1. PREAMBLE

Chochołowskie Termy Sp. z o.o. with its registered office in Chochołów, as the owner and administrator of the facility under the name: Chochołowskie Termy, located at the following address: Chochołów 400, 34-513 Chochołów, being a socially responsible enterprise, treats respect for human rights, in particular the rights of children, as persons particularly vulnerable to harm, as a priority issue requiring the utmost attention and a restrictive approach, without the possibility of accepting any abuse in this regard. 

The guiding principle of all actions taken by the Company and its staff is to act for the good of the child and in their best interests. Every member of staff treats children with respect and takes their needs into account. The staff undertakes to build and maintain 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 violence against a child in any form. In pursuing these objectives, all staff shall act within the framework of applicable law, internal regulations and their competences.

The amendment to the Family and Guardianship Code defined the conditions for the effective protection of minors against broadly understood harm. The changes introduced became a determinant for 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. the Standards for the Protection of Minors applicable at the Chochołowskie Termy facility, as one of the elements of a systemic solution for the protection of minors against harm, constituting a form of safeguarding their rights.

This document is a set of rules and procedures for dealing with situations that threaten the safety of minors, including, in particular, cases where there is a suspicion that a child staying at the Chochołowskie Termy facility is being harmed, and for preventing such threats. Its most important goal is to protect children from 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 the goals to be achieved through its implementation are known, understood and accessible to the entire company and all persons and entities cooperating with it. The full version and the abridged version (intended for minors, containing information relevant to them) of this document are available on the Company’s website at: https://www.chocholowskietermy.pl/, as well as at the Company’s registered office at: (34-513) Chochołów 400.

2. LEGAL BASIS 

§ 1

This document has been prepared on the basis of the following legal acts:

1. The Convention on the Rights of the Child adopted by the United Nations General Assembly on 20 November 1989 /United Nations guidelines on business and human rights, recognising the important role of business in ensuring respect for children’s rights, in particular the right to protection of their dignity and freedom from all forms of harm/;
2. The 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, Criminal Code;
8. Act of 6 June 1997 Code of Criminal Procedure;
9. Act of 23 April 1964 Civil Code;
10. Act of 17 November 1964, Code of Civil Procedure.

3. EXPLANATION OF TERMS 

§ 2

The following definitions are used in this document and should be understood as follows:

1. Administrator or Company – Chochołowskie Termy Sp. z o. o. with its registered office in Chochołów (34-513) Chochołów 400, entered in 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 KRS number: 0000261672, REGON: 120300433, NIP: 7361640322;
2. Chochołowskie Termy, Complex, Facility or Thermal Baths – the facility above the name: Chochołowskie Termy, located at: Chochołów 400, 34-513 Chochołów, owned and administered by Chochołowskie Termy Sp. z o.o. with its registered office in Chochołów, consisting of, among others, car parks, entrance halls, ticket offices, cloakrooms/changing rooms and showers, a swimming pool and water zone (including indoor and outdoor pools, a water slide complex, water playgrounds, a treatment area, and a quiet and relaxation area), a SPA zone (Chochołowskie SPA), a sauna zone (Chochołowskie Saunarium), normobaric chambers (Chochołowska Normobaria), sports area, including a gym (Chochołowskie Centrum Sportu), a restaurant complex and a service area; Chochołowskie Termy also includes 14 apartments located directly in the Chochołowskie Termy facility at the following address: Chochołów 400, 34-513 Chochołów, and 4 holiday cottages, together with accompanying infrastructure and a reception desk to service them, constituting a complex called Termalne Spanie (hereinafter referred to as: “Termalne Spanie”);

3. child’s personal data – any information enabling the identification of the child;
4. child/minor – any person under the age of 18;
5. Facility Management – persons managing the Facility on behalf of its administrator, i.e. Chochołowskie Termy Sp. z .o.o. with its registered office in Chochołów, in particular Members of the Management Board;
6. harm – the commission of a prohibited or punishable act to the detriment of a child by any person, including a member of the Staff, or a threat to the welfare of a child, including neglect; any intentional or unintentional action/omission by an individual, institution or society as a whole, and any result of such action or inaction, which violates the equal rights and freedoms of children and/or disrupts their optimal development; there are 5 basic forms of harm:

• Physical violence against a child is violence that results in actual physical harm or the threat of such harm to the child. This harm is the result of an act or omission by a parent or other person responsible for the child, or whom the child trusts or who has authority over them. Physical violence against a child can be a repeated or single act. 
• Emotional (psychological) violence against a child is a chronic, non-physical, harmful interaction between a child and an adult, involving both actions and omissions. It includes, among other things: emotional unavailability, emotional neglect, a relationship with the child based on hostility, blame, slander, rejection, developmentally inappropriate or inconsistent interactions with the child, failure to recognise or acknowledge the child’s individuality and the psychological boundaries between adult and child. 
• Neglect: occurs when no one makes the child feel important, special and loved, cares for them or supports them. The child’s carer is not interested in their health, nutrition or living conditions. Neglect is the failure to meet the child’s basic needs and/or respect their basic rights by parents, carers or other persons responsible for the care, upbringing and protection of the child.  It includes both isolated incidents and a pattern of behaviour in which the carer fails to provide adequate conditions for the child’s physical, cognitive, social, emotional and psychosexual development and well-being. 
• Sexual violence (child sexual abuse) is the involvement of a child by an adult and/or another child in sexual activity without physical contact (e.g. exhibitionism, all forms of verbal abuse, e.g. conversations of a sexual nature inappropriate for the child’s age or commenting in a sexual manner on the child’s appearance and 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 a child to touch the perpetrator’s body in a sexual manner or sexual intercourse. Any sexual activity with a child under the age of 15 is a crime. Sexual abuse occurs when such activity takes place between a child and an adult or between a child and another child, if these persons, due to their age or degree of development, are in a relationship of care, dependence or power. Sexual abuse can also take the form of sexual exploitation, i.e. 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 abuse of another person. There is a particular risk of sexual exploitation during humanitarian crises. The risk of exploitation exists for both children and their carers.
• Peer violence (peer aggression, bullying): occurs when a child experiences various forms of violence from peers, either directly or through the use of communication technologies (the Internet and mobile phones). It occurs when the action is intended to cause someone distress or harm (intentionality), is systematic (repetitive), and the victim is weaker than the perpetrator or group of perpetrators. It includes verbal violence (e.g. name-calling, teasing, ridicule), relational violence (e.g. exclusion from a group, ignoring, turning others against a person), physical violence (e.g. beating, kicking, pushing, shoving), material (e.g. theft, destruction of property) and electronic (malicious text messages or emails, posts on social media, posting photos or videos on the Internet that ridicule the victim), as well as violence during a date on the part of 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. stranger – 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 associates (lifeguards, cashiers, Customer Service Office employees, SPA employees/therapists, sauna attendants, employees operating the Termalne Spanie Complex, catering staff, security staff, cleaning service employees, etc.), management, managers, etc., regardless of the form of employment, including volunteers, interns, and persons referred for internships;
9. Child guardian – a person authorised to represent a child, in particular their parent or legal guardian; for the purposes of this document, a foster parent is also considered a guardian;
10. person responsible for Internet safety –  a member of staff appointed by the Facility Management to supervise children’s use of the Internet on the premises and their safety on the Internet;
11. person responsible for the Child Protection Policy – a member of staff appointed by the Facility Management to supervise the implementation of the Policy, its correct application and updating;
12. Child Protection Officer – a member of staff appointed by the Facility Management responsible for receiving reports of threats to the welfare of children and taking action before the relevant authorities or institutions;
13. person responsible for providing support to the child – a person responsible for developing and monitoring a support plan for the child;
14. employee hired to work with children – any person hired to perform such duties, including a person employed on the basis of a civil law contract, an apprentice, an intern and a volunteer, regardless of the person’s nationality and age;
15. violence – any single or repeated intentional act or omission, exploiting physical, mental or economic superiority, violating the rights or personal interests of a child, in particular exposing them to the risk of loss of life or health, violating their dignity, physical integrity, freedom – including sexual freedom, causing damage to their physical or mental health, as well as causing suffering and harm;
16. Minor Protection Standards/Child Protection Policy (with the proviso 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; in the event of disagreement between the child’s parents, the parents should be informed of the need to have the matter resolved by the family court.

4. GENERAL PROVISIONS 

§ 3

The main principles guiding the Company in the implementation of this document are as follows:

1. Chochołowskie Termy treats the welfare of children as a paramount value and, in conducting activities  related to recreation, sport and the development of interests by minors, always acts with respect for their rights, observing the principle that harming minors, in particular the use of violence against them in any form, is unacceptable, and every child should always be treated with due respect and dignity;
2. Chochołowskie Termy is fully committed to its role in conducting socially responsible business and promoting desirable social attitudes, in particular, it is aware of the importance of the legal and social obligation to notify law enforcement authorities of any suspected crime against children;
3. Chochołowskie Termy considers it particularly important to educate its staff on the principles of proper behaviour towards children, including how to respond appropriately in circumstances indicating child abuse or suspected child abuse.
4. Chochołowskie Termy applies safe recruitment practices in accordance with legal requirements, in particular by checking the criminal records of persons who will have contact with minors in the course of their duties.

5. RECOGNISING AND RESPONDING TO RISK FACTORS FOR CHILD ABUSE

§ 4

1. In order to prevent child abuse, it is essential to pay attention to the risk factors for child abuse. 
2. Child abuse risk factors are understood to be factors that may co-occur with or precede violence against a child. Skilful recognition and response to risk factors can reduce the risk of violence against children.
3. The Facility’s staff have the necessary knowledge and, as part of their duties, pay attention to risk factors and symptoms of child abuse.
4. If risk factors are identified, the staff will talk to the guardians, providing information about the available support and motivating them to seek help for themselves.
5. The staff monitors the situation and the well-being of the child.
6. Staff members receive training in child protection appropriate to their role within the Chochołowskie Termy structure and their professional duties, and relating to their responsibility for children.

§ 5

1. Each newly hired staff member is familiarised with the provisions of the Child Protection Policy (applicable rules and procedures) and, if necessary, undergoes additional training on the rules contained in the Policy.

2. When the Policy is updated, members of staff shall be informed of the changes and, if necessary, receive additional training.
3. The duties of the person responsible for the Child Protection Policy include:

1. ensuring that the Child Protection Policy is available on the Company’s website and on its premises;
2. preparing Staff to apply the Child Protection Policy before starting work or after changes have been made to the Policy;
3. delegating tasks and responsibilities related to the implementation of the Child Protection Policy in the Company to the relevant units and monitoring their implementation;
4. supervising the keeping of records of Staff members who have familiarised themselves with the Child Protection Policy before starting work or after changes have been made to it;
5. reviewing the Child Protection Policy in consultation and cooperation with Management, Staff and, if deemed appropriate, with children and, where possible, their parents/guardians; including analysing recommendations from those responsible for online safety, child protection and child support;
6. monitoring whether there are any difficulties in applying the Policy;
7. coordinating work related to updating the Policy;
8. developing training schedules and the scope of educational activities.
9. The person responsible for Internet safety is tasked with ensuring:

1. the development of rules for safe Internet use on the premises;
2. the availability of the developed rules to staff, children, carers and event participants;
3. safe conditions for using the Internet on computers located at the Facility;
4. the installation and regular, at least monthly, updating of software that blocks access to content that is harmful and inappropriate for children;
5. checking, at least once a month, whether computers with free access to the Internet contain harmful content that is inappropriate for children’s age (if applicable);
6. monitoring cases of cyberbullying occurring at the Facility and providing recommendations to increase Internet safety to the person responsible for updating the Child Protection Policy.

5. The person responsible for child protection shall, as appropriate to the situation:

1. receiving reports of risk factors threatening the welfare of children;
2. receiving reports of symptoms of child abuse or harm; receiving reports of incidents or events that threaten the welfare of a child, documenting them, verifying them and informing the Management of the results of the findings;
3. accepting reports of suspected or improper disclosure, dissemination or use of a child’s image or problems revealed in this context;
4. initiating intervention; 
5. informing the relevant social welfare centre of the need to initiate the “Blue Card” procedure; 
6. notifying the guardianship court; 
7. filing a report of suspected criminal activity to the detriment of a minor; 
8. keeping records of incidents and interventions, securing documentation;
9. forwarding recommendations to increase child safety to the person responsible for updating the Child Protection Policy.
10. The person responsible for providing support to the child shall:

1. developing a plan to help the child;
2. cooperating with specialists providing support;
3. monitoring the support provided to the child;
4. forwarding recommendations to improve child safety to the person responsible for updating the Child Protection Policy.

7. Depending on the nature of the business, size and structure of the Company’s staff, the above responsibilities (arising 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 (Safeguarding Officer) or several persons appointed by the Management, and they must be specifically identified by name.
8. If one person is selected for all of the above tasks, during their absence, their duties will be temporarily taken over by another designated and appropriately instructed member of staff.

6. INTERVENTION PROCEDURES IN CASES OF SUSPECTED CHILD ABUSE –  rules applicable to children staying at the Complex for a short period of time as part of the normal use of the Company’s services and rules applicable to children using the accommodation services at the Thermal Complex.

§ 6

Procedure in case of suspected child abuse 

–  rules applicable at in the case of short-term stays of children at the Complex as part of the normal use of the Company’s services

1. Due to the specific nature of the Chochołowskie Termy facility, one of the basic forms of effective prevention of child abuse is the identification of a child staying at the Facility and his/her relationship with the adult with whom he/she is staying. 
2. The staff shall take all possible steps to identify the child and his/her relationship with the adult with whom he/she is staying at the Facility.
3. Whenever possible, the child and his/her relationship with the adult with whom he/she is staying at the Facility should be identified.
4. In unusual and/or suspicious situations indicating a possible risk of harm to the child, identification shall be carried out by the Staff on a mandatory basis. Examples of situations that may raise suspicion are listed in Appendix 1.
5. For the purposes of identifying the child and their relationship with the adult accompanying them to the Facility, you should:

1. ask for the child’s identity document (ID card) or another document confirming the child’s details; examples of other documents that can be used for identification are: school ID card, MObywatel application, Internet Patient Account;
2. if there is no identity document or if it is refused or cannot be presented, ask for the child’s details (e.g. first name, surname, address, date of birth) from both the adult and the child; in addition, ask both the adult and the child about their relationship; an example of a conversation with an adult and a child can be found in Appendix 2;
3. if the adult is not the child’s guardian, they should be asked to present an appropriate document proving the parents’ consent for the adult to travel with the child (e.g. a written statement);
4. if the adult does not have a document confirming parental consent, ask for the parents’ telephone number in order to call them and confirm that the child is staying at the Facility with a stranger with the knowledge and consent of their parents/legal guardians;
5. if the adult accompanying the child refuses to provide the child’s document and/or indicate the relationship between them, explain that the procedure is to ensure the safety of children using Chochołowskie Termy 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; 
6. after clarifying the matter in a positive manner, thank the person for taking the time to ensure that the child is in good care and emphasise once again that the procedure is designed to ensure the safety of children;
7. if the conversation does not dispel doubts about the adult accompanying the child and their intentions towards the child, and especially if they refuse to show their ID or provide a statement containing the child’s details, discreetly notify your supervisor and security staff in such a way as not to arouse suspicion (e.g. you can refer to the need to use equipment in the reception area, asking the adult to wait with the child in the lobby, restaurant or other place);
8. from the moment the first doubts arise, both the child and the adult should be under constant observation by staff and should not be left alone;
9. the supervisor who has been notified of the situation, in consultation with the Management or, in the absence of the Management, independently, decides to notify the police or, in case of doubt, takes over the conversation with the adult in order to obtain further explanations;
10. if the conversation confirms the belief that an attempt has been made or an act has been committed to the detriment of the child, the supervisor, in consultation with the Management or, in the absence of the Management, independently, shall notify the police of this fact; the procedure shall then be followed as in the case of circumstances indicating harm to a child (§ 8);  
11. in any case where members of staff witness unusual and/or suspicious situations involving a child, including employees such as cleaning staff, bar and restaurant staff, recreation areas, security, etc., they should immediately notify their supervisor, and in the absence of the supervisor, the decision-maker who will decide on appropriate action; depending on the situation and location, the supervisor shall verify the validity of the suspicion of child abuse. To this end, they shall select appropriate measures to clarify the situation or decide to intervene and, in consultation with the Management or, in the absence of the Management, independently, notify the police.

§ 7

Procedure in case of suspected child abuse 

–  rules applicable to children using accommodation services at the Termalne Spanie Complex 

1. In cases where children use the services of the Termalne Spanie Complex run by the Company, employees and associates, in particular those responsible for operating the reception desk of the Termalne Spanie Complex (checking guests in and out), they are obliged to be particularly vigilant and to react to any irregular or suspicious circumstances that may indicate that a child is being harmed.
2. In the interests of the welfare of children staying at the Termalne Spanie Complex, while respecting the privacy of all guests, employees and associates, in particular those responsible for operating the reception desk of the Termalne Spanie Complex (checking guests in and out), shall take all possible steps to identify the child and their relationship with the adult accompanying them. Identification is always carried out at check-in, and additionally each time unusual behaviour or circumstances are observed, including in particular the circumstances indicated in Appendix 1, which may indicate that a child is being harmed.
3. For the purposes of identifying the child and their relationship with the adult with whom they are staying at the Termalne Spanie Complex, it is necessary to:

1. ask for the child’s identity document or another document confirming that the adult has the right to care for the child; examples of documents that can be used for identification are: identity card, school ID card, MObywatel application, Internet Patient Account, court ruling; in the absence of an identity document or refusal to present it, ask for the child’s details (e.g. first name, surname, address, date of birth);
2. if there are no documents indicating the relationship between the child and the adult or if they refuse to present them, ask the adult and the child about this relationship; an example of a conversation with an adult and a child can be found in Appendix 2;
3. if the adult is not the child’s parent or legal guardian, they should be asked to present a document, e.g. the parent’s consent for the person to travel with the child, drawn up in writing with a signature officially certified by a notary public, or consent signed by the child’s parent, indicating the child’s details, their address, the parent’s telephone number and the identity document number/PESEL number of the person to whom the parent has entrusted the care of the child;
4. if the adult does not have any of the above documents, they should be asked to complete the relevant declaration, a template of which is provided in Appendix 3; the statement should contain the child’s details and the details of the adult with whom the child is staying, together with an indication of the relationship between the child and the adult; if the adult is not the child’s parent or legal guardian, they should declare that the parents/legal guardians have given their consent for the child to be looked after;
5. if the adult accompanying the child refuses to present the child’s document and/or indicate the relationship between them, it should be explained that the procedure is designed to ensure the safety of children using the Termalne Spanie Complex 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; 
6. after clarifying the matter in a positive manner, thank them for taking the time to ensure that the child is well cared for and emphasise once again that the procedure is designed to ensure the safety of children;
7. if the conversation does not dispel doubts about the adult accompanying the child and their intentions towards the child, and especially if they refuse to show their ID or provide a statement containing the child’s details, discreetly notify your supervisor and security staff in such a way as not to arouse suspicion (e.g. you can refer to the need to use equipment in the reception area, asking the adult to wait with the child in the lobby, restaurant or other place);
8. from the moment the first doubts arise, both the child and the adult should be under constant observation by staff and should not be left alone;
9. the supervisor who has been notified of the situation, in consultation with the Management or, in the absence of the Management, on their own, decides to notify the police or, in case of doubt, takes over the conversation with the adult in order to obtain further explanations;
10. if the conversation confirms the suspicion of an attempt or commission of an act harmful to a child, the supervisor, in consultation with the Management or, in the absence of the Management, independently, shall notify the police of this fact; further, the procedure shall be followed as in the case of circumstances indicating harm to a child (§ 8);  
11. in any case where employees of other departments of the Termalne Spanie Complex, including, for example, cleaning staff, bar and restaurant employees, witness unusual and/or suspicious situations, the entertainment and recreation room, security staff, etc., they should immediately notify their supervisor, and in the absence of the supervisor, the decision-maker who will decide on the appropriate action to be taken; Depending on the situation and location, the supervisor verifies the validity of the suspicion of child abuse. To this end, they select appropriate measures to clarify the situation or decide to intervene and, in consultation with the management or, in the absence of the management, independently, notify the police.

§ 8

Procedure in the event of disclosure of circumstances indicating child abuse 

1. The disclosure of harm may occur in the following manner:
   1. the child has disclosed the abuse to the Facility Staff;
   2. a member of Staff observes the abuse;
   3. a third party (e.g. another Guest/Customer) has disclosed to Facility Staff a suspicion of child abuse, and the observations of an employee or co-worker have confirmed this fact with a high degree of probability;
   4. the child has signs of harm (e.g. scratches, bruises) and, when asked, responds inconsistently and/or chaotically and/or becomes embarrassed, or there are other circumstances that may indicate harm.
2. A member of staff who has reasonable suspicion that a child staying at the Facility is or has been abused should immediately notify their supervisor/decision-maker, who will assess the situation and, if necessary, in consultation with the Management or, in the absence of the Management, independently, notify the police. 
3. In the event of an immediate threat to the child’s safety, a member of staff who has reasonable grounds to suspect that a child is being harmed shall immediately notify the police by calling 112 and describing the circumstances of the incident. Notwithstanding the above, the member of staff shall notify their immediate superior of the incident, who shall in turn contact the Management. 
4. Efforts should be made to make it difficult or even impossible for the child and the person suspected of harming the child to leave the Facility. 
5. In the case specified in Article 243 of the Code of Criminal Procedure, a citizen’s arrest of the 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. The detention should be carried out with respect for the dignity of the detained person, without the presence of children, if possible.
6. In all cases, the safety of the child must be ensured. Where possible, the child should remain in the care of a designated member of staff until the police arrive. Where possible, an attempt should be made to support the child.
7. If there is reasonable suspicion that a crime has been committed, resulting in the child coming into contact with the perpetrator’s biological material (sperm, saliva, skin), the child should, if possible, be prevented from washing and eating/drinking until the police arrive. Calmly and respectfully explain to the child why these restrictions have been imposed.
8. Once the child has been taken into police custody, secure the CCTV footage and other relevant evidence (e.g. documents) relating to the incident and forward them to the Management, who will, at the request of the authorities, forward a copy by registered post or in person to the public prosecutor or the police. 
9. After the intervention, report the incident to the person responsible for the Child Protection Policy, who will then describe it in the incident log or other document designated for this purpose.

§ 9

Procedure in the event of suspected or confirmed child abuse by an employee/other adult

1. In the event of suspected child abuse by an employee or other adult who is not directly employed by the Company but by a third party, the person who has obtained this information should immediately inform their immediate 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 directly threatened, the person who has become aware of this should immediately notify the police by calling the emergency number 112, providing their own details, the child’s details (if possible), the child’s whereabouts and a description of the circumstances of the case and notify their supervisor/decision-maker, who will then contact the Management, who will notify the child’s guardians/parents. The person who became aware of the incident also informs the person responsible for the Child Protection Policy by email/in writing.
3. In the event that an employee has committed an act of harm against a child other than a criminal offence, the person responsible for the Child Protection Policy, after becoming aware of the information, should investigate all the circumstances of the case, in particular by interviewing the employee suspected of harm and other witnesses to the incident. In a situation where the violation of the child’s welfare is significant, in particular where there has been discrimination or violation of the child’s dignity, the person responsible for the Child Protection Policy should recommend to the Management appropriate personnel measures in relation to that employee.
4. If the person who committed the harm is not directly employed by the Company but by a third party (e.g. outsourcing), then a ban on their entry to the Facility should be recommended and, if necessary, the contract with the third party should be terminated.

§ 10

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

1. If a child is found to be harmed by a parent/guardian or other adult with whom the child is staying at the Facility, any member of Staff who witnesses such harm should react firmly.
2. If the child’s life or health is in immediate danger, the person who has become aware of this should immediately notify the police by calling the emergency number 112, providing their own details, the child’s details (if possible), the child’s whereabouts and a description of the circumstances of the case, and notify their supervisor/decision-maker, who will in turn contact the Management. The person who has become aware of the incident shall also inform the person responsible for the Child Protection Policy by e-mail/in writing.
3. If an employee of the Facility witnesses physical violence against a child (spanking, shaking, shouting, or other acts listed in the definition of physical violence), they should try to stop the abuse and react. Possible forms and methods of responding to abusive behaviour by a parent/guardian/other adult towards a child are listed in Appendix 4.
4. In a situation where a child under the age of 7 is left unattended, an employee who becomes aware of such an incident should notify their supervisor. The supervisor who has been notified of the situation decides on further action in the context of the provisions of the Criminal Code and the Code of Misdemeanours. Depending on the context, the supervisor shall attempt to locate the parent/legal guardian or other adult with whom the child is staying at the Facility and explain that they cannot leave the child unattended. In a situation where it is not possible to locate the parent/legal guardian or other adult with whom the child is staying at the Facility is not possible, or the parent/legal guardian/other adult does not want to and/or is not able to take care of the child, the supervisor, in consultation with the Management or, in the absence of the Management, on their own, shall notify the police. In all cases, the safety of the child must be ensured.

7. INTERVENTION PROCEDURES IN CASES OF SUSPECTED CHILD ABUSE – rules applicable to children participating in activities and events conducted by the Company’s staff at the Complex (activities at the Chochołowskie Sports Centre, swimming lessons, competitions and events, etc.) involving repeated contact with the children concerned 

§ 11

1. Intervention procedures are designed to support Staff members in fulfilling their legal and social obligation to respond to suspected child abuse. Sports staff, due to their ability to observe children in situations that reveal the effects of abuse, play an important role in the process of identifying abuse in children. 
2. The aim of the intervention is to stop the harm to the child and ensure their safety.
3. Threats to children’s safety can take many forms, using various means of contact and communication.
4. For the purposes of this document, the following classification of threats to children’s safety has been adopted:
   1. crime against a child (e.g. sexual abuse, child abuse);
   2. other forms of harm that are not prosecutable offences, such as shouting, physical punishment, humiliation;
   3. neglecting the child’s basic needs (e.g. related to nutrition, hygiene or health).
5. For the purposes of this document, intervention procedures have been identified in cases of suspected harm to a child by:
   1. adults (staff, other third parties, parents/legal guardians);
   2. another child.

§ 12

Procedure in cases of suspected child abuse

1. If a member of Staff suspects that a child is being harmed, or if such a circumstance is reported by a child or a child’s guardian, the member of Staff is required to make a memo and forward the information obtained to the Company’s Management. The memo may be in writing or by email.
2. The intervention is carried out by the Company’s Management, which may appoint another person to perform this task on a permanent basis. If such a person is appointed, their details (name, surname, email, telephone number) will be communicated to the Staff, children and guardians.
3. If another person is appointed to carry out the intervention, the term “Company Management” shall be understood to mean the person responsible for carrying out the intervention.
4. If harm has been reported on the part of the person appointed to conduct the intervention, the intervention shall be conducted by the Company Management.
5. If harm by Company Management has been reported and no person has been designated to conduct the intervention, the actions described in this chapter shall be taken by the person who noticed the harm or to whom the suspected harm was reported.
6. Specialists, in particular psychologists and educators, may be invited to participate in the intervention in order to assist in talking to the child about difficult experiences.
7. The Company’s management informs guardians of their 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). If informing the child’s guardian is contrary to the child’s best interests or impossible, this obligation is waived.
8. After informing the guardians in accordance with the preceding paragraph, the Company’s management shall report the suspected offence to the public prosecutor’s office/police or submit a request for an investigation into the family’s situation to the competent district court, family and juvenile division, or a letter requesting an investigation into the child’s situation to the social welfare centre.
9. Further proceedings shall be the responsibility of the institutions indicated in the preceding paragraph.
10. An intervention card shall be drawn up for each intervention, a template of which is attached as Appendix 5 to this Policy. The card shall be attached to the intervention register kept by the Company/the person designated as responsible for child protection.
11. All persons who, in the course of their professional duties, have obtained information about child abuse or related information are obliged to maintain confidentiality, except for information provided to authorised institutions as part of intervention measures.
12. If the child’s guardians have reported a suspected threat to the child’s safety and the suspicion has not been confirmed, the child’s guardians shall be informed of this fact in writing.
13. Depending on the needs, a team consisting of specialists and Company Personnel may be appointed to develop methods of supporting the abused child.

§ 13

If there is a suspicion that the child’s life is in immediate danger or that the child is at risk of serious harm to their health, the member of staff who first became aware of the threat shall inform their immediate superior, who, in consultation with the Management or, in the absence of the Management, independently, shall notify the relevant services (police, emergency services) by calling 112. 

§ 14

Abuse by an adult

1. In the event of a reported case of child abuse, the Company’s management conducts an interview with the child and other persons who have or may have knowledge of the incident and the child’s personal (family, health) situation, in particular their guardians. The management will attempt to establish the course of events, as well as the impact of the incident on the child’s mental and physical health. The findings will be recorded on an intervention card.
2. The Company’s management organises a meeting/meetings with the child’s guardians (unless the guardian is the perpetrator), during which it provides information about the incident and the need/possibility of seeking specialist support, including from other entities or services.
3. If a crime has been committed against the child, the Company’s management prepares a report on the possible crime and forwards it to the local police or prosecutor’s office.
4. If the conversation with the guardians reveals that they are not interested in helping the child, ignore the incident or otherwise do not support the child who has experienced harm, the Company’s management prepares a request for an investigation into the family’s situation, which it forwards to the competent family court.
5. If the findings indicate that the child’s guardian is neglecting their psychological and physical needs or that the family is unable to provide adequate care (e.g. the child wears clothes that are inappropriate for the weather, leaves their place of residence without adult supervision), the family uses violence against the child (parent/other household member shouts at the child, uses spanking or similar physical punishment), the competent social welfare centre should be informed of the need to help the family when the failure to meet the child’s needs is due to poverty or, in the case of violence and neglect, the need to initiate the “Blue Card” procedure.
6. If child abuse by a member of the Company’s staff has been reported, that person shall be removed from all forms of contact with children (not only the abused child) until the matter has been clarified.
7. If a member of the Company’s staff has committed an act of harm against a child other than a publicly prosecuted offence to the child’s detriment, the Company’s management should investigate all the circumstances of the case, in particular by hearing the person suspected of harm, the child and other witnesses to the incident. In a situation where the violation of the child’s welfare is significant, in particular where there has been discrimination or violation of the child’s dignity, consideration should be given to terminating the legal relationship with the person who committed the harm or recommending such a solution to that person’s superiors. If the person who committed the harm is not directly employed by the Company but by a third party or is a volunteer, then a ban on that person entering the Facility should be recommended and, if necessary, the contract with the cooperating institution should be terminated.
8. All persons who, in connection with the performance of their professional duties, have obtained information about child abuse or related information, are obliged to keep this information confidential, except for information provided to authorised institutions as part of intervention measures.

§ 15

Peer abuse

1. If there is a suspicion that a child is being harmed by another child at the facility (e.g. during training sessions or sporting events), a conversation should be held with the child suspected of causing harm and their guardians, as well as separately with the child being harmed and their guardians. In addition, other persons with knowledge of the incident should be interviewed. During the interviews, an attempt should be made to establish the course of events and the impact of the incident on the mental and physical health of the abused child. The findings are recorded on an intervention card. Separate intervention cards are drawn up for the abuser and the abused child.
2. A remedial plan should be developed together with the carers of the child who is causing harm in order to change undesirable behaviour.
3. A plan to ensure the safety of the abused child should be developed with the child’s guardians, including ways to isolate the child from sources of danger.
4. During the discussions, it is important to ensure that the child suspected of harming another child is not being harmed by their guardians, other adults or other children. If this is confirmed, intervention should also be taken in relation to that child.
5. If the child who is harming others does not participate in the activities of the entity, talk to the child who is being harmed, other people who have knowledge of the incident, and the carers of the child who is being harmed in order to establish the course of events and the impact of the incident on the child’s mental and physical health. The management of the facility organises a meeting/meetings with the child’s guardians, during which they provide information about the incident and the need/possibility of seeking specialist support, including from other entities or services, and about ways of responding to the incident (informing the family court, informing the school, informing the guardians of the child who committed the abuse).
6. If the person suspected of abuse is a child between the ages of 10 and 17 and their behaviour constitutes a criminal offence, the local family court or police should also be notified in writing.
7. If the person suspected of abuse is a child over the age of 17 and their behaviour constitutes a criminal offence, the local police or public prosecutor’s office should be notified in writing.

§ 16

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/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, the following steps should be taken:

1. notify the parents/guardians of the affected child and the child who made the content available;
2. record, analyse and document the incident appropriately;
3. notify the police/family court if a criminal offence is suspected;
4. ensure the safety and support of the affected child.

§ 17

Support plan

1. A support plan should be developed for a child who is being harmed. This applies to situations of harm by adults (staff, other third parties, parents/legal guardians) and other children. The plan should include guidelines for the Company to take action to ensure the child’s safety, including:

1. ways of isolating him from sources of danger;
2. support that the Company will offer the child;
3. referral of the child to a specialist child support facility, if necessary.

2. The support plan should be developed with the child’s guardians and discussed with the child. If the guardian is the person harming the child, the plan should be developed in consultation with the non-abusive parent.
3. When developing the support plan, the Company’s capabilities and resources should be used and other specialist entities should be involved, such as: local social welfare centres, crisis intervention centres, psychological and pedagogical counselling centres, specialist family counselling centres, early intervention centres, day support centres, community mental health centres for adults and community mental health centres for children and young people, child support centres (centrapomocydzieciom.fdds.pl), national and local non-governmental organisations involved in supporting parents and children. As a supplement to these measures, the child can be given the helpline number 116 111. Adults can use the Telephone for Parents and Teachers on Child Safety 800 100 100.

8. FACILITY STAFF – DETAILED REGULATIONS 

§ 18

1. The Company educates its Staff to equip them with the ability to recognise the signs/symptoms of child abuse and to respond quickly and appropriately to situations of abuse. 
2. The Company may provide the above-mentioned training in various forms, e.g. external training, internal training, e-learning, educational materials developed by the Company and available to Staff, educational materials available free of charge, developed by other organisations.
3. Before being allowed to work/perform official duties, each member of Staff shall familiarise themselves with the Child Protection Standards, which they shall confirm by submitting a statement to that effect. At the same time, they shall undertake to comply with the rules and procedures contained in the Standards. A template of the above-mentioned statement is attached as Appendix 6 to this Policy. 
4. The statement is included in the employee’s personal file or, if there is no such file, attached to the civil law contract.
5. Failure to consent to the signing of the documents referred to in section 3 above prevents the establishment of any legal relationship with that person (conclusion of an employment/cooperation contract).

§ 19

Employment of persons to work with children – rules for the recruitment of personnel

1. All persons 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 them with duties involving working with children, their qualifications and competences for working with children should be determined, and the risk of them posing a threat to the welfare and safety of children should be ruled out.
3. Before employing or assigning a person to work with children, it is determined whether they have harmed a child in the past. The findings are made in accordance with Article 21 of the Act of 13 May 2016 on counteracting threats of sexual crime and protecting minors, and are carried out in relation to every person employed by the Company for work related to education, recreation and childcare.

§ 20

Rules for safe employee-child relationships

1. All employees of the Chochołowskie Termy facility (all Staff), as well as other adults who have contact with children on the premises of the Facility, if such contact takes place with the consent of the Company, are required to maintain a professional relationship with children and to consider each time whether a given reaction, message or action towards a child is appropriate to the situation, safe, justified and fair. They should act in an open and transparent manner towards others in order to minimise the risk of misinterpretation of their behaviour.
2. The guiding principle of all actions taken by employees who come into contact with children on the premises of the Thermal Baths is to treat the child with respect and to take into account their dignity and needs. When communicating with a child, one should be patient and respectful, listen carefully to the child and give them answers appropriate to their 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 violence against a child in any form. 
5. It is not permitted to embarrass, humiliate, disregard or insult a child. It is not permitted to shout at a child in any situation other than one involving the safety of the child or other children. It is not permitted to hit, poke, push or in any way violate the physical integrity of a child, unless there is a threat to the health or life of the child.
6. Employees must not use their physical advantage or threaten children.
7. Employees must not make inappropriate jokes, use profanity, make offensive gestures or make sexually suggestive comments in the presence of children.
8. Employees should not engage in games such as tickling, pretend fighting, rough physical play, etc.
9. Employees are not permitted to record images of children for private purposes. Recording images in other situations and for other purposes is regulated by separate provisions.
10. Sensitive information about a child must not be disclosed to unauthorised persons, including other children. This includes the image of the child, information about his/her family, economic, medical, care and legal situation.
11. It is strictly forbidden to establish any romantic or sexual relationship with a child or to make inappropriate proposals to them. This also includes sexual comments, jokes, gestures and sharing erotic and pornographic content with children, regardless of its form.  It is forbidden to contact a child through private communication channels (private telephone, e-mail, instant messaging, social media profiles) or to meet with a child outside the workplace.
12. Contact with children should only take place during working hours and for purposes within the scope of the Staff’s duties.
13. It is strictly forbidden to offer children alcohol, tobacco products, other stimulants or illegal substances.
14. All of the above behaviours are prohibited under penalty of law as provided for in the Criminal Code, as well as loss of employment.
15. Staff are required to reassure children that if they feel uncomfortable in a situation, or about specific behaviour or words, they can tell Staff and can expect an appropriate response and/or help. The child should be informed where the Child Protection Standards are located in the Facility in a version that is understandable to them and assured that if they have any questions, they can contact a designated member of the Company’s staff.  
16. If an employee notices disturbing behaviour or a situation, in particular if they witness any of the above-described behaviours and/or situations on the part of other adults or children, they are required to follow the instructions contained in these standards of conduct.
17. The detailed rules for safe staff-child relationships are set out in Appendix 7.

§ 22

Rules for safe relationships in other configurations 

1. The Company has also implemented rules for safe child-child relationships, as set out in Appendix 8, and parent-child and parent-coach relationships, as set out in Appendix 9.
2. The rules set out in paragraph 1 above are known to the Staff.

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

§ 23

1. The Company ensures the highest standards of personal data protection for children in accordance with applicable law and the Company’s Personal Data Protection Policy.
2. Guidelines for the protection of children’s image, containing detailed rules for recording and publishing children’s image for business and private purposes, as well as rules for storing materials containing children’s image, are set out in Appendix 10 to the Policy.
3. Recognising the child’s right to privacy and protection of personal rights, the Company ensures the protection of the child’s image by acting responsibly and prudently with regard to the recording, processing, use and publication of images of children.
4. The recording, processing, use and publication of a child’s image in a photograph, recording or any other medium must be carried out with consideration and caution. Such activities are only permitted for the purpose of celebrating the child’s successes, documenting the activities or functioning of the Facility and events organised at the Facility (e.g. tournaments, competitions, games, training sessions and other events), while ensuring the safety of children.
5. The photographs or recordings referred to in paragraph 4 shall be made without discrimination on the basis of any characteristics.
6. In all cases, the welfare and dignity of the child must be taken into account. Material containing the image of a child must not be derogatory or offensive to the child, show situations which, without context, appear ridiculous or inappropriate, show violations of privacy or nudity, or perpetuate stereotypes. In order to protect the child from actions that violate their welfare, during registration:
   1. the child must be clothed, and the situation captured in the photograph/recording must not be humiliating or ridiculing to the child or show them in a negative context;
   2. photos/recordings of the child should focus on the activities performed by the child and, as far as possible, show the child in a group, not individually.
7. It is prohibited to disclose any information about the child during registration, including their health, financial situation, legal situation and information related to the child’s image.
8. All suspicions and problems concerning the inappropriate recording and dissemination of images of children should be recorded and reported to the Company’s Management and the Data Protection Officer appointed by the Company.

10. RULES FOR CHILDREN’S ACCESS TO THE INTERNET

§ 24

1. When providing children with access to the Internet, the entity is obliged to take measures to protect children from accessing content that may pose a threat to their proper development. 
2. The following are considered to be risks associated with children’s use of the Internet and electronic media:  
   1. access to illegal content, including material depicting child sexual abuse; materials depicting hardcore pornography, content promoting racism and xenophobia, other illegal content directed against the safety of children, for example: promoting or condoning paedophilic behaviour, materials depicting a naked person or a person engaged in sexual activity involving violence, threats of unlawful or deceitful acts or disseminated without consent, pornographic content made available to minors, seduction of children under 15 years of age via the Internet, so-called child grooming, sexual blackmail (also referred to as “sextortion”);
   2. access to harmful and inappropriate content, including content depicting violence, physical injury, presenting graphic scenes, death, cruelty to animals, content inciting self-destructive behaviour (self-harm, pro-ana, suicide, use of harmful substances, including psychoactive substances not clearly identified as drugs, etc.), content inciting violence, crime, radicalisation (including sects) and extremism, pathostreams, discriminatory and pornographic content;
   3. 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;
   4. access to harmful and risky behaviours – e.g., taking part in online challenges, sexting, exerting pressure, using violence with the use of information and communication technologies.
3. In connection with providing Wi-Fi access at its headquarters, the Company ensures that the IT and organisational solutions used are based on current security standards, in particular that the Company’s internet network or any network made available to children in any other way is protected against dangerous content. 
4. Every member of staff working with children ensures that they use electronic media safely, in particular by ensuring that children do not record or publish images of themselves or other children before, during and after training/classes/sports events in a manner contrary to the dignity of the child, and informs children about the need to use social media prudently.

11.  MONITORING OF POLICY IMPLEMENTATION, UPDATE PROCEDURE

§ 24

1. The procedure for updating the content of this Policy (monitoring and evaluation) takes place at least once every two years.
2. Monitoring and evaluation include verification of the implementation of the Standards for the Protection of Minors, responding to reports of violations of rules and procedures, and proposing changes to the document, especially in terms of adapting it to current needs and compliance with applicable regulations, and are carried out by the person designated as responsible for the Child Protection Policy.
3. The person responsible for the Child Protection Policy is also required to conduct interviews with Staff (at least once every two years) concerning 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 conducted among the Staff to monitor the level of implementation of the Policy. A template of the survey is provided in Appendix 11 to this Policy. In the survey, the Staff may propose changes to the Policy and indicate violations of the Policy.
4. A separate survey or other form of assessment of the functioning of the Policy may be conducted among children and their guardians, if necessary. A template is provided in Appendix 12.
5. The person referred to in section 2 of this paragraph shall prepare surveys or other forms of assessment completed by members of the Staff, children and their guardians, and assess the compliance of the Policy with applicable legal regulations. On this basis, they shall prepare a monitoring report, which shall then be submitted to the Company’s Management. 
6. The Company’s Management Board shall introduce the necessary changes to the Policy and announce the new wording of the Policy to the Staff, children and their guardians.

12. FINAL PROVISIONS

§ 25

1. In all matters not covered by this document, the generally applicable provisions of Polish law shall apply, including in particular the provisions of the legal acts listed in point II, as well as other internal regulations in force at the Baths.
2. The Company reserves the right to amend the provisions of this document. The amendments shall become effective on the date specified in the notification of the amendment (subject to paragraph 3 below). 
3. The appendices form an integral part of the Policy. Updating the list of appendices, changing their titles, numbering, adding/removing appendices and similar actions shall take effect automatically and shall not require the procedure described in paragraph 2 above. 
4. The Policy shall enter into force on 1 December 2025 and shall replace the version dated 8 August 2024.
5. The content of the Policy shall be announced in a manner accessible to the Company’s Staff, children and their guardians, in particular by displaying/posting it in the notice board for Staff and/or by sending its text to the Staff by electronic means and by posting it on the Company’s website and , displaying it in a visible place at the Company’s registered office, also in an abridged version intended for children (in the latter two cases, without Appendices 5, 6, 11 and 12, which are internal documents).
6. All entities cooperating with the Company, if their activities involve contact with children, are required to comply with the provisions of this Policy.