MINORS' PROTECTION STANDARDS introduced in Zagrywki – Activity Bar
§ 1
These MINORS' PROTECTION STANDARDS use the following terms and definitions:
1. Company – this shall be understood as Absolut sp. z o.o.
2. Employee – a person employed by the Company under an employment contract or a mandate contract.
3. Minor – any person under 18 years of age.
4. Guardian of a minor – a person authorized to represent a child, in particular their parent, legal guardian, or foster parent.
5. Statutory representative – this shall be understood as a parent or guardian with full parental authority or a legal guardian (a person representing a child, appointed by a court, in a situation where the parents do not have parental authority or where the parents are deceased). 6. Consent of the minor's guardian – consent of at least one of the child's parents, and in the absence of agreement between the child's parents, the decision on consent is made by the family court.
7. Harming a minor – the commission of a prohibited act or a criminal act to the detriment of a minor by any person, including an employee of the Company, or a threat to the child's well-being, including through neglect or failure to fulfill an obligation.
8. Personal data of a minor – this shall be understood as any information
enabling the identification of a minor using the Zagrywka – Activity bar services.
9. SOM Coordinator – this shall be understood as the designated Employee
supervising the implementation of these Standards.
1. PRINCIPLES OF SAFE RELATIONSHIPS BETWEEN MINORS AND EMPLOYEES
§ 1
1. The principles set forth in this document apply to all persons employed by the Company, regardless of the basis of employment. The rules also apply to individuals
undergoing internships, volunteers, and individuals and legal entities cooperating with
the Company under separate agreements (e.g., individuals organizing sports activities, events
or parties at the Company's place of business).
2. Company employees confirm that they have read the standards for the protection of minors in
a declaration.
3. New Company employees are familiarized with the standards immediately, but no later
than during their first week of employment. 4. The Company applies safe recruitment principles in accordance with the requirements of generally applicable laws, in particular by checking the criminal records of individuals who will have contact with minors as part of their official duties in appropriate registers, i.e.:
1) Before entering into an employment relationship with an individual or before admitting an individual to other activities related to the upbringing, education, recreation, or care of minors, information is obtained as to whether that individual's data is included in the Registry with limited access or the Registry of Persons for whom the State Commission for Counteracting the Sexual Exploitation of Minors under the age of 15 has issued a decision to enter the Registry;
2) Information on the candidate's criminal record is collected from the National Criminal Register; 3) If the candidate holds a citizenship other than Polish, they should also submit information from the criminal record of the country of which they are a citizen, obtained for the purposes of professional or volunteer activities related to contact with minors, or information from the criminal record if the law of that country does not provide for the disclosure of information for the above-mentioned purposes;
4) The candidate is required to submit a declaration regarding the country(ies) (other than the Republic of Poland) in which they have resided in the last 20 years, under pain of criminal liability; 5) If the law of the country from which the information on criminal record is to be submitted does not provide for the issuance of such information or does not maintain a criminal record, then the candidate shall submit, under penalty of criminal liability, a declaration of this fact, together with a declaration that he/she has not been convicted by a final judgment and that no other judgment has been issued against him/her in which it was found that he/she has committed such prohibited acts, and that he/she is not obliged, under a court decision, other authorized body or statute, to comply with a ban on occupying any or specific positions, performing any or specific professions or activities related to the upbringing, education, recreation, treatment, provision of psychological counseling, spiritual development, practicing sports or pursuing other interests by minors, or with caring for them; 6) A statement with the following content is submitted under penalty of perjury: "I am aware of criminal liability for submitting a false statement. This statement replaces the authority's notice of criminal liability for submitting a false statement."
5. A sample declaration of no criminal record and a commitment to comply with these Standards for the Protection of Minors is attached as Annex 1 to these Standards.
§ 2
1. Principles of Safe Relationships between Company Employees and Minors:
a) The fundamental principle of all actions undertaken by employees is to act for the minor's well-being and in their best interests. Employees treat everyone with respect and take into account their dignity and needs. Physical or psychological violence against minors in any form is unacceptable;
b) the principles of safe relationships between employees and minors apply to all
employees, interns, trainees, and volunteers;
c) knowledge and acceptance of the principles are confirmed by a signed declaration.
2. Employees are obligated to maintain a professional relationship with minors and
always consider whether their reaction, message, or action is appropriate
to the situation, safe, reasonable, and fair to others.
3. Inappropriate behavior in the presence of minors is prohibited. It is prohibited to
use vulgar words, gestures, jokes, make offensive remarks towards minors,
refer to sexual activity or attractiveness in statements, or
exploit a power relationship or physical advantage (intimidation,
coercion, threats) towards a minor.
4. When interacting with minors, an employee:
a) treats the minor with respect;
b) listens to the minors and tries to provide them with a response appropriate to the situation and their age;
c) does not embarrass, disrespect, humiliate, or insult the minor;
d) does not shout unless a dangerous situation requires it (e.g., warning, providing
instructions justified by the circumstances);
e) does not disclose sensitive information about the minor to unauthorized persons,
this also applies to disclosing the minor's image. 4. The principle of equal treatment of minors applies, regardless of their gender, sexual orientation, disability, social, ethnic, religious, cultural, or worldview status.
5. Employees are obligated to maintain the confidentiality of information obtained in connection with their function or work performed, concerning minors.
4. Minors have the right to privacy; any deviation from this principle of confidentiality must be justified by objectively justified circumstances or applicable legal provisions.
5. Employees may not record images of minors for private, including professional, purposes, unless the minor's guardian has given consent.
§ 3
1. Any behavior that constitutes violence (both physical and psychological) towards a minor is prohibited. This includes, but is not limited to, behavior involving pushing, hitting, prodding, name-calling, insulting, or other similar behavior of a similar nature.
2. An employee may not touch a minor in a way that could be misinterpreted.
3. Physical contact between an employee and a minor is generally prohibited. The exceptions are situations where such contact is justified by the circumstances and does not lead to harm to the minor – e.g., demonstrating proper body positioning during exercise, providing first aid, or other situations threatening the minor's life/health. Therefore, the following rules must be observed:
1) You must not hit, push, prod, or otherwise violate the physical integrity of a minor,
2) You must not touch a minor in a way that could be considered indecent
or inappropriate,
3) You must not tickle, pretend to fight with minors, or engage in rough physical play,
4) Physical contact with a minor must never be secret or hidden, involve any form of gratification, or result from a power relationship,
5) In situations requiring assistance to a minor, contact other than that necessary to provide assistance must be avoided.
4. Establishing any romantic or sexual relationship with a minor, or making inappropriate propositions, is prohibited. This also applies to sexual comments, jokes, gestures, and sharing erotic and pornographic content with minors in any form. 5. Offering alcohol, tobacco products, e-cigarettes, energy drinks, or illegal substances to minors is prohibited, as is using them in the presence of minors.
6. An employee who is aware that a minor has suffered some form of harm, such as physical, psychological, or sexual abuse, is obligated to exercise particular caution in contacts with the minor, demonstrating understanding and sensitivity.
7. Situations where an employee remains alone with a minor in unmonitored rooms should be avoided, unless justified by special circumstances (e.g., a threat to the minor's life/health).
§ 5
1. Contact with minors outside of working hours is generally prohibited.
2. You may not invite minors to your place of residence or meet with them outside of working hours. This also applies to contact with minors through any private communication channels.
3. Meetings with a minor or their guardian should take place on Company premises. If it is necessary to contact a minor or their guardian outside of working hours, you should use the company telephone or email address.
4. If an employee needs to contact a minor or their guardian outside of Company working hours, they are obligated to inform the Person responsible for the Protection of Minors.
5. If an employee has a family or social relationship with a minor or their guardian, they are obligated to maintain complete confidentiality, in particular to keep confidential matters concerning other minors, guardians, and employees. 2. RULES FOR INTERVENTION IN SITUATIONS OF SUSPECTED ABUSE OF A MINOR
§ 1
1. In the event of abuse of a minor on the premises of the Company or managed by it, or suspicion of such abuse, any person witnessing the abuse or suspecting abuse (including a minor) should report this circumstance to a Company employee (e.g., a trainer, animator, receptionist).
Any person who receives information about an incident threatening a minor shall keep it strictly confidential and only forward it to the person responsible for receiving reports (SOM Coordinator). 2. If an employee observes (or is informed by a third party) any behavior by another person within the premises of the Company or managed by it that constitutes abuse of a minor, they are obligated to take action to eliminate such behavior, in particular by bringing the behavior to the attention of the person engaging in such behavior and immediately notifying their supervisor of the situation. The manager of the relevant park, in consultation with the Company's management, decides whether it is necessary to call the police. The employee who witnessed the incident prepares a memo (written or email) describing the situation and forwards it to the Child Welfare Coordinator, who then contacts the Company's management. 3. If an employee suspects that child abuse has occurred, or if such a circumstance is reported by the minor, the minor's legal guardian, or a third party, the employee is obligated to immediately notify the Child Welfare Coordinator of the situation. The SOM Coordinator, in consultation with the Management Board, decides whether it is necessary to call the Police. The employee then prepares a memo (written or email) describing the situation.
4. In the event of incidents on the premises requiring an immediate response, in particular, a threat to the life of a minor or a threat of serious bodily harm, the employee witnessing the incident immediately notifies the appropriate services by calling 112 (police, ambulance), then notifies their supervisor and prepares a memo.
5. In the event of abuse of a minor, the SOM Coordinator decides to inform the minor's legal guardian and, if necessary, also to report the suspected abuse to the appropriate institution (i.e., filing a report with the appropriate law enforcement authorities, the family and guardianship court, or the nearest social welfare center). 6. If the intervention concerns a prohibited act, the SOM Coordinator informs the Company's management board, which then submits a report of the suspected crime to the appropriate law enforcement authorities, the family and guardianship court, or the nearest social welfare center. 7. A note is prepared on each intervention and added to the Company's intervention register. A template for the note is provided as Appendix 2 to this document. 8. A template for the intervention register is provided as Appendix 3 to these regulations.
§ 2
1. If a minor is observed being harmed by a legal guardian, the SOM Coordinator will make every effort to clarify the situation with the legal guardian.
During the interviews, efforts should be made to determine the course of the incident, as well as the impact of the incident on the mental and physical health of the minor being harmed (findings are recorded in a note attached to the intervention register). In justified cases, the SOM Coordinator will inform the Company's management board of the incident, which will then prepare an application to the relevant family court or other authorized institution for access to the family's situation.
2. If a crime has been committed against a minor or there is a reasonable suspicion of a crime, the SOM Coordinator will inform the Company's management board, which will then prepare a report of a possible crime and forward it to the local police or prosecutor's office. 3. If a Company employee has reported a minor being harmed,
that person is removed from all contact with minors until the matter is resolved.
4. If a Company employee has committed a form of harm against a minor other than committing a crime against them, the SOM Coordinator should
investigate all circumstances of the case, in particular, listen to the person suspected of harming them, the minor (in consultation with their legal guardian), and other witnesses
to the incident. In a situation where the violation of the minor's well-being is significant, particularly if
discrimination or a violation of the minor's dignity has occurred, consideration should be given to terminating
the legal relationship with the person who committed the harm, or recommending such a solution to that person's supervisor. If the person who committed the abuse is not directly employed by the Company but by a third party, then it should be recommended that this person be banned from entering facilities owned or managed by the Company, and if necessary, the contract with the cooperating entity should be terminated.
5. If a suspicion of abuse of a minor is reported by the minor's legal guardian and the suspicion is not confirmed, the minor's legal guardian should be informed in writing or electronically.
6. If it is suspected that another minor is being abused while
on the premises of facilities owned or managed by the Company, e.g., during
sports activities, steps should be taken to prevent further
abuse, including conducting a conversation with the minor suspected of abuse
and their legal guardian, and separately with the minor being abused and their legal guardian. A note of the incident is prepared and then added
to the intervention register. If the suspected abuser is a minor
between 13 and 18 years of age and their behavior constitutes a criminal offense, the SOM Coordinator should
also be informed, who, in consultation with
the Company's management, will then notify the appropriate family court, institution, or police.
7. All persons who, in connection with the performance of their official duties, become aware of the abuse of a minor or information related thereto are obligated
to keep this information confidential, excluding information provided
to authorized Company employees and authorized institutions as part of intervention activities.
8. Documentation regarding the intervention is kept in a manner that ensures confidentiality,
for no longer than is required or in accordance with applicable law.
3. RULES FOR PROTECTING A MINOR'S IMAGE AND RULES FOR USING ELECTRONIC DEVICES WITH INTERNET ACCESS
§ 1
Employees, recognizing the minor's right to privacy and protection of personal rights, ensure the protection of the minor's image.
§ 2
1. An employee may not allow media representatives to record the image of a minor (i.e., filming, photographing) on Company premises without the written consent of the minor's guardian.
2. To obtain the consent of the minor's guardian to record the image of a minor, the employee must contact the minor's guardian.
3. It is prohibited to provide a media representative with the contact details of the minor's guardian without the knowledge and consent of that guardian. 4. If the image of a minor is merely a detail of a larger event, such as a gathering, landscape, or public event, the consent of guardians to record the minor's image is not required.
§ 3
1. Public disclosure of a minor's image recorded in any form (e.g., photograph, audio-video recording) by an employee requires the written consent of the guardian.
2. Before recording the image, the minor and the guardian must be informed of where the recorded image will be placed and in what context it will be used for promotional purposes.
§ 4
1. Due to the specific nature of activities for minors conducted on the premises of facilities managed by the Company, including sports activities and birthday parties, which exclude the possibility of using electronic devices with internet access during such activities, the risk of the minor being exposed to threats related to harmful content is negligible. The Company does not provide electronic devices with internet access to minors.
4. RULES AND PROCEDURE FOR PROVIDING THE STANDARDS TO PARENTS AND MINORS FOR THEIR READING AND APPLICATION
§ 1
1. The content of this document is public and generally available to minors, their guardians,
class participants, and Company employees, class participants.
2. The Standards for the Protection of Minors are available on the website at:
https://zagrywki.pl/wroclaw/regulaminy and at the reception of the facility at: Bogusławskiego
16, 50-031 Wrocław
5. UPDATING THE STANDARDS FOR THE PROTECTION OF MINORS AND THE SCOPE OF COMPETENCE OF THE COORDINATOR FOR MINORS SOM
§ 1
1. These Standards are subject to review, evaluation, and updating, at least once every two years, by the Company's Management Board in consultation with the SOM Coordinator.
2. The aforementioned activities are undertaken by
3. As part of the aforementioned activities, an interview or survey should be conducted among
employees to monitor the level of implementation of the Standards.
4. Conclusions from the activities referred to above should be documented in writing.
6. FINAL PROVISIONS
§ 1
1. The Standards for the Protection of Minors come into effect on the date of their announcement.
2. The announcement shall be made in a manner accessible to employees, participants of activities
organized by the Company, minors, and guardians, in particular by
posting them on the website and at the reception desk of the facility
at ul. Bogusławskiego 16, 50-031 Wocław
3. The legal basis for this document is:
1. Act of 13 May 2016 on Counteracting the Threat of Sexual Crime and the Protection of Minors (consolidated text: Journal of Laws of 2023, item 1304, as amended);
2. Act of 28 July 2023 amending the Act – Family and Guardianship Code and certain other acts (consolidated text: Journal of Laws of 2023, item 1606);
3. Convention on the Rights of the Child, adopted by the United Nations General Assembly on 20 November 1989 (consolidated text: Journal of Laws of 1991, No. 120, item 526, as amended).
