LAS WODA Park Rekreacyjno-Biznesowy

Preamble Taking into account the legal obligation resulting from the provisions of the Act of May 13, 2016 on counteracting threats of sexual crime and the protection of minors, as well as the content of the United Nations Guidelines on Business and Human Rights, recognizing the important role of business in ensuring respect for children's rights, LAS WODA Recreational and Business Park adopts the Child Protection Policy. This document constitutes a set of rules and procedures applied in case of suspicion that a child staying in the facility/hotel, network is being harmed and to prevent such threats, taking into account the situation of children with disabilities and children with special educational needs. The child protection policy at LAS WODA is implemented based on the principles listed below:

1. LAS WODA conducts its operational activities with respect for the rights of children as persons particularly vulnerable to harm.
2. LAS WODA acknowledges its role in conducting socially responsible business and promoting desirable social attitudes. LAS WODA particularly emphasizes the importance of the legal and social obligation to notify law enforcement authorities of any suspicion of a crime against children and commits to training its staff in this regard.

Glossary: For the purposes of this document, the meanings of the following terms have been specified:

1. Tourist facilities – hospitality facilities and other facilities where hospitality services specified in the Act of August 29, 1997 on hospitality services and the services of tour escorts and tourist guides are provided.
2. Child/minor - for the purposes of this Policy, a child is any person who has not reached the age of 18 years.[1]
3. Child's guardian – the child's legal representative: parent or guardian; foster parent; temporary guardian (i.e., a person authorized to represent a minor Ukrainian citizen who is staying in the territory of the Republic of Poland without the care of adults)[2]
4. Stranger adult is any person over 18 years old who is not the child's parent or legal guardian.
5. Child abuse means behavior that may constitute the commission of a prohibited act against the child by any person, including a member of the tourist facility staff, or an endangerment of the child's welfare, including neglect; any intentional or unintentional act/omission by an individual, institution, or society as a whole and any result of such action or inaction that violates the rights, freedoms, and personal interests of children and/or disrupts their optimal development.
6. Forms of violence against a child:

●Physical violence against a child is violence resulting in actual physical harm or potential threat thereof. This harm occurs due to actions or omissions by a parent or other person responsible for the child or trusted by the child or who has authority over the child. Physical violence can be repeated or one-time. ●Psychological violence against a child is chronic, non-physical, harmful interaction between a child and caregiver, including actions and omissions. It includes emotional unavailability, emotional neglect, hostile relations with the child based on blame, defamation, rejection, developmentally inappropriate or inconsistent interactions with the child, failure to acknowledge the child's individuality and psychological boundaries between parent and child. ●Sexual abuse of a child involves engaging a child in sexual activity that they cannot fully understand or give informed consent to and/or are not developmentally mature enough to legally consent to and/or that is contrary to the legal or customary norms of the society. Sexual abuse occurs when such activity happens between a child and an adult or between a child and another child if those persons are in a relationship of care, dependency, or power due to age or development. Sexual abuse may also take the form of sexual exploitation, i.e., any actual or attempted abuse of a position of vulnerability, power imbalance, or trust for sexual purposes, including but not limited to financial, social, or political gain from sexual exploitation of another person. Sexual exploitation risks increase during humanitarian crises. Exploitation threats exist for both children and their caregivers (definition per UN Bulletin ST/SGB/2003/13). ●Neglect of a child is the chronic or occasional failure to meet a child's basic physical and psychological needs and/or disregard for their fundamental rights, causing health disorders and/or developmental difficulties. Neglect occurs in relationships where someone is responsible for a child's care, upbringing, concern, and protection.

7. Crime against a child – all crimes that can be committed against adults can also be committed against children, plus crimes that can only be committed against children (e.g., sexual abuse under Article 200 of the Penal Code^[3]). Due to the specific nature of accommodation facilities where isolation is easy, the most common crimes on their premises are against sexual freedom and morality, especially rape (Article 197 PC), sexual abuse of insanity and helplessness (Article 198 PC), sexual abuse of dependency or critical situation (Article 199 PC), sexual abuse of persons under 15 years old (Article 200 PC), grooming (enticement of minors via remote communication means - Article 200a PC).
8. Other forms of child harm than committing a crime against them – all forms of violence against a child that do not meet criminal prosecution criteria (e.g. shouting, humiliation, shaking, insulting, neglect of needs, etc.).
9. Employee means a person employed under an employment contract or performing work under a similar contract (e.g., mandate, B2B, contract for specific work), as well as interns, trainees, volunteers, etc.
10. Employee working with children is any person performing or delegated to perform tasks related to upbringing, education, recreation, treatment, psychological counseling, spiritual development, sports, or other interests of minors, or caring for them.
11. Entrepreneur – an entity/person managing a given tourist facility or network of facilities, responsible for the proper formal functioning of the facility.

CHAPTER I. FACILITY STAFFGeneral principles 1. LAS WODA commits to educating its employees about circumstances indicating that a child staying in the facility may be harmed and how to respond quickly and appropriately to such situations. The facility may conduct this education through various forms of training, e.g., external, internal training, e-learning, educational materials developed by the hotel and available to employees, free educational materials developed by other organizations. 2. Every employee, before being allowed to work, is familiarized with the Child Protection Policy, which is confirmed by their statement and commitment to follow the rules and procedures contained in this document. Appendix No. 1 3. Employees employed to work with children undergo periodic training, which is documented by the employer. 4. LAS WODA commits to considering the situations of children with disabilities and children with special educational needs, adapting the guidelines from Appendix No. 12 to the specificity and scope of the facility's operations. Employment of persons to work with children

1. Persons working with children must show in their employment history that they have never harmed a child in the past.
2. Every person employed/delegated by LAS WODA to work with children must be mandatorily checked in the Register of Perpetrators of Sexual Offenses, which also applies to underage workers under 18 years old. The check is conducted by printing the search results from the restricted-access Register, which is then filed in the person's personnel records. The scope of personal data needed for the check can be found in Appendix No. 3.
3. Furthermore, every person employed/delegated to 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 of the Penal Code, and 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.
4. If the employed/delegated person has citizenship other than Polish, they must also submit information from the criminal register of the country of which they are a citizen, obtained for professional or volunteer activities involving contact with children, or information that such register does not provide such information or does not maintain a criminal register.
5. A statement about countries of residence in the last 20 years other than the Republic of Poland and the country of citizenship must also be obtained from employed/delegated persons, under penalty of criminal liability. Appendix No. 4
6. If the law of the country providing the criminal record does not provide such information or does not maintain such a register, the person must submit a criminal liability statement to that effect. Appendix No. 5
7. Under penalty of criminal liability, a statement containing the following wording is submitted: “I am aware of the criminal liability for making a false statement.” This replaces the authority's instruction on criminal liability for false statements.
8. When using external entities, LAS WODA includes a relevant clause in the contract that enables enforcement of appropriate employee safety screening standards by that entity. This clause allows LAS WODA to control compliance under penalty of immediate contract termination and contractual penalties or other sanctions related to non-fulfillment of contract terms in this area.

Scope of competencies and responsibilities of persons appointed to implement the Child Protection Policy at LAS WODA 1. Supervision of the Child Protection Policy application is conducted by the Entrepreneur 2. The Entrepreneur appoints a coordinator for the Child Protection Policy (hereinafter referred to as the “Coordinator”). 3. The Coordinator is responsible for acquainting employees with the Child Protection Policy and monitoring its application at LAS WODA. 4. The Coordinator organizes and documents employee education in recognizing symptoms that a child in the facility may be harmed and how to respond quickly and properly, according to procedures adopted by the facility. 5. The Coordinator documents each intervention or reported incident of child abuse within the facility in a dedicated document (e.g., incident log or intervention register). 6. In case of justified suspicion of a crime, the Coordinator is responsible for securing evidence, including monitoring recordings, and handing them over upon request by authorities by registered mail or personally to the prosecutor or police. 7. The Coordinator leads procedures in situations where a child has been harmed by a facility employee or another adult not directly employed by LAS WODA but by a third party. 8. The Coordinator monitors and updates the Child Protection Policy and ensures its availability among employees and other cooperating entities and guests. 9. The Coordinator's contact details must be available to all employees and guests, including children, and include information on how to contact the Coordinator (email address, phone, availability: days and working hours). Safe employee-child relations principles

1. The following principles must be applied by all employees of LAS WODA and also by other adults who have contact with children on the premises if this contact is authorized by the facility.
2. The foremost principle of all activities by employees interacting with children on the premises of facility/hotel name, hotel network is to treat the child with respect and consider their dignity and needs.
3. It is unacceptable for employees and other adults to use any form of violence against a child.

1. Expected behaviors and practices from employees

●Show patience and respect in communicating with the child. ●Listen attentively to the child and respond appropriately to their age and situation. When communicating, keep your face at the child's eye level. ●Assure the child that if they feel uncomfortable, they can tell you or another designated person and get help. ●Inform the child where the Child Protection Policy is available at LAS WODA in an understandable version. Assure them they can ask you or another designated person questions. ●Respect equal treatment of all children regardless of gender, sexual orientation, disability, social status, ethnicity, culture, religion, or worldview. ●Ensure a safe environment. When children are in your work area, make sure equipment is used correctly and surroundings are safe (e.g., secure windows and stairs, limit access to busy roads, open water, etc.). ●If you see unattended children, and the situation may threaten their safety, take steps to find a parent/guardian.

2. Unacceptable behaviors and practices by employees towards children in the facility

●You must not shout at, embarrass, humiliate, ignore, or insult a child. ●You must not hit, push, shove, or physically harm a child unless the child's health or life is at risk. ●You must not establish any romantic or sexual relationships with a child or make inappropriate proposals. This includes sexually explicit comments, jokes, gestures, and sharing erotic or pornographic content with children in any form. ●You must not record or photograph a child for private or official purposes without parental/guardian and child consent. This also applies to allowing third parties to record children. An exception is when a child's image is only a detail of a larger scene (e.g., gathering, landscape, public event), no consent is needed. ●You must not contact a child through private communication channels (phone, email, messengers, social media) nor meet outside work. ●You must not offer the child alcohol, tobacco products, or illegal substances. ●Never touch a child if they do not want it or in a way that could be considered indecent or inappropriate. If you witness any of the above behaviors or situations by other adults or children, always inform the person responsible at the facility for implementing and monitoring the Child Protection Policy or your direct supervisor:please specify the position and contact details for reporting child abuse by an employee, another adult, or peerCHAPTER II. PROCEDURE FOR IDENTIFYING A CHILD DURING RECEPTION REGISTRATION

1. One form of effective prevention of child abuse is to establish the identity of a child staying in the tourist facility and their relationship to the adult accompanying them.
2. The reception staff takes all possible steps to identify the child and their relationship with the accompanying adult.
3. To identify the child and their relationship with the accompanying person, you should:
   1. ask for the child's identity document or other proof that the adult has the right to care for the child. Examples of documents: ID card, school ID, MObywatel app, Internet Patient Account, court decision. If no ID or refusal to show it, ask for child's details (name, surname, address, date of birth).
   2. If no documents proving the relationship or refusal, ask the adult and the child about the relationship. A sample conversation scheme is in Appendix No. 2.
   3. If the adult is not the child's parent or legal guardian, ask them to show a document, e.g., a parent's notarized written consent for the person to travel with the child, indicating child data, address, parent's phone, and the ID/PESEL of the person entrusted with care. If none of these documents are available, ask to fill a statement prepared by the tourist facility, including child and adult data and their relationship. The adult must declare that parents/legal guardians consented to the care.
4. If the adult refuses to show the child's document or indicate the relationship, explain that the procedure is to ensure the safety of children using LAS WODA and that according to the Act of May 13, 2016, facility employees must follow child rights provisions. After a positive explanation, thank them for the time spent ensuring the child's good care.
5. If doubts about the adult’s suspicion and intention to harm a child remain, especially if the adult refuses to show ID or statement, discreetly notify the supervisor and security staff (if present), without arousing suspicion (e.g., refer to the need to use equipment backstage and ask the adult to wait in the lobby, restaurant, or elsewhere).
6. From the moment doubts arise, both the child and adult should, if possible, remain within employee sight and not be left alone.
7. The supervisor notified of the situation takes over the conversation with the suspicious adult to obtain further explanations.
8. If the conversation confirms suspicion or crime against the child, the supervisor notifies the police and follows the procedure for suspected child abuse (see Chapter III).
9. If employees of other departments (LAS WODA, e.g. cleaning, room service, bar and restaurant staff, relaxation zone, security, etc.) witness unusual or suspicious situations, they should immediately notify their supervisor or, if absent, a decision-maker who will take appropriate action (see points 7 and 8 above).
10. Depending on the situation and place, the supervisor assesses the validity of the suspicion and decides on investigation means or intervention and informs the police.

CHAPTER III. PROCEDURE IN CASES INDICATING CHILD ABUSE BY AN ADULT

1. Justified suspicion of child abuse occurs when:

10. 1. the child has disclosed the abuse to the facility staff,
    2. the staff has observed the abuse,
    3. the child shows signs of abuse (e.g., scratches, bruises), and their answers are inconsistent and/or confused and/or embarrassed, or other circumstances indicate abuse, e.g., pornography materials with children found in the adult’s room.

2. An employee who has justified suspicion that a child in the facility is or has been abused should immediately notify their supervisor/decision-maker, who notifies the police. In case of existing threat to child safety, the employee must immediately call 112 and describe the situation. Independently, the employee notifies the Facility/Hotel, Network Coordinator.
3. Efforts should be made to prevent the child and suspected abuser from leaving the facility.
4. Under the Code of Criminal Procedure, citizens may detain a suspect. Until police arrive, the detainee stays under supervision of security or other hotel staff who can perform this safely.
5. In every case, the child's safety must be ensured. The child, if possible, should be cared for by an employee until police arrive. Support should be offered to the child (Appendix No. 10).
6. If there is suspicion of a crime involving the contact of the child with the perpetrator's biological material (sperm, saliva, skin), the child should not wash or eat/drink until police arrive, and an explanation should be given.
7. After police take the child, monitoring footage and other evidence (e.g., documents) must be secured and passed to the Coordinator, who will provide copies to authorities on request.
8. After intervention, the incident should be reported to the Coordinator for recording in the incident log or appropriate document.

CHAPTER IV. PROCEDURE IN CASE OF SUSPECTED OR CONFIRMED CHILD ABUSE BY AN EMPLOYEE/OTHER ADULT

1. If child abuse is suspected by an employee or another adult not directly employed by LAS WODA but by a third party, the person who learned this information must immediately inform the Coordinator or, in their absence, another assigned person.
2. If the child's life or health is threatened, the person must immediately notify police by calling 112, providing their own and the child's data (if possible), location, description of circumstances, and inform the supervisor/decision-maker, who informs the child's guardians/parents. The person must also notify the Coordinator at least by email or in writing.
3. If an employee commits a form of child harm other than a crime, the Coordinator investigates all circumstances, especially hearing the accused employee and witnesses. If the child's wellbeing is seriously violated, especially in cases of discrimination or dignity violation, the Coordinator recommends appropriate personnel actions.
4. If the perpetrator is employed by a third party (e.g., outsourcing), the Coordinator recommends banning their access to LAS WODA and, if necessary, terminating the third-party contract.

CHAPTER V. PROCEDURE IN CASE OF CONFIRMED OTHER FORMS OF VIOLENCE AGAINST A CHILD BY A PARENT/LEGAL GUARDIAN/OTHER ADULT

1. If a child is harmed by a parent/legal guardian or another adult staying with the child on the premises, every employee witnessing abuse should strongly intervene.
2. If the child's life or health is threatened, the person must immediately notify police by calling 112, providing their own and the child's data (if possible), location and description, and informing the supervisor/decision-maker. The person must also notify the Coordinator in writing or by email.
3. If an employee witnesses physical violence against a child (slaps, shaking, shouting, other forms mentioned in definition), they should try to stop and react. Possible responses are in Appendix No. 11.
4. If a child under 7 is left unattended, the employee who learned this should notify the supervisor, who decides on further actions regarding Penal and Misdemeanor Codes^[4]. The supervisor tries to find the parent/legal guardian or other adult and explains that leaving the child unattended is not allowed. If this is impossible or the responsible person refuses or cannot care for the child, the supervisor notifies the police. The child's safety must always be ensured.

CHAPTER V: MONITORING AND EVALUATION OF THE CHILD PROTECTION POLICY

1. The Entrepreneur appoints the Coordinator responsible for the Child Protection Policy applied at LAS WODA and posts their contact details in a place easily accessible to staff and guests, including children.
2. The Entrepreneur defines the Coordinator's tasks and competencies regarding staff preparation for applying the Child Protection Policy, the principles of preparing staff to comply and how to document these activities.
3. The Coordinator mentioned above conducts monitoring and evaluation of the Child Protection Policy every two years.
4. Monitoring and evaluation include verifying Policy implementation, responding to violation signals, and proposing document changes, especially to suit current needs and legal requirements.
5. The Coordinator conducts a survey among employees of facility/hotel name, hotel network every two years to monitor Policy implementation. The survey template is in Appendix No. 6.
6. Employees may propose changes and indicate violations of rules and procedures of the Child Protection Policy at LAS WODA in the survey.
7. The Coordinator analyzes the completed surveys, prepares a monitoring report, and submits it to the Entrepreneur, who implements necessary changes and announces the new Policy wording to employees.

[1] According to Polish law, a child is every person under eighteen (Article 1 of the Convention on the Rights of the Child adopted by the United Nations General Assembly on November 20, 1989). A minor is a person not of legal age, i.e., under 18, or a woman who attained legal age through marriage after 16 (Articles 10 § 1 and 2 of the Civil Code), which may occur by court permission for valid reasons if marriage aligns with family welfare (Article 10 § 1 Family Code). [2] Parents – Article 98 Family and Guardianship Code; Guardian – Article 155 Family and Guardianship Code; Foster parent – Article 1121 Family and Guardianship Code; Temporary guardian; Article 25 Act on assistance to Ukrainian citizens related to the armed conflict on their territory. ^[3] Act of June 6, 1997 Penal Code (Journal of Laws 2022 item 1138 with subsequent amendments). ^[4] Penal Code articles 160 par.1 and 2; 210 par.1, Misdemeanor Code article 106