CHILD PROTECTION STANDARDS

CHILD PROTECTION STANDARDS IN VHM HOTEL MANAGEMENT HOTELS
Preamble

Bearing in mind the content of the United Nations Guiding Principles 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, Satoria Group adopts this document as a model for policies and procedures in the event of suspected harm to a child who is present in the VHM Hotel Management facilities and in order to prevent such threats.

We will implement our Group’s child protection standards through these principles.

The VHM Hotel Management conducts its business with the utmost respect for human rights, in particular the rights of children as vulnerable persons.
The VHM Hotel Management recognises its role in running a socially responsible business andpromoting desirable social attitudes.
In particular, the VHM Hotel Management stresses the importance of the legal and social obligation to notify law enforcement authorities whenever a crime is suspected to have beencommitted against children and is committed to training its staff in this regard.
The VHM Hotel Management is committed to educating staff on circumstances indicating that a child in the facility may be abused and how to respond quickly and appropriately to such situations.
One way to effectively prevent child abuse is to identify the child in the facility and his/her relationship to the adult with whom he/she is in the facility. Staff take all possible steps to carry out identification of the child and their relationship with the adult with whom they are in the facility.

Explanation of terms

Child – any person under the age of 18;

Register – Sexual Offenders Register;

KRK – National Criminal Register;

Employee – a person employed by the VHM Hotel Management regardless of the form of employment or a cooperating person;

Child’s guardian – the person entitled to represent the child, in particular the child’s parent or legalguardian. Under this document, a foster parent is also a guardian;

Parental consent means the consent of at least one of the child’s parents/legal guardians. However, if there is no agreement between the child’s parents, the parents should be informed that the matter must be decided by the family and guardianship court;

Endangering the safety of a child or harming a child is to be understood as the commission of an offence or criminal act to the detriment of a child by any person, including an employee or associate of the organisation, a parent/legal guardian of a child or by another child, the use of violence against a child in any form or a threat to the welfare of a child, including neglect;

Offence is human behaviour that is considered socially harmful and therefore prohibited by law (mainly the Penal Code, but also many other laws, such as the Anti-Drug Addiction Act);

Criminal act is human behaviour deemed to be socially harmful which would constitute a criminal offence if committed by a person over the age of 17. A person under the age of 17 (a minor) is not subject to criminal liability, but is liable for their behaviour to the family court under the juvenile procedure. Juvenile proceedings aim to educate the offender, not to punish him;

Person responsible for the Child Protection Policy, also known as the Juvenile Protection Standards Coordinator (also referred to as the SOM Coordinator), is an assigned employee or associate working by virtue of their role, appointment or permanent contract, who oversees the implementation of the Child Protection Policy to protect children from harm at the facilities;

Facility – a hotel belonging to the portfolio of the VHM Hotel Management.

Child abuse – actions qualified as:

an offence against a child (e.g. sexual abuse, child harassment);
another form of harm that is not criminal, such as shouting, physical punishment, humiliation;
neglect of the child’s vital needs (e.g. related to nutrition, hygiene or health);

§ 1. Action to prevent child abuse

Whenever and wherever possible, the child and their relationship with the adult with whom they are in the facility should be identified.
In unusual and/or suspicious situations indicating a possible risk of child abuse, identification is compulsorily carried out by a member of the reception staff.
In order to identify the child and their relationship to the person with whom they stay in the facility, you should:
Once the matter has been clarified in a positive way, you should thank for time taken to make sure the child is well looked after and emphasise once again that the procedure is designed to keep children safe.
Ask about the child’s identity and the child’s relationship to the person with whom they have arrived at or are staying at the facility. You may ask for the child’s identity card or other proof that an adult has custody of the child in the facility¹. If no identity document is available, you may ask to give the child’s details (name, address, PESEL number).
1. In the absence of documents indicating the relationship between the child and the adult, the adult and the child should be asked about this relationship.
1. If the adult is not the child’s parent or legal guardian, ask if they have a document showing parental consent for the adult to travel with the child.
1. If the adult does not have a parental consent document, ask for the telephone number of the above to call and confirm that the child is on the premises with a strange adult with the knowledge and consent of the parents/legal guardians2.
In the event of resistance from an adult to show the child’s document and/or indicate the relationship, it should be explained that the procedure is designed to ensure the safety of children using VHM Hotel Management facilities and has been developed in consultation with NGOsworking on the subject.
In the event that the conversation does not dispel doubts about suspicion towards the adult and their intentions to harm the child, the manager and security staff (if they are on the premises at the time) should be discreetly informed. In order not to arouse suspicion, you can, for example, say that you

Such a document may be: the child’s identity document indicating the child’s relationship (identity card) or another document allowing the child to be identified (passport, school ID card), possibly additionally a birth certificate, a certificate confirming the assigning of a PESEL number, a court ruling on custody of the child, a notarised consent of the parent to travel with the child.
You cannot be sure that the telephone numbers given belong to the child’s parents or that on the other end of the there is a parent. Such an action is aimed at observing the behaviour of the adult to the request and their willingness to cooperate to clarify the matter. If there is any doubt, the SOM Coordinator or facility manager should be notified.

need to use the equipment at the back of reception, asking an adult to wait with the child in the lobby, restaurant or elsewhere.

From the moment the first doubts arose, both the child and the adult should be supervised by staff at all times and not left alone.
The manager who has been alerted to the situation will decide whether to notify the police or, if in doubt, take over the conversation with the suspect adult for further clarification.
If the conversation confirms the suspicion of an attempted or committed offence against the child, the manager shall notify the police. Further, the procedure is followed in the case of circumstances indicating a child abuse.
If unusual and/or suspicious situations are witnessed by employees in other departments of the facility, e.g. cleaning service, room service, bar and restaurant staff, relaxation area, security, etc.,they should notify their supervisor immediately, who will decide on appropriate action to be taken.
Depending on the situation and location, the supervisor verifies how much of the suspected child abuse is justified. To this end, the supervisor shall choose appropriate measures leading to clarification of the situation or shall decide to intervene and notifies the police.

§ 2 Actions in case of circumstances indicating a child abuse

If you have a reasonable suspicion that a child in the facility is being abused, notify the police immediately by calling 112 and describing the circumstances of the incident. Depending on the dynamics of the situation and circumstances, the call shall be made by the person who directly witnesses the incident (employee/supervisor). If the notifier is an employee, they shall simultaneously inform their supervisor of the incident.
Reasonable suspicion of child abuse occurs when:
1. the child has disclosed the fact of abuse to a member of staff at the facility;
1. an employee observed harm;
1. the child shows signs of abuse (e.g. scratches, bruises) and, when asked, responds incoherently and/or chaotically and/or becomes confused or there are other circumstances that may indicate abuse, e.g. finding child pornography in an adult’s room.
In this situation, the child and the person suspected of child abuse should be prevented fromleaving the premises.
In justified cases, a citizen’s arrest of a suspect may be made. In such a situation, the person should be kept under the supervision of two staff members in a separate room away from the view of other guest until the police arrive.
In all cases, the safety of the child must be ensured. The child should be in the care of a member of staff until the police arrive.
Where there is a reasonable suspicion that a criminal offence involving contact between a child and biological material of the perpetrator (sperm, saliva, epidermis), the child should be prevented as far as possible from washing and eating/drinking until the police arrived.

Once the police have collected the child, the CCTV footage and other relevant evidence (e.g.documents) relating to the incident should be secured and, if requested by the law enforcement, a copyshould be forwarded by registered letter or in person to the public prosecutor or the police.
The actions taken should be described in the intervention sheet (Annex 1)

§ 3 Juvenile Protection Standards Coordinator (SOM)

Each facility shall appoint a SOM Coordinator.
The tasks of the SOM Coordinator include, in particular:
1. proper monitoring of standards in operation;
1. once every 2 years to assess the standards of protection of minors, to report conclusions and updates in this regard;
1. staff training on the Standards for the Protection of Minors and

keeping appropriate records in this regard;

describing any interventions and incidents reported (Annex 1);
- securing evidence if a crime is committed;
- being responsible for the proper implementation of the procedure;
- liaising with the HR department regarding hiring to be checked against the KRK and the Register;
- notifying the guardianship court, the police or notifying a person who will be authorised to make such a notification to the court/police.
The SOM Coordinators are appointed by the Management Board of the Company.
Training on the Standards for the Protection of Minors is documented in the training register (Annex2).

§ 4 Employment of persons to work with children who are guests of the facilities

All persons working directly with children must be safe for them, which means, among other things, that their history should indicate that they have not harmed any child in the past.
A list of positions involving direct contact with children was published in the Board Member’scommunication of 12 March 2024 (re. VHM Hotel Management Sp. z o.o.) and of 13 March 2024 (re.Satoria Group SA).
All staff working with children, including those who may have potential direct contact with children, should declare that they have no criminal record and that they are not being prosecuted for acts against children – Annex 3.
Any person already employed by the VHM Hotel Management in a position specified in the §4 item 2 must be checked with the KRK and the Register. Checking a person in the Register is done by printing out the results of a search for a person in the Register with restricted access, which is then added to the personal file of such person.

The check referred to in § 4 item 4 must be repeated annually. The range of data necessary forchecking is included in Annex 4.
Prior to commencement of employment, the persons newly recruited for the positions mentioned in § 4, item 2 shall present an excerpt from the KRK (National Criminal Register) about not having a criminal record. Verification of the person in the Register is carried out in accordance with § 4 item 4.
Directors of the VHM Hotel Management facilities or Juvenile Protection Standards Coordinatorsinform by email the HR Department: kadry@satoriagroup.pl, kadry@vhmhm.pl about persons listed in § 4 items 2 and 4 who are subject to verification in the Registers listed in § 4 items 4 and 6.
The human resources department is responsible for checking the above-mentioned persons against the KRK and the Register, and the relevant certificates shall be included in the employee’s personal file.
The verification diagram is attached as Annex 5.

§ 5 Juvenile trainees

In the case of minors doing their apprenticeship at the VHM Hotel Management, all persons having direct and indirect contact with a trainee are subject to checking in the KRK and the Register.
The list of positions with direct contact with juvenile trainees was published in the announcement of the Board Member dated 12 March 2024 (re. VHM Hotel Management Sp. z o.o.) and 13 March 2024 (re. Satoria Group SA).
The list of positions and persons who have indirect contact with juvenile trainees is defined by the Directors of Facilities or the Coordinators of the Standards for the Protection of Minors.
All staff working with minors, including those who may have potential direct contact with children, should declare that they have no criminal record and that they are not being prosecuted for acts against children – Appendix 3

Any person already employed by the VHM Hotel Management in a position specified in the § 5 item 2 as well as the person in indirect contact with juvenile trainees must be checked in the KRK and the Register. Checking a person in the Register is done by printing out the results of a search for a person in the Register with restricted access, which is then inserted into the personal file of the person in question.

Prior to commencement of employment, the persons newly recruited for the positions mentioned in § 5, item 2 shall present an excerpt from the KRK about not having a criminal record. Verification of the person in the Register is carried out in accordance with § 5 item 4.
Directors of VHM Hotel Management facilities or Juvenile Protection Standards Coordinators inform by email the HR Department kadry@satoriagroup.pl, kadry@vhmhm.pl about the persons listed in § 4items . 2 and 4 who are subject to verification in the Registers listed in § 5 item 5.
The human resources department is responsible for checking the above-mentioned persons in the KRK and the Register, and the relevant certificates are included in the employee’s personal file.
The verification diagram is attached as Annex 5.

§ 7 Rules of communication with children guests or juvenile

trainees

The staff shall not contact children via private communication channels (telephone, email, text message) without the knowledge and consent of their legal guardians.
1. In the case of situations involving a apprenticeship at VHM Hotel Management facilities, the staff contact the child’s legal guardians first and then, with their consent, the child. It is recommended that such contact be in documented form (text message, e-mail).
1. The staff shall not have private conversations with children using social media.
1. If a private social media conversation is initiated by a child themselves, the member of staff shall not continue the conversation and shall instruct the child to report to him or her at the place of work orpass the contact to a legal guardian. This rule does not apply to situations of (even potential) danger to the child’s life and health. In this case, the employee may continue the conversation, but must at the same time inform the supervisor or the organisation’s management of the contact with the child and the reasons for the contact. Notification should be made in writing or by email where possible.

§ 8 Peer abuse

If a child is suspected of being abused by another child on the premises either as a visitor or a trainee, the child suspected of abuse and their carers should be interviewed, and the child being abused and their carers should be interviewed separately. In addition, you should talk to other people with knowledge of the incident. The interviews should seek to establish the course of the incident, as well as the impact of the incident on the abused child’s mental and physical health. The findings shall be written down on an intervention sheet (Annex 1). Separate intervention sheets shall be drawn up for the abused and the abused child.
A remediation plan should be developed jointly with the parents/carers of the abuser child with the aim of changing the undesirable behaviour.
A plan should be developed with the parents/guardians of the child being abused to ensure the child’s safety, including ways to isolate the child from sources of danger.
During interviews, it should be ensured that the child suspected of abusing another child is not themselves being harmed by parents/carers, other adults or other children. If such a circumstance is confirmed, the procedure described in § 2 shall apply.
If the suspected abuser is a child between 13 and 17 years of age and their behaviour constitutes an offence, the locally competent family court or the police shall also be notified in writing.

If the suspected abuser is a child over 17 years of age and their behaviour constitutes an offence,the locally competent police or prosecutor’s office shall also be notified in writing.