Minor Protection Standards

I. General Principles

1. Given the need to ensure that minors are adequately protected during their stay at a hotel facility belonging to the Dr Irena Eris SPA Hotel Group, these "Standards for the Protection of Minors in the Dr Irena Eris SPA Hotel Group", hereinafter referred to as the Standards, are hereby adopted.
2. Whenever the Standards refer to:
   1. Hotel – means any hotel facility that is part of the Dr Irena Eris SPA Hotel Group, i.e., the Dr. Irena Eris SPA Hotel in Krynica-Zdrój, the Dr Irena Eris SPA Hotel in Wzgórza Dylewskie, and the Dr Irena Eris SPA Hotel in Polanica-Zdrój,
   2. Hotel director – means the person managing a given hotel of the Dr. Irena Eris SPA Hotel Group,
   3. Hotel employee – means a person employed by the Hotel, regardless of the type of contract under which they perform work at the Hotel,
   4. Minor – this refers to a person who has not reached the age of 18.
3. At every stage of implementing the procedures set forth in the Standards, it is important to keep in mind that they may cause inconvenience to hotel guests ; therefore, staff should show understanding for guests’ reactions to these procedures and explain to them the necessity – both practical and legal – of carrying out these procedures at the hotel. However, a hotel guest’s reaction must not serve as a reason to deviate from the procedures.
4. All procedures provided for in the Standards must be applied in a reasonable manner, taking into account all relevant circumstances, while respecting the dignity and privacy of the minor and the adult with whom the minor is staying at the Hotel.
5. Hotel employees should take into account the emotional and intellectual development of minors when interacting with them, and should consider this circumstance in cases where a minor has a disability or special educational needs.

II. Policies ensuring safe relationships between Hotel employees and minors, and in particular prohibited conduct toward minors

1. Any contact between a Hotel employee and a minor staying at the Hotel should not go beyond interactions justified by the Hotel employee’s official duties.
2. It is unacceptable for Hotel employees to subject a child to physical, psychological, or sexual abuse, cyberbullying, or neglect in any form.
3. A Hotel employee’s interactions with a minor should be of a professional nature and related to the performance of the employee’s duties. It is unacceptable to use a professional relationship to establish private relationships or contacts with a minor that are unrelated to the minor’s stay at the Hotel or the Hotel’s services.
4. It is recommended to avoid being alone with a minor in private spaces, such as a hotel room. If a work-related situation requires contact with a minor in such a place, the employee should, to the extent possible, ensure transparency and safety during the interaction.

III. Rules and Procedures for Identifying a Minor Staying at the Hotel and their relationship to the adult with whom they are staying at the Hotel

1. The Guest Relations Department staff are responsible for identifying minors and determining their relationship to the adult with whom they are staying at the Hotel.
2. Such identification is based on a statement from the adult staying at the Hotel with the child, confirming the child’s information and specifying the relationship between the adult and the child.
3. If a guest refuses to complete the declaration referred to in Section III, paragraph 2 above, the Hotel will refuse to check the guest in.
4. If, during the procedure described in Section III, paragraph 1, a Guest Relations Department employee has reasonable doubts regarding the relationship between a minor and the adult with whom the minor is staying at the Hotel, the Hotel Manager, Deputy Manager, or supervisor must be discreetly notified. Both the minor and the adult should remain under the supervision of Hotel staff during this time.
5. Identification procedures should be carried out in a manner that is discreet, respecting the dignity and privacy of both the minor and the adult.

IV. Policies and procedures for responding to a reasonable suspicion, if the welfare of a minor on the Hotel premises is at risk

1. If there is a reasonable suspicion that the welfare of a minor on the Hotel premises is at risk, every Hotel employee is required to respond to this situation and take appropriate action.
2. A reasonable suspicion of harm to a minor exists, in particular, when a Hotel employee observes circumstances that may indicate harm to a minor, when a minor bears marks that may indicate harm, or when the minor himself or herself reports the harm.
3. The actions referred to in paragraph 1 should consist of immediately notify the Hotel Director of the situation; if this is not possible or could cause an unnecessary delay, notify the Deputy Hotel Manager or a supervisor. In situations requiring immediate intervention, the police or other appropriate authorities must be notified.
4. An employee may also take direct action to stop the harm, provided that such an attempt does not endanger the safety of the employee, the minor, or bystanders. The actions of the employee Hotel should remain within the limits of the law, in particular complying with the rules governing self-defense or so-called citizen’s arrest.
5. If a minor discloses abuse, the employee should first and foremost ensure that the child’s safety is maintained, remain calm, listen to the child, and limit the conversation to the information necessary to provide assistance. Do not conduct your own investigation or ask the child for details about the incident. In this regard, staff should refer to the guide "How to Talk to a Child Who Is a Victim of a Crime – Guidelines for Hotel Staff."
6. Until the police or other emergency services arrive, if necessary to ensure the child’s safety, the child should remain under the care of a Hotel employee , from while adhering to safety guidelines and respecting the child’s dignity.

V. Procedures and persons responsible for reporting suspected of a crime committed against a minor and notifying the juvenile court

1. After a Hotel employee reports situations provided for Under these Standards, the Hotel Manager or another person listed in Section IV, paragraph 3, is required to assess the situation and, if the circumstances warrant it, to notify the police or the family court.
2. In urgent situations, every Hotel employee is authorized and obligated to notify the police.
3. The person responsible for receiving reports and coordinating further actions at the Hotel is the Hotel Manager, and in his or her absence, the Assistant Hotel Manager or a supervisor.
4. The incident and the actions taken must be documented in the form of a memo or other documentation accepted by the Hotel, while maintaining confidentiality and adhering to personal data protection rules.

VI. The scope of responsibilities of the person in charge of training Hotel employees to apply the Standards, the procedures for training these employees to apply them, and the method of documenting this activity

1. The persons responsible for preparing Hotel employees to The individuals responsible for implementing the Standards are the Hotel Directors, each within the scope of the hotel they manage, and they are supported in this regard by the Human Resources Manager of Hotele SPA Dr. Irena Eris Sp. z o.o.
2. Hotel employees will have the opportunity to enhance their skills related to the tasks outlined in the Standards through internal training sessions. Upon completing a training session, an employee confirms attendance by signing the attendance sheet and signs the relevant statement.
3. Department of Guest Relations are in particular, familiarized with the rules for identifying minors and determining their relationship with an adult, as well as the rules of conduct in situations that raise doubts.
4. Hotel employees have access to the resource "How to Talk to a Child Victim of a Crime – Guidelines for Hotel Employees."
5. Employees’ familiarization with the Standards, as well as training and updates on these procedures, are documented in accordance with the Company’s established procedures.

VII. Final Provisions

1. At least once every two years, the Hotel Director will evaluate the Standards to ensure they are aligned with current needs and compliance with applicable regulations, and the findings of the assessment will be documented in writing.
2. The Standards apply to all Dr. Irena Eris SPA Hotels and are available on the website www.drirenaerisspa.pl and in paper form in a conspicuous location at the Front Desk of each Hotel, along with an abridged version intended for minors.
3. These standards take effect on August 15, 2026.
4. The standards in this version were adopted following a periodic review of the standards in effect as of August 15, 2024.