Child Protection Standard

at LIM Center sp. z o.o.

Warsaw, 1 October 2024

LIM Center sp. z o.o. operates in the hospitality sector as the owner of Warsaw Presidential Hotel and also provides vocational training placements for students of hospitality and gastronomy technical schools.

We want to ensure safe and comfortable conditions for children and young people during both their training and their stay at our Hotel. In our relations with children, we strive to set proper standards of conduct, both in educational activities and in every contact with a child.

Responsibility for the proper implementation of these Standards rests with the Director of the Human Resources Department.

Definitions

• Child – any person under 18 years of age.
• Student – any person undertaking vocational training at Warsaw Presidential Hotel on the basis of an agreement between LIM Center sp. z o.o. and a vocational school or technical school.
• Supervisor – the internship mentor and any person under whose supervision a student completes vocational training.
• Abuse of a child – any intentional conduct that deliberately causes a child sadness, pain, shame or other negative emotions. This includes, in particular, hitting, humiliating, unfair punishment, or touching in a way that causes the child embarrassment.
• Personnel – all persons working for LIM Center sp. z o.o., regardless of the basis of their employment.
• Register – the register of sexual offenders maintained pursuant to the Act of 13 May 2016 on counteracting threats of sexual crime and protecting minors.

General rules and intervention procedures

1. All members of personnel are obliged to treat children with respect for their dignity.
2. Personnel are obliged to ensure the safety of children staying at the Hotel and students during vocational training. No one is allowed to:
   1. establish physical contact with children that may be considered inappropriate, such as placing children on one’s lap, carrying them on one’s shoulders, or kissing them; however, holding a child’s hand, for example while accompanying them to a room or another place, is not prohibited,
   2. hit a child or cause pain in any way whatsoever, for example by hitting them with a door or an object,
   3. shout at children or raise their voice at them; even if a child behaves improperly, they should be corrected calmly, and in the case of children who are Hotel guests, attention should be drawn to their guardians,
   4. swear in the presence of children or use insulting, offensive or vulgar language,
   5. show children any recorded content containing violence, pornography, vulgarity or other images or sounds that may be harmful, including films, photos, recordings, applications and any content stored on phones, smartphones, laptops, tablets, etc.
3. All personnel of LIM Center sp. z o.o. and the Hotel must remain alert to any signs of child abuse. Special vigilance is required from student supervisors as well as reception and restaurant staff.
4. All suspicions of child abuse or any other suspicious behaviour towards children must be reported immediately to Human Resources staff or directly to the Director of the Human Resources Department. The Director of the Human Resources Department or a designated employee of that department shall immediately undertake explanatory actions and, if it is found that the child’s welfare is at risk, shall notify the Police and/or the child’s legal guardian.
5. In the event of a justified suspicion of a direct threat to a child’s safety, every member of personnel is obliged to notify the Police immediately and only afterwards notify the Director of the Human Resources Department, an HR employee, the Reception Manager or the Manager on Duty. A direct threat to a child’s safety exists in particular where personnel witness abuse or possess credible information about such abuse.
6. Hotel personnel have the right to make a citizen’s arrest of any person with respect to whom there is a justified suspicion that they have committed an offence involving abuse of a child.
7. Any intervention referred to in points 5–6 should be carried out in a manner that minimizes the risk to the child and limits trauma. Wherever possible, the child should be separated from the adult and the detention should be carried out, for example, while the child enters a restroom. The Reception Manager, Manager on Duty, or Director/employee of the Human Resources Department is responsible for the care of the child during the intervention.
8. An intervention shall also be undertaken at the request of a child communicated to an employee, if the circumstances indicate a likelihood that the child is in danger.
9. The Internet network made available on the Company’s premises may be used by children under the supervision of accompanying adults. In the case of students, browsing websites containing pornography, vulgar language or other inappropriate content may constitute grounds for disciplinary measures.

Rules relating to vocational training placements

1. Personnel, especially internship mentors and instructors, shall ensure the safety of students during vocational training placements.
2. Internship mentors and supervisors are obliged to pay attention to disturbing behaviour among students. Students should behave towards one another politely and respectfully. Students may not:
   1. insult one another or use vulgar language towards one another,
   2. use physical violence against one another in any form,
   3. engage in so-called hate behaviour,
   4. disclose information about the private lives of other students if this could be embarrassing or shameful.
3. Students have the right to approach their supervisors or internship mentors in the event of any disturbing behaviour directed towards them.
4. Students have the right to use phones and other devices with Internet access during vocational training placements. Supervisors and internship mentors may inspect content viewed by students on their devices only with the consent of the students’ legal guardians. Such inspection may take place only where there is a justified suspicion that the student is viewing harmful content, in particular pornographic, vulgar or violent material.

Rules relating to hotel guests

1. Hotel personnel are obliged to determine whether a Hotel guest is a child, even if the child’s presence was not reported during room reservation or check-in.
2. Hotel personnel, especially reception staff, shall determine the nature of the relationship between the child and the adult staying with them at the Hotel. If possible, given the child’s age and development, this should also be established directly with the child. This must be done in a way that does not cause the child anxiety or fear.
3. It must be established whether the adult with whom the child is staying at the Hotel is the child’s legal guardian.
4. In case of doubt as to whether the adult staying with the child is the child’s legal guardian, Hotel personnel may request the presentation of:
   1. an identity document of the adult guest and the child, or
   2. a document confirming custody rights, for example a court decision, or
   3. another document confirming the temporary right to care for the child, for example written authorization from the legal guardian.
5. In case of doubt, personnel may ask the adult for contact details of the child’s legal guardian. Personnel shall immediately contact the child’s legal guardian and clarify any doubts regarding custody.
6. If Hotel personnel cannot perform the actions described above, for example due to the objection of the person staying with the child, they must immediately notify the Reception Manager, Manager on Duty or Night Reception Manager, depending on the time of check-in. The notification should be made discreetly so as not to arouse the suspicions of the person caring for the child. The Reception Manager, Manager on Duty or Night Reception Manager shall take further appropriate action, including notifying the Police.
7. In the event of a justified suspicion of child abduction, for example visible fear of the child, lack of the child’s documents, or signs of violence, Hotel personnel shall seek to separate the child from the adult immediately and safely. Hotel security personnel shall make a citizen’s arrest of the person suspected of abducting the child and notify the Reception Manager, Manager on Duty or Night Reception Manager, who shall immediately inform the Police.
8. If a person suspected of abducting a child is detained, Hotel personnel shall ensure proper care for the child, for example in a restaurant, playground, children’s corner or other safe place appropriate to the child’s age, development and condition.

Tasks of the Human Resources Department and other persons

1. The Director of the Human Resources Department or a designated employee of the Human Resources Department is responsible for fulfilling the Company’s statutory obligations, including:
   1. training personnel on these Standards,
   2. checking whether student supervisors, internship mentors and teachers are listed in the restricted-access Register,
   3. placing a summary of the Standards (Appendix No. 1) in visible places at the Company’s premises and the Hotel, especially in areas where children are present,
   4. publishing the current text of the Standards on the Company’s website,
   5. conducting verification activities in the event of suspected abuse of children.
2. Each member of personnel is obliged to familiarize themselves with the content of the Standards and confirm this with their signature.
3. Once a year, the Human Resources Department organizes training on the application of the Standards for all members of personnel. Participation in the training is mandatory for internship mentors, student supervisors, reception staff and security staff. The training programme is determined by the HR employee responsible for the training. The HR employee prepares an attendance list for the training.
4. An HR employee shall make the Standards available upon request to any student, parent of a student, child or guardian.
5. An HR employee shall keep documentation and a register of all reports concerning suspected child abuse and all interventions.
6. Documentation of reports and interventions shall include CCTV recordings, notes prepared by personnel, photographs and any other documents or evidence collected during the intervention. The Manager on Duty / Director of the Human Resources Department may decide to make copies and hand over the originals to the Police or another public authority.
7. The register of reports and interventions shall contain the following data:
   1. date of the report or intervention,
   2. source of the report or intervention (without personal data),
   3. age of the child and the child’s biological sex,
   4. type of incident,
   5. description of actions taken,
   6. effects of the actions taken.
8. Data in the register shall be fully anonymized and stored for a period of 5 years from the date of the report or intervention.

Admission to work with children

1. The provisions of this section apply to members of personnel having direct contact with children, in particular student supervisors, internship mentors and teachers.
2. Before employing or allowing a member of personnel to work with children, a designated employee of the Human Resources Department shall:
   1. check whether the person is listed in the register of sexual offenders – the restricted-access register – through the form available at https://rps.ms.gov.pl/pl-PL/Public#/,
   2. request that the candidate or member of personnel submit a statement indicating the country or countries in which they have resided during the last 20 years, other than the Republic of Poland and their country of citizenship,
   3. request that the member of personnel provide a certificate from the National Criminal Register or an appropriate foreign register confirming no convictions for offences under Chapters XIX (offences against life and health) and XXV (offences against sexual freedom and decency) of the Polish Criminal Code, as well as Chapter 7 of the Act of 29 July 2005 on counteracting drug addiction, or equivalent offences under foreign law; a printout from such register shall be attached to the employee’s personnel file or other personal documentation of the person being employed,
   4. request that internship mentors and teachers of vocational training submit a statement confirming no convictions for offences against family and guardianship, except for the offence of failure to pay child support.
3. If it turns out that a job candidate or member of personnel has been convicted of the offences referred to in point 2 above, or refuses to submit the certificate from the National Criminal Register or the statement referred to in point 2(b) or (c), that person may not be permitted to work with minors.
4. Certificates referred to in section 2 above must have been issued no earlier than 6 months before their presentation.

Support plan

1. Where abuse of a child or other inappropriate conduct is disclosed, the Director of the Human Resources Department or a designated employee of the Human Resources Department shall prepare a support plan for the child. The support plan shall be prepared immediately after the threat has ceased or evidence relating to another incident involving the child has been secured.
2. Depending on the specific case, the following persons may participate in preparing the plan:
   1. the child’s guardian or legal guardians,
   2. the child, if permitted by the child’s age, development and the circumstances of the incident,
   3. a psychologist or educator,
   4. the person who disclosed the incident or abuse,
   5. a lawyer.
3. The child’s support plan may include, in particular, financing by the Company of therapy for the child to an appropriate extent, support in legal proceedings against the perpetrator of the abuse, or any other forms of assistance deemed appropriate in the given case. When developing the support plan, the reasonable expectations of the child should be taken into account.

Entry into force and publication

1. These Standards enter into force on the date they are signed by the members of the Management Board of LIM Center sp. z o.o.
2. Not less than once every two years, the Director of the Human Resources Department or a designated employee of the Human Resources Department shall review the Standards and amend or adapt them to new legal regulations or standards for the protection of minors. The Director of the Human Resources Department or the designated employee shall document the review by signature, including electronic signature, and the verification date on the document.
3. These Standards shall be published on the Company’s website and at the reception desk of the Company’s premises. Together with the full text of the Standards, their summary, constituting Appendix No. 1, shall also be published.

Summary of the Standards for the Protection of Minors – for children

1. No one is allowed to hurt you. No one is allowed to shout at you, hit you, strike you or insult you.
2. No one is allowed to touch you if you do not want them to.
3. If you are afraid of someone or someone is hurting you, you can tell any employee. The staff will help you.
4. Be kind to other children. Do not do to others what you would not like done to you.