention, the incident should be reported to the person responsible for the Child Protection Policy, who will then describe it in an event log or other document intended for this purpose.

§ 8

Procedure in the event of suspicion or discovery of child abuse by an employee/other adult

1. In the event of suspicion of child abuse by an employee or another adult who is not directly employed by the Company but by a third party, the person who received this information should immediately inform the direct superior, who should then contact the Management. Appropriate measures will be selected and implemented to clarify the situation and, if necessary, appropriate intervention will be carried out.
2. If the life or health of a child is in immediate danger, the person who became aware of this should immediately notify the police by calling the emergency number 112, providing their own data, the child’s data (if possible), the child’s place of residence and a description of the circumstances of the case and notify the superior/decision maker, and the superior/decision-maker then contacts the Management, which notifies the child’s guardians/parents. The person who learned about the incident also informs the person responsible for the Child Protection Policy in e-mail/written form.
3. If an employee has committed a form of abuse to a child other than committing a crime to its detriment, the person responsible for the Child Protection Policy, after receiving information, should investigate all the circumstances of the case, in particular by listening to the employee suspected of abusing him or her and other witnesses of the incident. In a situation where the violation of the child’s best interests is significant, particularly when discrimination or violation of the child’s dignity has occurred, the person responsible for the Child Protection Policy should recommend to the Management appropriate personnel actions in relation to this employee.
4. If the person who committed abuse is not directly employed by the Company but by a third party (e.g. outsourcing), then it should be recommended that he or she be banned from entering the Facility and, if necessary, terminate the contract with the third party.

§ 9

Procedure in the event of other forms of violence against a child being found by a parent/guardian/other adult

1. If it is discovered that a child is being harmed by a parent/guardian or another adult with whom the child is staying on the premises of the Facility, any Staff member who witnesses such harm should react firmly to it.
2. If the life or health of a child is in immediate danger, the person who became aware of this should immediately notify the police by calling the emergency number 112, providing their own data, the child’s data (if possible), the child’s place of residence and a description of the circumstances of the case and notify the superior/decision-maker and the superior/decision-maker contacts the Management in turn. The person who learned about the incident also informs the person responsible for the Child Protection Policy in e-mail/written form.
3. If an employee of the Facility witnesses physical violence committed against a child (spanking, pulling, screaming, others listed in the definition of physical violence), he or she should try to stop the abuse and react. Possible forms and ways of responding to the harmful behaviour of a parent/guardian/other adult towards a child are included in Annex No. 3.
4. If a child under 7 years of age is left unattended, the employee who becomes aware of such an incident should notify his or her superior. The superior who has been notified about the situation decides to take further action in the context of the provisions of the Penal Code and the Code of Petty Offences. Depending on this context, the supervisor attempts to find the parent/legal guardian or other adult with whom the child is staying at the Facility and explains that he or she cannot leave the child unattended. In a situation where it is not possible to find the parent/legal guardian or another adult with whom the child is staying at the Facility or the parent/legal guardian/other adult is unwilling and/or unable to take over the care of the child, the supervisor, in consultation with the Management, or in the event of the Management’s absence, informs the police on its own. In all cases, you must ensure your child’s safety.

7. INTERVENTION PROCEDURES IN CASE OF SUSPECTED CHILD ABUSE – rules applicable to children participating in classes and events conducted by the Company’s Staff at the Complex /classes at the Chochołowskie Sports Centre, swimming lessons, competitions and events, etc./, related to repeated contact with given children

§ 10

1. Intervention procedures are designed to support Staff members in fulfilling their legal and social obligation to respond in the event of suspected child abuse. Due to the ability to observe the child in situations showing the effects of abuse, sports staff play an important role in the process of recognising it in a child.
2. The aim of the intervention is to stop child abuse and ensure his or her safety.
3. Threats to children’s safety may take many forms, using various methods of contact and communication.
4. For the purposes of this document, the following classification of threats to children’s safety was adopted:
   • crime against a child (e.g. sexual abuse, child abuse);
   • another form of harm that is not a publicly prosecuted crime, such as shouting, physical punishment, humiliation;
   • neglect of the child’s vital needs (e.g. related to nutrition, hygiene or health).
5. For the purposes of this document, intervention procedures have been distinguished in the event of suspected action to the detriment of a child by:
   • adults (Staff, other third parties, parents/legal guardians);
   • another child.

§ 11

Procedure in case of suspected child abuse

1. If a Staff member suspects that a child is being harmed, or if such a circumstance is reported by the child or the child’s guardian, the Staff member is obliged to prepare an official note and forward the information obtained to the Company’s Management. The note may be in writing or by e-mail.
2. The intervention is carried out by the Company’s Management, which may permanently appoint another person to this task. If such a person is appointed, his or her details (name, surname, e-mail, telephone number) will be made known to the Staff, children and guardians.
3. If another person is appointed to conduct the intervention, the term “Company Management” should be understood as the person responsible for conducting the intervention.
4. If abuse is reported by the person designated to conduct the intervention, the intervention is carried out by the Company’s Management.
5. If abuse is reported by the Company’s Management and no person has been designated to intervene, then the actions described in this chapter are taken by the person who noticed the abuse or to whom the suspected abuse was reported.
6. Specialists, especially psychologists and educators, can be invited to participate in the intervention in order to use their help in talking to the child about difficult experiences.
7. The Company’s management informs guardians about the obligation to report suspected child abuse to the appropriate institution (prosecutor’s office/police or family and guardianship court or the nearest social welfare centre). This obligation is waived if informing the child’s guardian is contrary to the child’s best interests or is impossible.
8. After informing the guardians in accordance with the preceding paragraph, the Company’s Management submits a notification of suspicion of a crime to the prosecutor’s office/police or an application for insight into the family’s situation to the appropriate district court, family and juvenile department, or a letter to investigate the child’s situation to a social welfare centre.
9. The further course of proceedings falls within the competence of the institutions indicated in the preceding paragraph.
10. An intervention card is prepared for each intervention, the template of which is attached as Annex No. 4 to this Policy. The card is attached to the intervention register kept by the Company /designated person responsible for child protection/.
11. All persons who, in connection with the performance of their official duties, received information about child abuse or information related to it, are obliged to maintain confidentiality, except for information provided to authorised institutions as part of intervention activities.
12. If the suspicion of a threat to the child’s safety has been reported by the child’s guardians and this suspicion has not been confirmed, the child’s guardians should be informed of this fact in writing.
13. Depending on the needs, a team may be established to develop methods of supporting an abused child, consisting of specialists and Company Staff.

§ 12

If there is a suspicion that the child’s life is in immediate danger or there is a risk of serious damage to health, the staff member who first learned about the threat informs the immediate superior, who, in consultation with the Management or in the absence of the Management, independently notifies the appropriate services (police, ambulance) by calling 112.

§ 13

Harm by an adult

1. If child abuse is reported, the Company’s Management conducts a conversation with the child and other people who have or may have knowledge about the incident and the personal situation (family, health) of the child, in particular its guardians. Management tries to determine the course of the incident but also the impact of the event on the child’s mental and physical health. The arrangements are written down on an intervention card.
2. The Company’s management organises a meeting with the child’s guardians (unless the guardian is the perpetrator), to whom they provide information about the incident and the need/possibility of using specialist support, including from other entities or services.
3. If a crime has been committed against a child, the Company’s Management prepares a notification about the possibility of committing a crime and forwards it to the local police or prosecutor’s office.
4. If the conversation with the guardians shows that they are not interested in helping the child, ignore the incident or do not otherwise support the child who has experienced abuse, the Company’s Management prepares an application for insight into the family’s situation, which it submits to the appropriate family court.
5. If the findings show that the child’s guardian neglects the child’s psychophysical needs or the family is educationally ineffective (e.g. the child wears clothes that are inappropriate for the weather, leaves the place of residence without adult supervision), the family uses violence against the child (parent/other household member shouts at the child, uses spankings or similar physical punishment), the appropriate social welfare centre should be informed about the need for help for the family when the failure to meet the needs results from poverty or – in the case of violence and neglect – the need to initiate the “Blue Card” procedure arises.
6. If child abuse is reported by a member of the Company’s Staff, that person is removed from all forms of contact with children (not only the aggrieved child) until the matter is resolved.
7. If a member of the Company’s Staff has committed any form of harm to a child other than committing an offence prosecuted to the detriment of the child, the Company’s Management should investigate all the circumstances of the case, in particular, listen to the person suspected of harming the child, the child and other witnesses of the event. In a situation where the violation of the child’s best interests is significant, in particular when discrimination or violation of the child’s dignity has occurred, termination of the legal relationship with the person who committed harm should be considered or such a solution should be recommended to the person’s superiors. If the person who committed harm is not directly employed by the Company, but by a third party or is a volunteer, then it should be recommended that this person be banned from entering the Facility and, if necessary, terminate the contract with the cooperating institution.
8. All persons who, in connection with the performance of their official duties, receive information about child abuse or information related to it, are obliged to keep this information secret, except for information provided to authorised institutions as part of intervention activities.

§ 14

Peer bullying

1. If a child is suspected of being abused by another child staying at the Facility (e.g. during training sessions, or sporting events), a conversation should be held with the child suspected of abuse and his or her guardians, as well as separately with the child subjected to abuse and his or her guardians. Additionally, you should talk to other people who know about the incident. During the conversations, efforts should be made to determine the course of the event, as well as the impact of the event on the mental and physical health of the abused child. The arrangements are written down on an intervention card. Separate intervention cards are prepared for the abusive and abused child.
2. Together with the guardians of the abusive child, a recovery plan should be developed to change undesirable behaviour.
3. A plan should be developed with the caregivers of an abused child to ensure the child’s safety, including ways to isolate the child from sources of danger.
4. During conversations, make sure that a child suspected of harming another child is not being harmed by caregivers, other adults or other children. If such a circumstance is confirmed, intervention should also be undertaken with respect to this child.
5. If the abusing child does not participate in the entity’s activities, you should talk to the child subjected to abuse, other people who know about the incident, as well as the guardians of the abused child in order to determine the course of the event, as well as the impact of the event on the child’s mental and physical health. The Facility’s management organises a meeting with the child’s guardians, providing them with information about the incident and the need/possibility of using specialist support, including from other entities or services, and about how to respond to the event (informing the family court, informing the school, informing the guardians of the abusive child).
6. If the person suspected of abuse is a child aged 10 to 17 and his or her behaviour constitutes a punishable act, the locally competent family court or the police should also be informed in writing.
7. If the person suspected of harming is a child over 17 years of age and his or her behaviour constitutes a crime, then the appropriate local police or prosecutor’s office unit should be informed in writing.

§ 15

Procedure in the event of disclosure of illegal, harmful or age-inappropriate content or in the event of incidents affecting the safety of children related to the use of the Internet

In the event of reporting/disclosing illegal, harmful or age-inappropriate content, or in the event of events affecting the safety of children related to the use of the Internet, you should:

1. notify the parents/guardians of the injured child and the child sharing the content;
2. register, analyse and properly document the event;
3. notify the police/family court if you suspect a prohibited act has been committed;
4. provide safety and support to the abused child.

§ 16

Support plan

1. A support plan should be developed for a child subjected to abuse. This applies to situations of abuse by adults (Staff, other third parties, parents/legal guardians) and another child. The plan should include instructions regarding the Company’s actions to ensure the child’s safety, including:
   • ways to isolate it from sources of danger;
   • the support the Company will offer to the child;
   • referring the child to a specialist child welfare facility, if necessary.

2. A support plan should be developed with the child’s caregivers and discussed with the child. If the caregiver is a child abuser, then the plan should be developed in consultation with the non-abusive parent.
3. When creating a support plan, the Company’s capabilities and resources should be used and other specialised entities should be involved, such as: local social welfare centres, crisis intervention centres, psychological and pedagogical counselling centres, specialised family counselling centres, early intervention centres, day support centres, community mental health centres for adults and community mental health centres for children and adolescents, children’s assistance centres (centrapomocydzieciom.fdds.pl), national and local non-governmental organisations supporting parents and children. As a supplement to the activities, you can provide your child with the helpline number 116 111. Adults can use the Telephone for Parents and Teachers regarding Child Safety 800 100 100.

8. FACILITY STAFF – DETAILED REGULATIONS

§ 17

1. The Company educates its Staff in order to equip them with the ability to recognise the signs/symptoms of child abuse and the ability to quickly and appropriately respond to situations of abuse.
2. The Company may implement the above-mentioned education through various forms, e.g., external and internal training, e-learning, educational materials developed by the Company and available to Staff, and educational materials available free of charge, developed by other organisations.
3. Before being allowed to work/perform official tasks, each Staff member reads the Child Protection Standards, which is confirmed by submitting a declaration of completion of this activity. At the same time, it undertakes to comply with the principles and procedures contained in the Standards. The above-mentioned pattern declaration is attached as Annex No. 5 to this Policy.
4. The declaration is included in the employee’s personal files and, failing that, it is attached to the civil law contract.
5. Lack of consent to sign the documents mentioned in section 3 above makes it impossible to establish any legal relationship with this person (concluding an employment/cooperation contract).

§ 18

Employing people to work with children – rules of staff recruitment

1. All people working with children must be safe for them, which means, among other things, that their employment history should indicate that they have not harmed any child in the past.
2. Before employing a person or establishing cooperation in another form and entrusting him or her with the duties of working with a child, his or her qualifications and competencies to work with a child should be determined, as well as the risk of a threat to the child’s well-being and safety should be excluded.
3. Before employing or assigning a person to work with children, it is determined whether he or she has committed child abuse in the past. The arrangements are made in accordance with Art. 21 of the Act of 13 May 2016 on counteracting threats of sexual crime and protection of minors and are carried out in relation to each person employed by the Company for work related to education, recreation and child care.

§ 19

Principles of safe employee-child relationships

1. All employees of the Chochołowskie Thermal Baths facility (all Staff), as well as other adults who have contact with children on the premises of the Facility, if this contact takes place with the consent of the Company, are obliged to maintain a professional relationship with children and each time consider whether a given reaction, the message or action towards the child is adequate to the situation, safe, justified and fair. You should act openly and transparently to others to minimise the risk of misinterpreting your behaviour.
2. The guiding principle of all activities undertaken by employees who have contact with children in the Thermal Baths is to treat the child with respect and consider his or her dignity and needs. When communicating with a child, you should be patient and respectful, listen carefully to the child and provide him or her with answers appropriate to his or her age and the situation.
3. All children should be treated equally, regardless of any characteristics, including their gender, sexual orientation, ability/disability, social, ethnic, cultural, religious status, worldview, etc.
4. It is unacceptable for employees and other adults to use any form of violence against a child.
5. You must not embarrass, humiliate, disrespect or insult a child. You must not shout at a child in a situation other than for the safety of the child or other children. You must not hit, poke, push or in any way violate the physical integrity of the child unless there is a threat to the child’s health or life.
6. An employee must not take advantage of a physical advantage or use threats against children.
7. An employee is not allowed to joke inappropriately, use profanity, make offensive gestures or express sexual content in the presence of children.
8. The employee should not engage in games such as tickling, pretend fighting, brutal physical play, etc.
9. The employee may not record images of children for private purposes. Image recording in other situations and for other purposes is regulated by separate regulations.
10. You must not disclose sensitive information about a child to unauthorised persons, including other children. This includes the child’s image, information about his or her family, economic, medical, guardianship and legal situation.
11. It is strictly forbidden to enter into any romantic or sexual relationship with a child or to make inappropriate proposals to the child. This also includes sexually explicit comments, jokes, gestures and sharing erotic and pornographic content with children regardless of its form. You must not contact the child through private communication channels (private telephone, e-mail, instant messaging, social media profiles) or meet the child outside the workplace.
12. Contact with children should occur only during working hours and for purposes falling within the scope of the Staff’s responsibilities.
13. It is strictly prohibited to offer children alcohol, tobacco products or other stimulants or illegal substances.
14. All the behaviours described above are prohibited under the penalty provided for in the provisions of the Penal Code, as well as loss of job.
15. Staff are obliged to assure children that if they feel uncomfortable in a certain situation, behaviour or words, they can tell the staff about it and they can expect an appropriate response and/or help. The child should be informed about the location of the Child Protection Standards in the Facility in a version he or she understands and assured that if the child has any questions, he or she can contact a designated person from the Company’s Staff.
16. If an employee notices disturbing behaviour or situations, in particular when witnessing any of the above-described behaviours and/or situations on the part of other adults or children, he or she is obliged to follow the instructions contained in these standards of conduct.
17. The detailed rules for safe Staff-child relationships are set out in Annex No. 6.

§ 20

Principles of safe relationships in other configurations

1. The Company has also implemented the principles of safe child-to-child relationships, constituting Annex No. 7, and parent-child and parent-trainer relationships, constituting Annex No. 8.
2. The rules set out in section 1 above are known to the Staff.

9. RULES FOR THE PROTECTION OF CHILDREN’S PERSONAL DATA AND IMAGE

§ 21

1. The Company ensures the highest standards of protection of children’s personal data in accordance with applicable law and the Company’s Personal Data Protection Policy.
2. Guidelines on the protection of the child’s image containing detailed rules for registering and making public the child’s image for business and private purposes and the rules for storing materials containing the child’s image constitute Annex No. 9 to the Policy.
3. The Company, recognising the child’s right to privacy and protection of personal rights, ensures the protection of the child’s image, guided by responsibility and prudence towards the recording, processing, use and publication of children’s images.
4. The recording, processing, use and publication of a child’s image in a photo, recording or on any medium must be done sensibly and carefully. Activities of this type are permitted only for the purpose of celebrating the child’s success, documenting the activities or operation of the Facility and events organised at the Facility (for example, tournaments, competitions, games, training and other events), while maintaining children’s safety.
5. The photos or recordings referred to in section 4, are implemented without discrimination due to any characteristics.
6. In each case, the best interests and dignity of the child should be taken into account. Material containing the image of a child cannot be derogatory or insulting, show situations that seem ridiculous or inappropriate without context, show transgressions of the intimate zone and nudity or perpetuate stereotypes. In order to protect the child against activities that violate his or her well-being during registration:
   • the child must be dressed, and the situation recorded in the photo/recording cannot be degrading, ridiculing or present in a negative context for the child;
   • photos/recordings of the child should focus on the child’s activities and, if possible, show the child in a group, not alone.
7. It is prohibited to disclose any information regarding the child during registration, including his or her health condition, financial situation, legal situation and information related to the child’s image.
8. All suspicions and problems regarding the inappropriate recording and dissemination of images of children should be registered and reported to the Company’s Management and the Data Protection Inspector appointed by the Company.

10. RULES FOR CHILDREN’S ACCESS TO THE INTERNET

§ 22

1. When providing children with access to the Internet, an entity is obliged to take measures to protect children from access to content that may threaten their proper development.
2. The risks associated with children’s use of the Internet and electronic media include:
   • access to illegal content, including child sexual abuse material; materials depicting hard pornography, content promoting racism and xenophobia, other illegal content directed against children’s safety, for example: promoting or praising pedophilic behaviour, materials recording the image of a naked person or a person engaged in sexual activity using violence, unlawful threats or deceit or distributed without her consent, pornographic content made available to a minor, seduction of a child under 15 years of age. via the Internet, the so-called child grooming, the phenomenon of sexual blackmail (also referred to as “sextortion”);
   • access to harmful and inappropriate content, including: content depicting violence, physical injuries, drastic scenes, death, cruelty to animals, content calling for self-destructive actions (self-mutilation, pro-ana, suicide, taking harmful substances, including psychoactive substances not clearly identified as drugs, etc.), content calling for to violence, crime, radicalisation (including sects) and extremism, patostreams, discriminatory and pornographic content;
   • access to harmful and inappropriate online contacts and online services – including: peer pressure, cyberbullying, grooming, sexual blackmail, sexual activity as a source of income for minors, online gambling, age-inappropriate advertising, age-inappropriate social media;
   • access to harmful and risky behaviour – e.g. taking online challenges, sexting, exerting pressure, using violence using information and communication technologies.
3. In connection with making the WI-FI network available at its headquarters, the Company ensures that the IT and organisational solutions used are based on current security standards, particularly that the Company’s Internet network or the network made available to children in other ways is protected against dangerous content.
4. Each Staff member working with children ensures their safe use of electronic media, in particular, ensures that children do not record or publish their own or other children’s images before, during and after training/sports activities/events in a manner contrary to the child’s dignity, and also informs children about the need to use social media carefully.

11. MONITORING THE APPLICATION OF THE POLICY, UPDATE PROCEDURE

§ 23

1. The procedure for updating the content of this Policy (monitoring and evaluation) takes place at least once every 2 years.
2. Monitoring and evaluation include verifying the implementation of the Standards for the Protection of Minors, responding to signals of violation of rules and procedures and proposing changes to the document, especially in terms of adapting them to current needs and compliance with applicable regulations, and are carried out by a designated person responsible for the Child Protection Policy.
3. The person responsible for the Child Protection Policy is also obliged to conduct discussions with the Staff (at least once every 2 years) regarding the protection of minors, situations that pose a threat to minors, and proposed changes to the content of the Policy. For this purpose, a survey is carried out among the Staff to monitor the level of implementation of the Policy. The survey template is attached as Annex No. 10 to this Policy. In the survey, Staff may propose changes to the Policy and indicate violations of the Policies.
4. If necessary, a separate survey or other form of assessment of the functioning of the Policy may be conducted among children and their guardians. The template is provided in Annex No. 11.
5. The person referred to in section 2 of this paragraph, prepares surveys or other forms of assessment completed by Staff members, children and their guardians, and assesses the compliance of the Policy with applicable legal provisions. On this basis, it prepares a monitoring report, which is then submitted to the Company’s Management.
6. The Company’s Management Board introduces the necessary changes to the Policy and announces the new wording of the Policy to the Staff, children and their guardians.

12. FINAL PROVISIONS

§ 24

1. In all matters not regulated in this document, generally applicable provisions of Polish law shall apply, including in particular the provisions of the legal acts listed in point II and other internal regulations in force in the Thermal Baths.
2. The Company reserves the right to change the provisions of this document. The changes will be effective on the date given, along with the information about its change (subject to section 3 below).
3. Annexes constitute an integral part of the Policy. Updating the list of annexes, changing their titles and numbering, adding/removing annexes, and similar actions are automatic and do not require the procedure described in section 2 above.
4. The policy enters into force on August 8, 2024
5. The content of the Policy is announced in a manner accessible to the Company’s Staff, children and their guardians, in particular by posting/exhibiting notices for the Staff in the place and/or by sending its text to the Staff electronically and by posting on the Company’s website and displaying it in a visible place in the Company’s registered office, also in a shortened version, intended for children (in the last two cases without Annexes Nos. 4, 5, 10 and 11, which are internal documents).
6. All Entities cooperating with the Company if their activities include contact with children are obliged to comply with the provisions of this Policy.