Minor Protection Standards

Standards for the Protection of Minors
at Arche Garnizon Białystok

General Information about the Standards

1. The Basis for Adoption of the Standards
   1. The Standards for the Protection of Minors (hereinafter "Standards") have been adopted on the basis of Article 22c
      of Section 3 and following of the Act of May 13, 2016, on counteracting threats involving sexual crimes and the protection of minors.
2. Where the Standards Apply
   1. The Standards apply at Arche Koszary Białystok (address: ul. Depowa 15-399, Białystok) [hereinafter "Hotel"], which is a hotel facility run by ARCHE S.A. with its registered office in Warsaw at ul. Puławska 361, 02-801 Warsaw, entered in the register of entrepreneurs of the National Court Register maintained by the District Court for the Capital City of Warsaw
      in Warsaw, 13th Commercial Division of the National Court Register under KRS number 0000831001, having NIP 821-163-93-35 and REGON 710021277.
3. Who the Standards Apply To
   1. The Standards apply to the Hotel staff, as well as the parents, legal or actual guardians of minors, as well as other persons obliged to protect minors in connection with their stay at the Hotel.
4. What the Standards Regulate
   1. The Standards regulate in particular:
      1. principles ensuring safe relationships between the Hotel staff and minors, especially prohibited behaviours towards minors;
      2. principles and procedures for identifying a minor staying at the Hotel and their relationship to the adult person accompanying them in the facility;
      3. principles and procedures for responding in cases of justified suspicion that the welfare of a minor on the Hotel premises is at risk;
      4. procedures and persons responsible for reporting suspicion of a crime committed against a minor and notifying the family court;
      5. the scope of competence of the person responsible for preparing the Hotel staff to apply the Standards, the principles for preparing this staff to implement them, and the method of documenting this activity.

Standards for the Protection of Minors

1. Safe Relationships between Staff and Minors
2. General Principles
   1. The Hotel operates with respect for human rights, particularly the rights of minors as persons especially vulnerable to harm. Therefore, the Hotel staff treat minors with due respect, honoring their dignity and needs.
   2. Hotel staff act based on and within the limits of the laws applicable in the territory of the Republic of Poland;
   3. internal regulations and these Standards.
3. Communication with Minors
   1. In communication with minors, Hotel staff:
   2. address the minor with respect and patience; listen attentively and provide answers appropriate to the minor's age and situation, taking into account minors with disabilities and special educational needs; respect the minor's right to privacy;
   3. do not shout, humiliate, insult, ignore, embarrass the minor, or otherwise violate their dignity.
4. The following behaviours are strictly prohibited towards minors:
   1. any behaviours forbidden by law, including criminal law;
   2. disclosing to unauthorized persons information about minors, such as their image, family, custody, or legal situation;
   3. use of vulgar language, gestures, jokes, offensive remarks, references to minor's sexuality, exploitation of power relations or physical superiority, including intimidation, threats, coercion;
   4. recording the image of minors in any form for private purposes, including filming, photographing, voice recording;
   5. offering minors alcohol, tobacco products, or other illegal substances, as well as using them in the presence of minors;
   6. establishing any romantic or sexual relationship with a minor, including making sexual comments, jokes, gestures, or sharing erotic and pornographic content in any form;
   7. use of physical or psychological violence of any form, especially hitting, pushing, shoving, violating the minor's bodily integrity; touching the minor in a way that could be considered indecent or inappropriate.
5. Staff Selection
   1. All persons working with minors must be safe for them, which means notably that their employment history should show no past harm to minors.
   2. Anyone employed by the Hotel in roles related to education, recreation, and care of minors must be mandatorily checked in the Register of Sexual Offenders.
   3. Checks are performed by printing the search results from the restricted-access Register, which are then placed in the personnel files. Checks must be repeated annually. The scope of personal data required for checking is found in Annex 1 to the Standards.
   4. Additionally, every person hired/deployed for work with children must provide information from the National Criminal Register concerning crimes specified in Chapters XIX and XXV of the Penal Code, Articles 189a and 207, and in the Act of July 29, 2005 on Counteracting Drug Addiction (Journal of Laws 2023 item 172 and 2022 item 2600), or equivalent prohibited acts under foreign law.
   5. Staff working with minors, including those potentially in contact with minors, should submit a declaration of no criminal record and that no proceedings relating to offenses against minors are pending – Annex 2 to the Standards.
   6. If a person hired/deployed has citizenship other than Polish, they must also provide information from their country's criminal registry, obtained for professional or volunteer activities involving contact with children, or a statement if such information is not issued in that country.
   7. A declaration concerning countries of residence in the past 20 years, other than Poland and country of citizenship, signed under criminal liability, must be obtained from the person hired/deployed – Annex 3 to the Standards.
   8. If the law of the country, from which criminal record information should be provided, does not provide such records or does not maintain a criminal registry, the hired/deployed person must submit a statement to that effect under criminal liability – Annex 4 to the Standards.
   9. Declarations signed under criminal liability must include the statement: "I am aware of the criminal liability for submitting a false declaration." This statement replaces official instructions about criminal liability for false declarations.
6. When using external service providers, the Hotel includes a provision in the contract enabling enforcement of the appropriate standard regarding employee checks for child safety. This clause allows the Hotel to control compliance, with the threat of immediate contract termination and contractual penalties or other sanctions for non-compliance.

Identification of the Minor and Their Relationship to the Adult

1. One effective form of preventing harm to minors is identifying the minor staying in the hotel and their relation to the accompanying adult. Staff take all possible steps to identify the minor and their relationship with the adult present.
2. When speaking with an adult, remain calm, polite, and patient. At the start, inform the adult that the Hotel follows the Standards for the Protection of Minors and that staff may ask additional questions to verify the minor's details. When needed, refer to the legal basis mentioned at the beginning of this document.
3. To identify the minor and determine their relationship to the accompanying adult, it is necessary to:
   1. request the minor's identity document (ID card, passport, school ID) and record their data in the hotel guest register;
   2. inquire about the minor's relationship to the accompanying adult;
      1. if no documents indicate kinship between the minor and the adult, ask about the relationship from both the adult and the minor;
      2. if the adult is not the parent or legal guardian of the minor, request a parental or guardian consent document for the adult to accompany the minor (e.g., a written statement);
      3. if the adult does not have a parental consent document, ask for the parents' or guardians' phone number to call and confirm the minor's stay with the accompanying adult with their knowledge and consent. Also ask the adult to fill out a relevant declaration prepared by the Hotel. This declaration should contain the child's and adult's details, indicating the relationship between them. If the adult is not the parent or legal guardian, they must declare that the parents/guardians consented to their care. The declaration template is in Annex 5 of the Standards.
   3. if the adult refuses to show the minor's document or disclose the relationship, explain that the procedure serves to ensure the minor's safety and is mandated by law;
   4. after a positive resolution, thank the person for their time and emphasize again that the procedure aims to ensure minors' safety;
   5. if doubts remain regarding suspicion about the adult and their intentions to harm the minor, discreetly inform a supervisor. To avoid suspicion, you can, e.g., cite the need to use equipment at the back of the reception, asking the adult to wait with the minor in the lobby, restaurant, or another location. The supervisor refers to the Hotel Director and their deputies, or the department manager assigned to duty;
   6. once doubts arise, both the minor and adult should be under staff observation and not left alone;
   7. the notified supervisor decides whether to inform the police or, if in doubt, takes over the conversation with the adult for further clarifications;
   8. if the conversation confirms the suspicion of a crime against the minor, the supervisor reports it to the police and follows the procedure for circumstances indicating harm to a minor;
   9. if employees from other Hotel departments witness unusual or suspicious situations, e.g., cleaning staff, room service, bar and restaurant staff, relaxation areas, security, etc., they should promptly inform a supervisor, who will decide on appropriate actions.
4. Depending on the situation and location, the supervisor assesses the validity of the suspicion of harm to a minor and chooses appropriate means to clarify or initiates intervention and informs the police.
5. A sample conversation with an adult and minor is described in Annex 6 to the Standards, and examples of suspicious situations are found in Annex 7.

Response in Case of Justified Suspicion that the Welfare of a Minor is Threatened

1. Procedure in Cases Indicating Harm to a Minor.

If there is a justified suspicion that a minor staying on the premises is being harmed, the police must be immediately notified by calling 112 and describing the circumstances. Depending on the situation’s dynamics and circumstances, the call is made by the person who is a direct witness (employee/supervisor). If the notifier is a staff member, they also inform their supervisor.

1. Justified suspicion of harming a minor arises when:
   1. the minor reveals to an employee that they are harmed;
   2. an employee observes harm;
   3. the minor bears signs of harm (e.g., scratches, bruises), and when questioned responds inconsistently/chaotically and/or becomes embarrassed, or other circumstances indicate harm, e.g., finding child pornographic materials in the adult’s room;
2. In this situation, prevent the minor and the person suspected of harming them from leaving the premises.
3. In justified cases, a citizen’s arrest of the suspected person may be made. Until the police arrive, keep the person in a separate room out of guests’ sight, supervised by two employees.
4. Always ensure the minor’s safety. The minor should remain under staff care until police arrive.
   1. If there is justified suspicion of a crime involving contact with the perpetrator’s biological material, if possible prevent the minor from washing or eating/drinking until the police arrive.
   2. After police take the minor, secure monitoring footage and other relevant evidence (e.g., documents) and promptly forward to the facility's General Manager.
   3. After the intervention, describe the incident in the incident log or another designated document.

Procedures and Persons Responsible for Reporting Suspicion of a Crime against a Minor and Notifying the Family Court

1. Procedure and Authorized Persons
   1. The reporting procedure described above applies.
   2. Persons authorized to report notifications are those indicated above.

Scope of Competence of the Person Responsible for Preparing Staff to Apply the Standards, Preparation Principles, and Documentation Methods

1. Scope of Competence
2. The person responsible for preparing the Hotel staff to apply the Standards is the Hotel Director or an authorized person.
3. The person mentioned acquaints staff with the Standards, collects declarations as per point 4.3 of the Standards, and is responsible for receiving reports of incidents threatening minors.
4. Staff employed to work with children undergo cyclical training, documented by the employer.
5. The person mentioned in point 8.1 conducts monitoring and evaluation of the Standards every two years.
6. Staff Preparation Principles

Staff are prepared by appropriate training on the content and application of the Standards. Training occurs within one week from employment. The person mentioned in point 2 above is responsible for organizing the training.

1. Documentation Methods
   1. Every disclosed or reported case or incident threatening a minor's welfare is recorded in the register maintained by the Hotel Director.
   2. Every entry initiates a review and possible update of the Standards.

Guidelines for the Child Protection Policy Considering Minors with Special Educational Needs, Including Disabilities

1. The Hotel commits to considering the situation of children with disabilities and special educational needs by adapting the guidelines in Annex 8 to the facility's specifics and scope of operation.

Annex 1

Scope of employee/collaborator/intern data needed for Registry checks

Register of Sexual Offenders.

First and Last Name: _________________________

Date of Birth: _________________________

PESEL: _________________________

Maiden Name: _________________________

Father's Name: _________________________

Mother's Name: _________________________

Register available at: https://rps.ms.gov.pl/

Annex 2

Declaration of No Criminal Record

_______________________
(city, date)

I, the undersigned ___________________, holder of ID card no. ______________, PESEL _______________, hereby declare that I have not been convicted of prohibited acts equivalent to crimes specified in Chapters XIX and XXV of the Penal Code, Articles 189a and 207, and in the Act of July 29, 2005 on counteracting drug addiction, and no other judgment was issued stating I committed such acts or was prohibited from holding certain positions or professions related to upbringing, education, recreation, treatment, psychological counseling, spiritual development, sports, or interests of minors, or caring for them. I also declare no criminal or disciplinary proceedings are pending in this regard. Furthermore, I confirm having reviewed the Standards for the Protection of Minors applicable at the Hotel and commit to abiding by them. I am aware of criminal liability for false declaration.

_______________________________

Legible Signature

Annex 3

Template for Declaration of Countries of Residence

_______________________

(city, date)

DECLARATION OF COUNTRIES OF RESIDENCE

I declare that in the past 20 years I have resided in the following countries other than the Republic of Poland and my country of citizenship: At the same time, I provide information from the criminal registers of these countries for the purposes of professional or volunteer activities involving contact with children / confirmation of no criminal record. I am aware of criminal liability for false declaration.

_______________________________

Legible Signature

Annex 4

Template for Declaration of No Criminal Record for Foreigners

_______________________

(city, date)

Declaration of No Criminal Record

I, ................................................. PESEL number ......................../passport number ...................................., declare that in the country of ……………………. there is no criminal registry / such information is not issued [strike as not applicable]. I declare that I have not been lawfully convicted in the country ..................... for prohibited acts corresponding to crimes specified in Chapters XIX and XXV of the Penal Code, Articles 189a and 207, nor been issued any other ruling stating I committed such acts or subject to a ban from holding certain positions or professions related to upbringing, education, recreation, treatment, psychological counseling, spiritual development, sports, or interests of minors, or caring for them. I am aware of criminal liability for false declaration.

_______________________________

Legible Signature

Annex 5

Template for Declaration on Identification of Minor and Their Relationship with the Adult Accompanying Them at the Hotel.

Child Registration Card

First Name / First name

Last Name / Surname

Document Number / Passport No.

Date of Birth / Date of birth

Degree of Kinship / Degree of kinship

Check-in Date / Arrival Date

Check-out Date / Departure

Date

I declare that I have read the Standards for the Protection of Minors in force at "ARCHE" Joint Stock Company with its registered office in Warsaw, adopted pursuant to Article 22c Section 3 et seq. of the Act of May 13, 2016 on counteracting sexual crime threats and protecting minors. I declare that I have the consent of the minor's legal guardians for care over the minor.

_______________________________

Legible Signature

Annex 6

Template for Declaration of No Criminal Record

Example of a conversation with an adult arriving at the Hotel with a minor:

Staff: Our facility operates the Standards for the Protection of Minors, therefore, at registration, we ask all hotel guests arriving with a minor to present identity documents. Does the minor have an identity document?

If the minor does not have an identity document or after checking the document it is uncertain if the adult is the minor's legal guardian, the minor's situation must be determined by asking the following questions:

Staff:

• What is the minor's name?
• How old is the minor?
• Is the minor related to you, or are you the minor’s legal guardian?
• Do you have authorization/power of attorney from the minor’s guardians to care for the minor?
• May we have the phone number of the minor's guardians for confirmation?

Example conversation with the minor:

Staff:

• What is your name?
• How old are you?
• Where do you live?
• Who is the person you came with/are staying with/traveling with?
• Where are your parents? We’d like to contact them – do you have their phone number?

Annex 7

NOTE! Each situation should be analyzed individually. Not every situation indicates abuse of a minor but vigilance and attention to warning signs are required.

Reception

• Guest refuses to provide personal data of themselves or the minor.
• Guest lacks their own and/or minor’s documents.
• Guest pays cash or with prepaid card, or pays through another person.
• Guest brings gadgets or gifts for the minor.
• Guest arriving with a minor rents a room with, for example, a double bed.
• At registration, the minor shows signs of stress or nervousness.
• Minor arrives at unusual times like during the night or school hours.
• It seems the guest does not want the minor to interact with reception staff.
• Guest arriving with a minor invites other persons who are not hotel guests.
• Guest arriving with a minor has no luggage.
• Guest behaves towards the minor in a sexually suggestive manner.
• Minor is dressed inappropriately for weather, age, or presence of an adult.
• Minor does not know where they are.

Restaurant and Bar

• Guest asks about sexual services for adults, including with young people.
• Outsiders not registered in the hotel appear to seek clients and offer services.
• Minors wait at tables or bar for an adult who collects them but does not seem to be their parent or guardian.
• Minors appear restless, nervous.
• Adult behaves sexually suggestive towards a minor.
• Visible exchange of money between adult and minor.
• Adult gives alcohol to a child.

Housekeeping

• Refusal to clean the room during the guest’s entire stay when the guest stays with a minor.
• Children left unattended for a long time in the room or not leaving the room at all.
• Adult and minor do not leave the room or leave at times when few guests are moving around the Hotel.
• Children's clothes or toys are present in the room though no minor is registered.
• Alcohol or drugs are noticed in a room where a guest stays with a minor.
• Visible condoms or similar items in the room where the guest is registered with a minor.

Annex 8

GUIDELINES FOR THE CHILD PROTECTION POLICY CONSIDERING MINORS WITH SPECIAL EDUCATIONAL NEEDS, INCLUDING DISABILITIES.

1. General Principles
2. Every minor should be treated with due respect, without discrimination based on any attribute, including special needs, disabilities, race, gender, religion, skin color, national or ethnic origin, language, marital status, sexual orientation, health status, age, abilities, political beliefs, or social status.
3. Show care for the welfare and development of all minors.
4. Consider universal design, reasonable accommodations, and modifications, ensuring equal access for persons with special educational needs, including disabilities.
5. Eliminate barriers hindering minors’ independent functioning and expression, including informational, architectural, and digital barriers.
6. Staff-related recommendations - general rule:
   1. It is recommended to ensure the presence of a person trained and skilled in providing first aid at the Hotel.
   2. All assistance provided to minors with special educational needs, including disabilities, must comply with applicable law and prioritize the minor’s best interest.
   3. Any form of ridicule, discrimination, humiliation, intimidation, defamation, exclusion, or other psychological, physical, or sexual violence must be counteracted. Immediate response to such situations, including among minors, is required.
   4. Support for self-care activities should be provided in a manner preventing discomfort, humiliation, or ridicule by others, ensuring safety, privacy, and oversight by staff.
7. In case of suspicion or disclosure of harm, always give minors the opportunity to speak and express their opinion, understanding this may be their first and only chance to seek support. It is especially important to:

• express concern by assuring the minor they are believed;
• reassure the minor that talking about the harm was the right thing to do;
• explain the minor is not responsible for the situation;
• clearly condemn all forms of violence, signaling it is unacceptable and must be prevented/stopped;
• appropriately inform the minor that others will handle the matter and inform them of the protective actions taken;
• assure the minor that they are not to blame for what happened.

1. Prohibited Staff Behaviors

• Discussing the minor’s situation, including family or health matters, in the presence of unauthorized persons;
• Making disparaging comparisons with others;
• Isolating the minor in closed rooms, holding doors, restricting movement by tying; use of coercion allowed only under mental health law and its procedures;
• Deliberately provoking difficult or undesirable behaviors in the minor;
• Over-assisting or closely supervising beyond necessary self-care or hygiene activities;
• Ignoring or superficially addressing the minor’s reported needs for support or help;
• Passive staff attitude in caring for the minor’s development and protection when well-being is at risk.

1. Procedure for Responding to Difficult, Aggressive, or Violent Behavior by a Minor. The aim is to ensure the safety of all minors and adults present during situations threatening health, safety or life.
   1. Scope of Application:

• physical assault on others;
• psychological violence, violation of personal dignity;
• fighting, beating;
• creating threats to the health or life of self or others;
• threats of violence;
• use of dangerous objects;
• property damage.

1. Scope of Responsibility:

• every staff member may notice or be informed about acts of aggression or violence;
• every staff member must react in aggressive or violent situations (witnessing or informed) by attempting to stop the situation;
• ensure the safety of persons involved: witnesses, victim, aggressor – isolate them;
• the reaction procedure includes informing the designated intervention officer, who will take overall responsibility for the matter, or another decision-maker (e.g., director, specialist).